Does Simulator Time Count Toward ATP? FAA Credit Worksheet

Executive Summary

Simulator time can count toward a US airplane ATP, subject to the requirement being tested. Under FAA §61.159(a)(6), up to 100 hours combined in a full flight simulator (FFS) or flight training device (FTD) may support overall ATP or restricted-ATP experience when the device represents an airplane and the experience forms part of an approved course under Parts 121, 135, 141, or 142. This is credit toward a defined requirement, not a reason to relabel simulator sessions as aircraft flight time. ^{[1] [2] [3]}

The other caps must remain separate. The airplane-class requirement allows at most 25 qualifying FFS hours toward 50 required hours, and expressly excludes FTDs and aviation training devices (ATDs). The instrument requirement is 75 hours, with an ordinary FFS/FTD allowance of 25 hours, increasing to 50 for qualifying Part 142 training. Those allowances do not add to the overall device cap. ^{[1] [2]}

The report's hypothetical portfolio contains 1,420 eligible aircraft hours, 60 eligible FFS hours, 40 eligible FTD hours, and a separate 20-hour ATD record. If the FFS/FTD conditions are satisfied, the overall-experience subtotal is 1,520 hours, while aircraft flight time remains 1,420 hours. If approved-course evidence is missing for 30 FTD hours, the supported overall subtotal falls to 1,490 hours, with the missing-evidence sessions held unresolved. These are arithmetic examples, not proof that a pilot satisfies all ATP minima. The overall, class, instrument, cross-country, night, and command requirements still need their own evaluations. ^[4]

The practical method is to preserve each original session, attach its device and course evidence, and calculate a separate subtotal for each receiving requirement. FAA training-record provisions address instructor observation and endorsements; the current application requests applicable pilot-time and course information. The Airline Transport Pilot Certification Training Program (ATP-CTP) is a prerequisite for the airplane multiengine ATP knowledge test under §61.156 and does not remove those credit checks. The worksheet therefore keeps aircraft flight time, recorded lesson time, and credit used separately labeled, with an explicit queue for missing documentation. ^{[3] [5] [6]}

Introduction and Background

The practical question is rarely whether a pilot has ever trained in a simulator. It is whether an identifiable session supports the particular experience subtotal being reported. Under the United States Federal Aviation Administration (FAA) rules, flight time, pilot time, and credit toward a certificate requirement have different meanings. The flight-time definition concerns aircraft movement for flight; the pilot-time definition also includes authorized instruction in specified training devices. ^{[7] [8]}

An airline transport pilot (ATP) reconciliation should therefore preserve the original lesson and calculate its uses separately. Recurrent, type-rating, and ATP-CTP records may sit in different books; inventory each session before deciding which credit path applies. The FAA logging rule already distinguishes flight time from lesson time, while its instrument-training provisions address observation and signed records. The worksheet proposed here adds an evidence trail around those records. Its additional identifiers, review fields, and formulas are suggested audit practices, rather than a claim that every proposed column appears verbatim in the regulation. ^{[9] [3]}

This report addresses US airplane ATP and restricted-ATP records. It does not transfer FAA permissions to another licensing jurisdiction. Its rule review used the Electronic Code of Federal Regulations (eCFR), displaying Title 14 current through October 29, 2026, accessed for this report on October 31. The annual Code of Federal Regulations (CFR) publications provide supporting published text; their edition dates should not be mistaken for the live rule's currency. ^{[10] [2]}

The intended output is a reproducible explanation: what the receiving field means, which original sessions support it, which eligibility tests they pass, and how the applicable limit changes the result. A formatted report is an output from that process. For example, ForeFlight describes its application report as a guide to completing the FAA application, while CrewLounge PILOTLOG documents configurable treatment of simulator time in printed totals. Those reporting capabilities illustrate why a displayed total still needs a definition. ^[11] (Source: support.crewlounge.aero)

