Pilot currency: the one clock the FAA keeps, and the one you keep
Ask a crew lead whether a pilot is current and you can get two different answers. One is about the rule: has this pilot done the recurrent training the FAA requires? The other is about the pilot: have they flown enough lately to put on a client job tomorrow? Part 107 answers the first question and says nothing about the second.
This article covers the rule, what it does and does not require, and the second clock that a crew keeps for its own reasons.
The FAA’s clock: § 107.65
Part 107 has exactly one recency rule. Under § 107.65, a remote pilot may not exercise the privileges of the certificate unless, “within the previous 24 calendar months”, they have done one of two things:
- passed the initial aeronautical knowledge test; or
- completed recurrent training covering the same areas of knowledge.
The certificate does not lapse. What lapses is the pilot’s right to use it. § 107.12 makes the connection: nobody may act as remote pilot in command, or fly the aircraft at all, without a certificate and meeting § 107.65. The one exception is a person flying under the direct supervision of a remote pilot in command who can take control immediately. (14 CFR § 107.12.)
For most crews, the recurrent route is the one that matters. It is an online course, the FAA’s Part 107 Small UAS Recurrent (ALC-677), and it is free on FAASafety.gov. The other route is to sit the initial knowledge test again at a testing center, which costs a fee. (FAA Safety Team notice; ALC-677.)
Calendar months, not days
“24 calendar months” runs to the end of a month, not to the anniversary date. The FAA Safety Team’s own example: complete ALC-677 on April 6, 2021, and you may fly under Part 107 through April 30, 2023. (FAA Safety Team notice.)
That gives every pilot one date that matters: the last day of the month, 24 months after their most recent course or test. Write that date down, not the day they took the course.
What a pilot carries
§ 107.7 requires the remote pilot to have the certificate and an identification in their physical possession when flying, and to show both on request to the FAA, the NTSB, the TSA or a law enforcement officer. (14 CFR § 107.7.) The rule does not ask the pilot to carry proof of the recurrent course. Keep the completion certificate anyway, with the pilot’s record. It is the only document that shows the clock was reset.
What Part 107 does not have
There is no flight-recency rule in Part 107 — no minimum takeoffs, landings, or flight hours in the preceding 90 days. Someone who passed the recurrent course last month and has not flown in a year meets § 107.65 in full.
That is a fact about the rule, not a statement about safety. Hand skills fade on a schedule that has nothing to do with knowledge recency. A pilot can be fully legal and still badly out of practice on the aircraft you are sending them out with.
The clock you keep: recent flying
So most crews keep a second clock: days since the pilot last flew. Nobody requires it. It is the crew’s own policy, kept for the crew’s own reasons:
- Putting the right pilot on the job. A multi-aircraft day, a tight site or a client’s first flight is not the place for someone’s first flight in four months.
- The insurer. Insurers ask about pilots, not only aircraft. SkyWatch, a drone insurer, lists “pilot qualifications” among the documentation every claim needs. (SkyWatch on record-keeping.) BWI, an aviation broker, writes that general-aviation underwriters look at a pilot’s “time in last 90 days and 12 months”. (BWI on underwriting.) That is manned aviation, and no drone insurer we found publishes a recency requirement. But it is the question an underwriter knows how to ask.
Pick your own thresholds
Because the clock is yours, so are the numbers. A common shape is two thresholds: a warning at, say, 60 days since the last flight and an overdue mark at 90. Choose numbers that fit how often your work actually flies. A mapping crew that flies every week and a team that flies one event a quarter will not want the same ones.
Decide in advance what a threshold means. For most crews it is a prompt, not a ban: a short practice flight, or a job flown with a senior pilot, before that pilot leads a client job again. A threshold nobody acts on is just a number on a list.
Be honest about what your log sees
Your records see only the flying a pilot did with you. A freelancer who flew three jobs last week for someone else looks stale in your log. A part-time pilot who flies their own aircraft at weekends looks the same.
So call the number what it is: last flight with us. Ask a pilot who looks overdue whether they have been flying elsewhere before you treat the number as a problem. And don’t put it in front of a client as if it were a regulatory status. The only regulatory status is § 107.65.
Running both clocks across a crew
A crew of three can do this in their heads. A crew of eight, half of them freelance, cannot. Four habits keep both clocks honest:
- One record per pilot. Certificate number, the date of the last recurrent course or test, the month-end date it runs to, and the date of their last flight with you. If it lives in three places, it will be out of date in two of them.
- Look at the job date, not today. The question is not “is this pilot current now?” but “will they be current on the day of the job?” A pilot whose § 107.65 month ends on the 31st cannot fly your job on the 2nd. A pilot at 50 days today is at 75 on a job three weeks out.
- Book the recurrent course early. It is free and online. Do it in the month before the clock runs out, not on the last day: the FAA itself has warned pilots that the course site can be slow when traffic is high (FAA).
- Get the proof from freelancers. A copy of the certificate and of the latest completion certificate, on file before their first job and again each time their clock resets.
None of this is hard. It needs two dates per pilot, kept where the crew schedule can see them.
Tobren Operations is built around this record: the flight log, the aircraft and battery history and the crew behind them, in one place. Start free; the Free plan never expires, and the pricing is on the Operations page.
See it with your own fleet.