The Solo Cross-Country Requirement Every Student Pilot and CFI Must Know
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Editor’s Note: Many student pilots think they can tackle their first solo cross-country flight without any instrument flying. Not so fast. DPE Jason Blair explains why 14 CFR 61.93(e)(12) requires pre-solo instrument training—and how skipping it can create legal issues and, more importantly, safety risks.
As a DPE, I test many CFI candidates each year. A big part of that process is evaluating whether they “know how to do the job” administratively—not just how to teach a turn around a point or a chandelle. In the training pathway, some tasks must be completed in the proper order to remain technically compliant with the regulations.
One requirement I regularly find either completed out of order—or not completed at all—is the requirement to provide a student with basic attitude instrument skills training before they conduct any solo cross-country flying.
Solo cross-country flight is a rite of passage, often completed soon after what may be the biggest milestone of all: the first solo. After some dual cross-country training with their CFI, a student pilot heads off alone to transit from one airport to another some distance away.
Cross-country flights introduce variables such as changing weather, navigation challenges, and the potential for inadvertent entry into instrument meteorological conditions (IMC). Even in visual flight rules (VFR) conditions, basic instrument skills can be lifesaving if disorientation sets in or visibility deteriorates. The FAA recognizes this—hence the requirement.
Understanding the Basics: What Is 14 CFR 61.93?
Section 61.93(e) applies to the airplane category and lists 13 maneuvers and procedures that must be demonstrated and logged with an authorized instructor before solo cross-country flight. These range from airport operations and traffic patterns to emergency procedures and night operations (if applicable).
Our spotlight today is on paragraph (e)(12), which reads verbatim:
“Control and maneuvering solely by reference to flight instruments, including straight and level flight, turns, descents, climbs, use of radio aids, and ATC directives. For student pilots seeking a sport pilot certificate, the provisions of this paragraph only apply when receiving training for cross-country flight in an airplane that has a VH greater than 87 knots CAS.”
This isn’t optional fluff—it’s a mandatory training competency that must be provided by a CFI and documented in the student’s logbook. Without it, a solo cross-country endorsement under § 61.93(c) is not technically valid.
This regulation mandates specific training in controlling and maneuvering an aircraft solely by reference to flight instruments before a student pilot can embark on solo cross-country adventures. It includes essentials such as straight-and-level flight, turns, descents, climbs, use of radio aids, and following ATC directives.
What’s particularly nuanced—and commonly missed—is that this requirement also applies to sport pilot certificate seekers when training in aircraft with a maximum cruising speed (VH) greater than 87 knots calibrated airspeed (CAS).
Many CFIs working with sport pilots—something that is becoming increasingly common with recent MOSAIC changes—assume that because there is no minimum instrument-hour requirement for a sport pilot (as there is for a private pilot), no instrument training is required at all. That assumption is incorrect.
A CFI Catch: Who Can Give This Training?
To make matters more confusing, a sport pilot CFI cannot provide this training unless they have first received it themselves. According to AC 61-65K:
“For those flight instructors with a sport pilot rating and single-engine airplane privilege who wish to provide training on control and maneuvering an airplane solely by reference to the instruments to their students pursuing a sport pilot certificate, they must receive the 3 hours of training described in 14 CFR § 61.412 and receive an endorsement from a 14 CFR part 61 subpart H instructor, qualifying them to provide that instruction.”
In other words, a sport-pilot-only CFI who first earned a sport pilot certificate and then their sport pilot CFI would not be eligible to provide this training unless they had met the three-hour instrument training requirement. It’s a quirk—but one that matters.
Where the Hiccup Happens in the Training Order
One of the most prevalent issues I see in logbooks during practical tests is the tendency for CFIs to postpone instrument training until the tail end of a student’s program, often right before the checkride.
A common sentiment is, “We’ll knock out the instrument stuff after you’ve got your XC legs under you.” But this approach does not reflect the correct regulatory training order.
The full three hours of instrument training required for a private pilot certificate do not need to be completed before solo cross-country flying. However, the CFI must have provided some instrument training covering the required skill areas before endorsing any solo cross-country flight.
The same principle applies to sport and recreational pilots. While there is no minimum time requirement, the student must receive dual instruction in these areas prior to solo cross-country flight.
From a safety standpoint, early exposure to instrument flying builds foundational skills that enhance all aspects of training. Spatial disorientation remains a leading cause of general aviation accidents, according to NTSB data. Introducing instrument references early teaches students to trust their instruments over their senses, reducing the risk of graveyard spirals or controlled flight into terrain during unexpected reductions in visibility.
Delaying this training can also lead to rushed instruction. I’ve seen students cram instrument maneuvers into a single flight just to “check the box,” missing the deeper understanding needed for real-world application. The FAA’s intent is proficiency—not mere exposure.
