SOE Limitation Removal: The Complete §61.64(g) Guide

"Subject to pilot in command limitations." Five words on an otherwise perfect certificate, and suddenly the jet you're typed in isn't quite yours. This guide covers everything about the SOE limitation: why it exists, exactly what 14 CFR 61.64(g) requires to remove it, the logbook attestation rules that trip up most applicants, the IACRA mechanics, and what actually happens on removal day.

First: which SOE do you have?

"SOE" shows up on two very different certificates, and the removal paths are different. Sort yourself first:

• Type-rating SOE — your pilot certificate says something like "THE CE-525S IS SUBJECT TO PILOT-IN-COMMAND LIMITATION(S)." This is the §61.64 limitation and it's what this guide covers. It appears after a type-rating practical test completed entirely in the simulator.
• CFI SOE — your flight instructor certificate carries a Supervised Operating Experience limitation requiring supervised instruction hours before your instructing privileges are unrestricted. Different animal, different documentation (supervising-instructor endorsements rather than observing-PIC attestations). If that's you, go to SOE Limitation Removal (CFI) — the rest of this article is about type ratings.

Both removals are administrative — no checkride either way — and both are $200 flat at Daytona DPE. But the evidence the examiner needs is not the same, so make sure you're reading the right playbook.

Why your type rating has an SOE limitation

Modern type ratings are earned in Level C/D full-flight simulators — for most types, nobody is doing V1 cuts in the actual airplane anymore. The FAA is fine with that, with a catch. Under §61.64(b) (turbojets; §61.64(c) covers turboprops, (d) helicopters), you can take the entire practical test in the sim and walk away with an unrestricted type rating only if you already have meaningful heavy-aircraft experience — one of these:

• A prior type rating in the same class of airplane that doesn't itself carry an SOE limitation;
• 1,000 hours in two different turbojets of that class;
• Appointment by the U.S. Armed Forces as PIC in a turbojet of that class;
• 500 hours in the specific type you're testing for; or
• 2,000 hours total with 500 in turbine airplanes of that class.

Don't meet any of those? Then §61.64(f) gives two options: complete certain tasks of the practical test in the actual aircraft (preflight, normal takeoff, ILS, missed approach, normal landing) — which almost never happens in a standard sim course — or accept the rating with the limitation printed: "The [type rating] is subject to pilot in command limitations." Until it's removed, §61.64(f)(2) restricts you from serving as PIC in the type except under supervision.

This is why first jet types almost always carry SOE: the owner-pilot stepping out of a piston twin into a Phenom 100 or Mustang, and the regional FO upgrading into a CRJ or E175 seat, rarely have 1,000 turbojet hours behind them. The limitation isn't a comment on your checkride — it's an artifact of how the checkride was delivered.

The removal rule: §61.64(g), clause by clause

The regulation lists four requirements. Every one of them matters, because the examiner verifies each one before signing:

(g)(1) — 25 hours, in the type, under qualified observation

You need 25 hours of flight time in an aircraft of the category, class, and type the limitation applies to, flown under the direct observation of a PIC who holds the category, class, and type rating without limitations. Three things people get wrong:

• "In the type" is strict. The hours must be in the type rating the limitation names. E175 time can't clear an ERJ-190 SOE; a CJ can't clear a Mustang SOE. But where one rating covers multiple models — the CE-500 straight-wing Citation family, or the EMB-135/140/145 — mixed-model time all counts.
• The observer's rating must be unlimited. A supervising pilot who carries their own SOE on the type doesn't qualify. Verify before hour one.
• No instructor certificate required. The reg says PIC with an unrestricted rating — check airman, mentor pilot, contract captain, partner, all fine. A CFI ticket adds nothing here.

(g)(2) — every flight logged and attested in writing

This is where most removals stall. Each SOE flight must be logged, and the observing PIC must attest in writing to each flight. Not a blanket letter covering "approximately 25 hours." Not a text message. Not company training records. Per-flight, written, in or attached to your logbook, with the observer's signature and certificate number.

Good attestation wording identifies the flight, states the observer watched you perform the duties of PIC, and signs it. We publish exact sample language: → Sample SOE attestation wording (PDF)

(g)(3) — you fly it as acting PIC

The hours count only while you're performing the duties of pilot in command. You fly the airplane, run the decision-making, command the flight — the qualified observer observes. SIC time doesn't count. Riding along while the mentor demonstrates doesn't count. This is also why the arrangement works inside Part 121 operating experience: the upgrading captain performs PIC duties while the check airman observes.

