Do you know the new IFR recency rules?
When it comes to IFR currency in Canada, we all grew up with the classic "6-6-6" rule. Transport Canada has officially overhauled instrument rating recency under CAR 401.05, completely changing how you maintain your privileges.
Generations of pilots grew up with the classic "6-6-6" rule—6 hours of instrument time, 6 approaches, and a 6-month rolling window.
Transport Canada has officially overhauled the instrument rating recency requirements under CAR 401.05(3.1) and (3.2). This change modernizes how instrument-rated pilots maintain their privileges, shifting the focus from purely logging flight hours to demonstrating active proficiency and strict record-keeping.
What Has Changed?
The 6-Hour Rule is Gone
You no longer have to log 6 hours of instrument time within the preceding 6 months. Transport Canada realized it didn't make sense to force pilots to go up "under the hood" just to burn fuel and log hours. The strict hourly time requirement has been completely eliminated.
The "Grace Period" Shrank
Under the old framework, passing an IPC or flight test granted a 12-month grace period before rolling currency kicked in. Now, that grace period is only 6 months. Starting on the first day of the seventh month following your test or check, you must have completed your approaches.
You Still Need 6 Approaches (With More Flexibility)
While the hours are gone, you must still complete 6 instrument approaches (in accordance with published minima) within the preceding 6 months. The new rules focus strictly on performance and whether you can successfully execute the maneuvers.
Where You Can Log Them (CAR 401.05(3.1))
- In Aircraft: Actual or simulated IMC.
- As Instructor: Teaching towards an endorsement.
- Simulators: Level B, C, or D full-flight sims.
- Approved FTDs: Under Standard 425.21(9) supervision.
Heavy Focus on Specific Competencies
It’s not just about flying generic approaches anymore. To stay compliant—especially for cross-border FAA/TCCA agreements—your currency tasks must explicitly include holding procedures and intercepting/tracking courses via electronic navigation systems.
The 3-Year Record Keeping Rule
Under CAR 401.05(3.2), Transport Canada requires strict accountability. You are legally required to retain a record proving you have met your applicable recency requirements for three (3) years.
Whether you keep a digital logbook, a paper logbook, or simulator completion certificates, ensure your entries clearly record the date, location, type of approach, and supervision details. If Transport Canada conducts an audit, the burden of proof is on you.
At a Glance: Old vs. New Framework
| Requirement | Legacy "6-6-6" Rule | New CAR 401.05 |
|---|---|---|
| Grace Period Post-Check | 12 Months | 6 Months (Rolling recency begins day 1 of month 7) |
| Hourly Requirement | 6 hours instrument time | Eliminated (0 hours) |
| Required Approaches | 6 approaches | 6 approaches to published minima |
| Sim / FTD Logging | Strict limitations | Level B/C/D Sims + FTDs under 425.21(9) |
| Record Retention | General logbook rules | Mandatory 3-Year Retention |
What Has NOT Changed?
The 24-Month Rule remains exactly the same. Your Instrument Rating itself never actually expires from your aviation document. Once you earn it, you never have to retake the initial written exams or the initial flight test, even if you don't fly IFR for a decade.
However, Transport Canada separates holding a rating from having the privilege to use it. Every 24 months, you must complete an Instrument Proficiency Check (IPC), a formal flight test, or an airline PPC.
The "Driver's Licence" Analogy
Think of it like a car. Your rating is your driver's licence—you have it forever. Your currency is having insurance and gas. If you don't have them, you can't drive the car today, but you don't lose your licence. You just need to fill the tank (log your approaches or do an IPC) to go flying again.
Are You Legal to File Today?
Run through this interactive audit checklist based on CAR 401.05(3.1) and (3.2) before you act as PIC under IFR.
Check all 7 boxes to verify full regulatory compliance before exercising IFR privileges today.
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