Key Changes: From Session Totals to Requirement Credits

Change the calculation, while preserving the source entry

The proposed process change is to stop asking one undifferentiated total to answer every question. It is not a claim that the FAA introduced new simulator-credit limits this month. Historical FAA rulemaking already discussed approved-course conditions and distinct class credit; today's application must use the current rule and actual session evidence. ^{[12] [4]}

Maintain these separate outputs:

• Aircraft flight-time total: retain the aircraft-only subtotal under its stated definition.
• Training-session total: preserve the duration recorded for each device lesson.
• Requirement credit: calculate the eligible portion for a named regulatory paragraph.
• Application entry: transfer the appropriate result into the receiving field, following its instructions.

The first distinction has a concrete FAA basis: logging flight time requires qualifying aircraft time, whereas device lessons can remain legitimate training records. Recording a lesson does not establish that its whole duration satisfies every certificate minimum. FAA advisory guidance expressly separates recording device training from limits on credit toward certification. ^{[3] [13]}

Identify the receiving question before totaling

The current FAA Form 8710-1, labeled March 2026, directs applicants to complete the pilot-time blocks applicable to the certificate or rating sought. Its instructions allow device time to contribute only as permitted by regulation. A field on the form cannot enlarge the underlying permission. ^[5]

Before generating totals, retain a copy of the receiving form or its instructions and record:

• Purpose: unrestricted ATP, a particular restricted-ATP pathway, or another defined report.
• Field definition: aircraft flight time, device time, pilot time, class credit, or instrument credit.
• Cutoff: the last included session and the report's preparation date.
• Units: the convention used for converting recorded durations.
• Authority: the rule paragraph and any applicable device or course approval.

These are worksheet controls, not a substitute form. FAA's Integrated Airman Certification and Rating Application (IACRA) help directs applicants to obtain instructor assistance as needed and ensure the hours are correct before submission. Airline reporting fields require their own definitions; the licensing calculation should not silently become a universal airline total. ^[14]

Keep three kinds of authority separate

The regulation establishes the requirement. A device's qualification or authorization establishes approved uses within its scope. An application's instructions establish where the supported figures go. FAA guidance describes Part 60 flight simulation training devices (FSTDs) separately from aviation training devices, and its application requests approved-course information rather than relying only on a simulator label. ^{[15] [5]}

A fourth layer, the worksheet, makes those relationships inspectable. An electronic logbook can help generate reports, but its category labels are not another licensing authority. LogTen, for example, distinguishes simulator category information from a Simulator Time field and offers grouping tools for separate totals. ^[16]

Session Inventory and Evidence Register

Build Table A before applying any cap. Each row represents an original session, identified by a stable reference that also appears on the supporting record. Preserve the recorded duration even when some or all of it remains uncredited. FAA logging requirements include date, lesson duration, device identification, and the type of experience or training; instructor endorsements have additional requirements. ^{[17] [3]}

Table A is a filled Hypothetical Example, independent of the larger portfolio in Table C. Every identifier, date, provider, approval, and endorsement below is an illustrative assumption. All sessions represent an airplane multiengine land (AMEL) configuration. In actual use, replace each assumed document with its source reference.

The table separates facts about the lesson from conclusions about credit. For an actual entry, a missing course reference remains an explicit open field. The existence of a provider, device, and duration does not fill that gap. FAA Form 8710-1's approved-course section requests agency or center identity, certification information, curriculum, and graduation information, supporting the need to retain the course connection. ^[5]

Gather an evidence packet with these components:

• Original entry: the paper page, signed training record, or original electronic record.
• Device identity: the identifier tied to the session, rather than a product-family nickname.
• Applicable approval: the document supporting the device's status at the session date.
• Configuration: the aircraft representation actually used for the training.
• Course connection: the approved syllabus or program and the session's place within it.
• Instructor record: the required observation, endorsement, and certification information.
• Instrument detail: the supported instrument portion, rather than an assumed percentage.
• Open issues: the missing item, who holds it, and what subtotal depends on it.