Busting the Myth: Is This Really Required for Sport Pilots?
The sport pilot certificate, introduced in 2004 to make flying more accessible, comes with lighter requirements: no medical certificate, fewer training hours, and limitations to lighter aircraft.
A widespread misconception is that sport pilots are completely exempt from instrument training under § 61.93(e)(12). A partial reading of the regulation fuels this belief. Yes—if a sport pilot is training in an aircraft with a VH of 87 knots CAS or less, this paragraph does not apply.
But here’s the critical caveat: if the training aircraft exceeds 87 knots CAS, the instrument training requirement applies in full.
VH is the maximum speed in level flight with maximum continuous power, as defined in the aircraft’s certification basis. Many aircraft commonly used today—such as Cessna 172s and Piper Cherokees—have cruising speeds in the 100–110 knot range and are now eligible to be flown by pilots exercising sport pilot privileges.
The 87-knot threshold reflects the FAA’s original intent to limit sport pilots to slower, simpler aircraft operating primarily in VFR conditions. Faster aircraft introduce greater weather exposure and decision-making challenges—hence the need for basic instrument competency.
To be clear: sport pilots are not required to complete a minimum number of instrument hours. But when training for solo cross-country flight in faster aircraft, this specific pre-solo instrument training is required. It’s not about becoming an IFR pilot—it’s about survival skills.
“But the Sport Pilot Requirements Don’t List This…”
A common argument is that § 61.313 (“What aeronautical experience must I have to apply for a sport pilot certificate?”) does not list this requirement.
That’s true—but it misses the regulatory framework. When a pilot is acting as a student pilot for any initial certificate (sport, recreational, or private), the student pilot regulations in §§ 61.81 through 61.95 apply. Section 61.313 governs eligibility for the certificate itself, not the training and endorsement requirements that apply while the applicant is still a student pilot.
That brings us right back to § 61.93(e)(12).
Why Early Integration Makes Sense
Rather than delaying, the better approach is early and progressive integration of instrument training. Begin in ground school by explaining attitude indicators, altimeters, heading indicators, and basic navigation concepts. In flight, incorporate short hood segments during dual lessons—10 to 15 minutes at a time—to practice basic control, unusual attitude recovery, or escaping inadvertent IMC.
This approach offers multiple benefits:
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Safety: Early exposure demystifies the instrument scan and builds confidence.
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Efficiency: For private pilots, it counts toward the three-hour requirement in § 61.109. For sport pilots in faster aircraft, it satisfies the requirement without excess.
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Confidence: Students often associate instruments with “advanced IFR flying.” Early exposure turns fear into familiarity.
Practicing a simple 180-degree turn under the hood during a local dual flight is empowering—and directly applicable to cross-country scenarios where a student may need to divert or return due to marginal VFR.
Final Thought
14 CFR 61.93(e)(12) isn’t a hurdle—it’s a gateway to safer, more competent flying. And it is a requirement that must be met before sending any student pilot on a solo cross-country flight, regardless of the certificate they are pursuing.
Don’t wait until the end. Integrate it early.
A NAFI Master Flight Instructor and 2023 Michigan FAA Safety Team Representative of the Year, Jason has over 30 years of flying experience and two decades as a flight instructor. He was named 2016 Michigan CFI of the Year and has served as Executive Director of the National Association of Flight Instructors. His service includes national committees such as the FAA’s Runway Safety Council, the General Aviation Joint Steering Committee, and the TSA Aviation Safety Advisory Council.
In addition to examiner duties, Jason works with aviation associations and companies as a consultant and writer, focusing on pilot training, testing, and safety. He holds undergraduate degrees in Human Resource Management and International and Comparative Politics, plus a master’s degree in Development Administration from Western Michigan University. Originally from Michigan’s Upper Peninsula, he is an avid outdoorsman who enjoys scuba diving, skiing, hunting, fishing, mountain biking, and golfing.
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I’m still a student pilot and all of these lessons are greatly appreciated. I learn and apply everything
I had a great paperwork/DPE mentor who pointed me in the right direction with my Light Sport students concerning this. I’m sure I would have let them go without “Instrument Training” if she hadn’t counselled me on it. It would help if this was mentioned in the FARs concerning Light Sport students. 14 CFR 61.313 should state this and give it a minimum time requirement.
What good is instrument training ifyou are Sport Pilot flying an aircraft that is not instrument equiped, e.g. a Cub or Champ???
They usually have a compass, turn coordinator and altimeter – just like the 20s and 30s. That’s all you need. Go practice. (and enjoy). You can do this.
My training in Cubs and Champs only had a compass. An Altimeter would have been greatly appreciated.