(g)(4) — present the evidence, get it removed

Take the evidence to any Examiner or Flight Standards office and the limitation is removed administratively. No checkride, no additional training, no oral. The examiner's job is verification and paperwork — which is exactly why this action works well virtually.

How the 25 hours actually get flown, fleet by fleet

The reg is one-size-fits-all; the real world isn't. How SOE gets flown off depends on which seat you're sitting in:

Two notes that apply across the airline fleets. First, operating experience with a check airman almost always satisfies §61.64(g) — the check airman holds the unrestricted type, and you're performing PIC duties — so most 121 captains have the hours flown before line release, whether or not the paperwork followed. Second, many airlines process the removal in-house right after OE; if you changed fleets, were displaced, or left for a major before that happened, the limitation is still printed and any examiner can remove it. There's no time limit in the reg.

And one more reason not to carry it around: under §61.64(b)(1), a type rating with an SOE limitation doesn't count as the prior unrestricted type that would qualify you for an all-sim practical on your next type rating. The limitation can follow you into your next training event.

The IACRA application, in brief

SOE removal runs through IACRA like any certificate action. The short version:

1. Register/log in at iacra.faa.gov and have your FTN (FAA Tracking Number) handy.
2. Start an 8710-1 application for the limitation removal on your pilot certificate.
3. Complete your applicant sections — personal info, certificate held, and the removal being requested. Don't guess at fields; wrong entries mean starting over on the call.
4. Stop before the examiner sections. The examiner completes and signs their portion live during the appointment, after verifying your evidence.

We keep a field-by-field walkthrough with screenshots here: → IACRA walkthrough for SOE removal (PDF)

What removal day looks like

At Daytona DPE the whole action is a scheduled 20-minute video call, from anywhere — hangar office, crashpad, layover hotel. The sequence:

1. Before the call: you submit the contact form, get a document checklist within 24 hours, and send your logbook evidence ahead. We verify the 25 hours and every attestation against §61.64(g) before the appointment — if something's short, you find out then, free, with exact instructions on what to fix.
2. Identity verification: valid, unexpired government photo ID.
3. Certificate and logbook review: limitation confirmed on the certificate, hours and attestations confirmed against the reg.
4. IACRA: the application is signed live.
5. Issuance: temporary certificate without the limitation, issued on the call. The permanent plastic follows from the FAA by mail.

Scheduling note: FAA Designee Management System oversight requires appointments be entered at least 24 hours in advance, so same-day isn't possible — but 3–5 business days from first contact to unrestricted temporary is typical. Cost is $200 flat: no travel fees, no rescheduling fees, and no charge at all if the review finds you're not eligible yet.

Frequently asked

Is a checkride required to remove an SOE limitation?

No. Removal under §61.64(g) is purely administrative — verification of identity, certificate, hours, and attestations, then an IACRA signature. No flight test, no sim, no oral.

Who can supervise my SOE hours?

Any PIC holding the category, class, and type rating for the aircraft without limitations. Check airmen, mentor pilots, contract captains, and partners all qualify. Instructor certificates are irrelevant — and a supervising pilot who carries their own SOE on the type does not qualify.

Does SIC time count toward the 25 hours?

No. §61.64(g)(3) requires the time be flown while you perform the duties of PIC under the qualified observer. Watching from the right seat accumulates nothing.

Do airline OE hours count?

Usually yes — see the fleet table above. The flying almost always qualifies; the per-flight written attestations in your own logbook are what's typically missing. Get them during OE, not three years later from an airline you no longer work for.

Is there a deadline?

No. The reg has no time limit. We've processed removals for limitations issued years earlier — the evidence is all that matters.

Can this be done online?

Yes. SOE removals are administrative actions eligible for virtual processing under current FAA guidance — more on how that works at FAA virtual examiner guidance. Daytona DPE handles them worldwide.

Type-specific pages: CE-525S · CL-65 · ERJ-170/190 · ERJ-145 · EMB-505 · EMB-500 · CE-500 series · CE-510S — or start at the Type Rating SOE Removal hub. Also carrying a restricted ATP? See R-ATP to unrestricted ATP.