The LOA has a specific expiration date. ^[13]

Retaining the actual approval is also documented manufacturer practice. ELITE recommends keeping the authorization for examiner review and recording the aircraft make/model represented. AOPA's device-record discussion likewise identifies an FAA authorization as a key check. These sources corroborate the recordkeeping task; the legal credit still comes from the applicable FAA provision and approval. ^{[18] [19]}

Eligibility and the Separate FAA Credit Limits

Device status and approved context come first

A full flight simulator (FFS), flight training device (FTD), and aviation training device (ATD) are not interchangeable labels. The FAA definition places an ATD outside the FFS/FTD categories. Basic and advanced ATDs, abbreviated BATD and AATD, require examination of their actual approval rather than inference from cockpit appearance or marketing terminology. ^{[8] [15]}

For ATDs, keep the LOA and QAG accessible with the device. ^[13]

Class, instrument, and overall credits are parallel tests

Under US §61.159(a)(3), the airplane-class requirement is 50 hours, with at most 25 hours from an eligible representing-class FFS in an approved course under the specified parts. An FTD or ATD cannot satisfy this paragraph's class requirement. ^{[1] [4]}

The instrument requirement is 75 hours. The ordinary FFS/FTD simulated-instrument allowance is 25 hours; the rule permits up to 50 hours for qualifying training in a Part 142 training-center course. The device must represent an airplane. These are alternative constraints within instrument credit, not extra hours to add to the overall cap. ^{[2] [1]}

Table B applies those tests to Table A's Hypothetical Example. It assumes no other device credit has consumed the caps. Gross eligible time and credit used are calculated from the sessions, rather than prefilled with a maximum. All times in the calculated columns are hours.

The table does not authorize combining the maxima. A session may support more than one constrained requirement without creating additional elapsed time. A conservative worksheet also distinguishes an amount excluded by a known rule from an amount held unresolved for missing evidence. Both contribute no present credit, but they require different follow-up.

AATD credit requires a narrower question

AATD credit for ATP depends on the LOA. Evaluate instrument and overall credit separately. ^[13]

Implementation Considerations and Process Changes

Retain the entry, then calculate its uses

The working method is to keep the original record and attach a requirement-specific evaluation. Under US §61.51(g)(4), device time used for instrument aeronautical experience toward a certificate or rating requires the authorized instructor's observation and signed verification. Section 61.51(h) supplies the training-entry endorsement requirements. An unsupported summary cannot replace those underlying records. ^[3]

For each requirement row, apply this sequence:

1. Select: identify potentially relevant sessions by device, representation, and training purpose.
2. Verify: match the applicable approval and course evidence to each session.
3. Partition: use the documented qualifying portion for the requirement being tested.
4. Aggregate: sum each selected session or portion once within that requirement.
5. Constrain: apply the relevant cap and any narrower approval condition.
6. Reconcile: retain excluded and unresolved amounts alongside credit used.
7. Transfer: map the result to the receiving form's defined field.
8. Preserve: keep the source records and the dated calculation together.

This sequence is an audit design. It follows the distinction in FAA advisory guidance between recording training and crediting minimum experience. It avoids changing a signed historical lesson merely because only part of that lesson is being used on today's application. ^[13]

Paper and electronic methods should produce the same explanation

With paper records, enter a session reference in the worksheet and identify its original book and page. Keep approval documents and signed training records with the reconciliation. For ATD sessions, retain a copy of the LOA. ^[13]

With electronic records, inspect the device classification and report settings before exporting. MyFlightbook documents a Ground Sim field and filters for simulator versus real-aircraft entries. ForeFlight documents filtered experience reports. These functions can help produce separate inventories, but the pilot still needs the legal eligibility evaluation. ^{[20] [11]}

Other documented controls address specific failure points. LogTen offers a flight-audit check for simulator time assigned to a nonsimulator aircraft category. CrewLounge PILOTLOG can print a separate simulator record sheet. Use such controls to expose inconsistent classification or presentation before relying on the final subtotal. ^[21] (Source: support.crewlounge.aero)

For a pilot maintaining records in Pilot Logbook, retain the same source packet and requirement worksheet alongside the chosen logbook method. This recommendation makes no claim that a product automatically determines FAA credit. Readers considering that publisher's logbook can request an invite; the licensing calculation remains the separate evidence exercise described here.

