CFI Recent Experience & Reinstatement — The Dec 2024 Rule, Explained by a DPE

What changed on December 1, 2024

The FAA's final rule titled "Removal of Expiration Date on a Flight Instructor Certificate; Additional Qualification Requirements To Train Initial Flight Instructor Applicants; and Other Provisions" (89 FR 79968, published Oct 1, 2024) eliminated the practice of printing an expiration date on the CFI certificate. The rule has a two-phase rollout: Phase 1 effective December 1, 2024 (the recent-experience framework) and Phase 2 effective March 1, 2027 (additional qualification requirements for those who train initial CFI applicants).

Three CFR sections work together to define the new framework:

• 14 CFR §61.19 — Duration of pilot and instructor certificates. As amended, the CFI certificate is issued without an expiration date.
• 14 CFR §61.197 — Flight instructor recent experience requirements. Lists the qualifying methods to establish recent experience for another 24 calendar months.
• 14 CFR §61.199 — Expired flight instructor certificates and ratings (reinstatement). Governs what happens when a CFI fails to establish recent experience and the 3-month grace closes.

The Recent Experience End Date (REED) — the new 24-month clock

The REED is a rolling deadline. The first REED for any CFI is set at 24 calendar months from the date you most recently completed a qualifying §61.197 method (for existing CFIs, the printed expiration date on the old plastic is treated as your first REED). When you establish recent experience again before that date, the REED rolls forward another 24 months.

The REED gates the privilege to instruct, not the certificate itself. You can hold a CFI certificate indefinitely. You can exercise it only when the REED is in the future.

The five qualifying recent-experience methods (§61.197)

Establish any one of these in the 24-month period ending on or before the REED, and your recent experience is reset for another 24 months:

1. FIRC graduation — Complete an FAA-approved Flight Instructor Refresher Course within the prior 3 calendar months of the application. This is by far the most common method; multiple FAA-approved FIRC providers run online courses, typically 16 hours over 1–2 weeks.
2. Graduate-of-students activity — Endorse at least 5 different students for a practical test within the prior 24 calendar months, with 80% or better first-attempt pass rate. The records must be defensible (logbook entries, IACRA artifacts, recommending-instructor endorsements).
3. Examiner activity — Service as a DPE, Aircrew Program Designee, FAA Aviation Safety Inspector, or chief instructor of an approved Part 141 pilot school within the prior 24 months.
4. FAA inspector check — Pass a flight instructor proficiency check administered by an FAA Aviation Safety Inspector. This is the least-common path because inspector availability is limited, but it remains on the books.
5. WINGS-based (added by the 2024 rule) — Complete one phase of the FAA WINGS pilot proficiency program and conduct 15 flight activities during which you evaluated at least 5 different pilots, with appropriate logbook endorsements, in the prior 24 months.

You arrive at the DPE appointment with documentation of one of the above. Daytona DPE doesn't run the FIRC, doesn't sign your students' tests, and doesn't run WINGS — the DPE's job is the administrative step that records your recent experience with the FAA via the 8710-1.

The DPE-validated 8710-1 is still required

This is the most common point of confusion about the Dec 2024 rule. The rule did not change who validates the FAA Form 8710-1. Per the December 2024 revision of FAA Form 8710-1 and the rule preamble, the 8710-1 must be validated by a certifying official — a DPE, ACR, or FAA inspector — via IACRA. Flight instructors cannot self-file directly to the FAA.

So even though the certificate no longer "expires," the administrative step a DPE handles is unchanged. Daytona DPE conducts this virtually for $200 flat in about 20 minutes.

When the REED passes: the 3-month FIRC grace window

The moment a REED passes without recent experience being established, the CFI's instructional privileges are immediately suspended. The certificate is not revoked; the privilege to teach simply pauses. A 3-calendar-month grace window opens.

Inside the grace window:

• You may NOT give instruction, sign endorsements, or recommend students for practical tests.
• You MAY enroll in and complete an approved FIRC.
• You MAY then complete an administrative 8710-1 with a DPE or FSDO inspector. The recent experience is reset; the temporary certificate is issued same-appointment; privileges resume immediately.

The same-day FIRC-graduation → DPE-appointment workflow is the most common reinstatement scenario Daytona DPE sees inside the grace window. Schedule the appointment →

After the 3-month grace closes: §61.199 practical test

If 3 calendar months pass after the REED without recent experience being reestablished, the FIRC-administrative pathway is no longer available. Under §61.199 the CFI must take a flight instructor practical test to reinstate the privilege. This is a full ACS practical — oral plus flight portions — administered in person by a DPE or FAA inspector.

Daytona DPE focuses on administrative actions and does not conduct initial CFI practical tests. For a §61.199 reinstatement practical, locate a DPE at designee.faa.gov.

Existing CFI certificates with printed expiration dates

Hundreds of thousands of CFIs hold certificates issued before December 1, 2024 with a printed expiration date. Those certificates remain valid. The FAA treats the printed date as your initial REED. You'll continue establishing recent experience under §61.197 on the same 24-month cycle you were already on. The next time the certificate is replaced (lost/damaged/upgraded), the new certificate will be issued without an expiration date.

What didn't change

• The 24-month interval for recent experience.
• The DPE-validated 8710-1 requirement.
• The 3-month FIRC grace window.
• The §61.199 practical-test fallback after grace closes.
• The administrative nature of the recent-experience step — no checkride, no flight component when handled inside grace.

Where Daytona DPE fits in

The recent-experience step is exactly what Daytona DPE handles — virtually, worldwide, in about 20 minutes for $200 flat. Whether you're establishing recent experience proactively before your REED or inside the 3-month grace after, the administrative action is the same.

Sources and primary citations

This page is written by an FAA-designated DPE and grounded in the primary FAA sources:

• 89 FR 79968 — Final rule, "Removal of Expiration Date on a Flight Instructor Certificate" (Oct 1, 2024 publication; Phase 1 effective Dec 1, 2024).
• 14 CFR §61.19 — Duration of pilot and instructor certificates.
• 14 CFR §61.197 — Flight instructor recent experience requirements.
• 14 CFR §61.199 — Expired flight instructor certificates and ratings.
• FAA Form 8710-1 (Dec 2024 revision) — Airman Certificate and/or Rating Application.
• FAA Clarification Statement — issued to FIRC providers explaining the recent-experience framework after the rule's effective date.

Frequently asked