An export also needs a preservation check. LogTen documents spreadsheet export but states that signatures and other images are excluded. Preserve those items through the appropriate original-record method instead of assuming that a spreadsheet is the whole logbook. MyFlightbook's guidance on comparing paper and electronic records recommends a spreadsheet running total to locate discrepancies. ^{[22] [20]}

Data Analysis and Evidence

Overall-experience reconciliation (Hypothetical Example)

Assume 1,420 eligible aircraft hours, 60 eligible FFS hours, and 40 eligible FTD hours. Assume all device hours meet the airplane-representation and approved-course conditions of US §61.159(a)(6). Add a separate 20-hour ATD record, without evidence establishing overall credit under that paragraph. These are constructed inputs, not observed pilot averages. The legal basis for the eligible device subtotal is the combined 100-hour FFS/FTD limit. ^{[1] [2]}

Table C calculates the distinct outputs and then tests a documentation gap.

The first column demonstrates that potential overall experience can reach 1,520 hours while aircraft flight time stays 1,420 hours. The recorded device-session inventory remains 120 hours. These figures describe different quantities; there is no need to force them to agree. The second column shows why missing approval evidence cannot be filled by a cap: 70 proven eligible hours remain usable on the assumptions, while 30 hours remain unresolved.

This establishes only an overall subtotal. It does not establish the remaining experience minima, other certification prerequisites, or entitlement to a certificate. US §61.159 separately addresses cross-country, night, class, instrument, and pilot-in-command experience, so a completed overall row cannot stand in for those checks. ^[4]

Overlapping categories (Hypothetical Example)

In the smaller Table A example, session S-A is an assumed eligible 4-hour FFS lesson, all acceptable for the overall and sought-class rows, with 3 hours documented as eligible instrument training. The worksheet can show 4 overall-credit hours, 4 class-credit hours, and 3 instrument-credit hours, subject to the relevant caps. It does not show 11 extra overall hours. The categories overlap; their totals are not an addition problem. ^{[4] [2]}

Session S-B, the assumed eligible 2-hour FTD lesson, increases the overall device subtotal to 6 hours. It contributes zero to the class row because the FAA paragraph excludes FTD class credit. Its assumed documented 1-hour instrument portion raises instrument credit to 4 hours. Session S-U remains unresolved and adds nothing to these credited totals. ^[4]

The reproducible rule is simple: within the overall device subtotal, use the union of eligible sessions, each once. Across requirement rows, show every legitimate constrained use and label the overlap. No public benchmark is needed for this calculation because the evidence consists of the stated hypothetical inputs, the applicable rule, and arithmetic.

Implications and Future Directions

Restricted ATP changes the pathway, not the need for evidence

US §61.160 provides conditional reduced-total pathways including 750, 1,000, and 1,250 hours. Those figures depend on the pathway's qualifications and documentation; they are not interchangeable targets available merely because a pilot has simulator time. The published annual rule provides the same threshold structure. ^{[23] [24]}

The restricted-ATP provisions retain other applicable experience requirements, with specified cross-country treatment. The overall simulator provision expressly refers to §61.160 as well as §61.159(a). A restricted-ATP worksheet should therefore name its pathway and evaluate each relevant requirement instead of merely replacing the ordinary total at the bottom of an unrestricted worksheet. ^{[23] [1]}

Historical FAA rulemaking is useful for understanding the separation: it discussed expanding approved-course contexts for device experience and established ATP certification training as its own component. It is background evidence, while the current rule governs today's credit evaluation. ^[12]

Maintain a reviewable record as documents evolve

When a document is missing, seek the source that can establish it:

• Device status: request the applicable qualification or authorization and its identification details.
• Course approval: request the program reference and the lesson-to-course link.
• Instructor evidence: obtain the original signed training record or resolve its missing fields.
• Instrument portion: obtain the supported duration rather than estimating from the session title.
• Receiving definition: obtain the form instructions or ask its administrator what the field includes.
• Final reconciliation: present unresolved items to the recommending instructor or evaluator before submission.

This is a proposed review checklist. Retain the LOA. A dated copy and a session reference make later calculations easier to reproduce than an unexplained aggregate. ^[13]

Frequently Asked Questions (FAQs)

Does simulator time count toward ATP or the 1,500 hours?

Yes, conditionally. US §61.159(a)(6) permits up to 100 hours combined from airplane-representing FFS/FTD experience in approved courses under Parts 121, 135, 141, or 142. It does not convert those sessions into aircraft flight time. Apply the rule to the records before adding the permitted credit to the relevant overall-experience subtotal. ^{[1] [3]}

Does simulator time count as total flight time?

Keep aircraft flight time separate from device credit. FAA's flight-time definition concerns aircraft movement for flight, while its ATD guidance says flight-time columns should remain blank for ATD lessons. A receiving field labeled only “total time” needs its own instructions; the label alone cannot identify the intended quantity. ^{[7] [13]}

Can AATD time count toward ATP?

Consult the device's LOA for allowable ATP credit. ^[13]

Does completing ATP-CTP make every simulator hour eligible?

No blanket conclusion follows from completion. The Airline Transport Pilot Certification Training Program (ATP-CTP) is a separate approved-course prerequisite for the relevant knowledge test. The FAA course rule specifies classroom and device training, including 10 FSTD hours and at least 6 hours in a Level C or higher FFS, with the required multiengine turbine representation and other stated conditions and deviation provisions. Each session's other credit still needs evaluation under the applicable experience paragraph. ^{[6] [25]}

How should simulator time be logged for ATP?

Record the identifiable session, its duration, training type, and required instructor information in the appropriate training record. Preserve the underlying entry and calculate requirement credits separately. In software, examine classification and reporting settings: ForeFlight recommends keeping simulated time separate in its Recap guidance, while LogTen distinguishes its Simulator Time field from other category handling. Neither convention replaces the FAA rule. ^{[3] [26] [16]}

What if the approved-course documentation is incomplete?

Keep the session in the inventory but mark the proposed credit unresolved. The overall FAA provision requires the approved-course connection, while the current application includes course-identification fields. Request the missing record and recompute only the affected requirement rows when it arrives. A documented smaller subtotal is reviewable; an assumed approval is not evidence. ^{[5] [2]}

Conclusion

Simulator time can support a US airplane ATP application, but the useful answer is a set of labeled, evidence-backed subtotals. The overall rule permits constrained FFS/FTD credit, the class rule has a narrower device allowance, and the instrument rule has its own conditions. ^{[2] [4]}

The proposed worksheet keeps the original session intact. Table A identifies the lesson and supporting records. Table B tests each licensing requirement independently. Table C demonstrates why an aircraft-only total, a training-session inventory, and a requirement-specific total can legitimately differ. Overlapping categories describe multiple uses of the same evidence; they do not create additional overall hours.

The practical deliverable is therefore more than a printed grand total. It is a source packet, a receiving-field definition, a list of eligible sessions, a transparent cap calculation, and an explicit register of unresolved items. Paper and electronic methods can both support that process. Software reports should be checked against their configuration and retained source material, particularly where exports omit signatures or images. (Source: support.crewlounge.aero) ^[22]

Before transferring the results, resolve the questions that determine eligibility and retain the calculation used for the application. FAA's application help emphasizes correct hours before submission. A reviewer should be able to move from a reported subtotal back to its sessions and evidence without reconstructing the pilot's assumptions. ^[14]