How a military pilot converts wings to an FAA commercial certificate and instrument rating under 14 CFR 61.73. Steps, documents by service, and the MCN test.
14 CFR 61.73 lets a military pilot apply for an FAA commercial pilot certificate and an instrument rating without a practical test. You pass one written test, gather your military records, and submit an application.
The rule was amended in 2009 and the knowledge test was replaced in 2018, so some older guidance no longer matches it. The Air Force has also stopped issuing the form that most checklists tell UPT graduates to bring.
The documents you need depend on where you are in your career.
Everything else on the page:
None of these steps involves a flight evaluation.
61.73(a) covers a commercial pilot certificate with the appropriate category and class rating, an instrument rating, and a type rating.
It excludes anyone removed from flying status for lack of proficiency or because of a disciplinary action involving aircraft operations. That exclusion applies to the whole section.
61.73(b) then requires three things:
Item 3 is written as an either/or. 61.73(h)(3) separately requires a record of a passed pilot proficiency check and instrument proficiency check, so the 10-hour route does not remove the need for checkride paperwork. It applies to a pilot who holds a check in one aircraft and needs to reach a rating tied to another.
A 12-month recency requirement is still widely repeated. The current rule does not contain one.
61.73(b)(3) says "Before the date of the application" for both the proficiency check and the 10-hour option, with no calendar limit attached. The 12-month window was in the earlier version and was removed by the amendment published at 74 FR 42555 on August 21, 2009, which is the citation printed at the end of the section.
A pilot who last flew a military aircraft in 2009 is still eligible, provided the records exist.
61.73 depends on graduating a manned undergraduate pilot training program. A pilot who completed manned UPT and later moved to RPAs keeps their eligibility, since the graduation and rating already occurred. A pilot trained entirely in unmanned aircraft does not qualify.
Request records before scheduling the test. The test takes one sitting. Records can take weeks, and for separated pilots they may be held at the National Personnel Records Center rather than by a unit.
61.73(h) describes what each document must show rather than naming a specific form. Services record the same information differently and form numbers have changed over the years, so treat the lists below as a starting point and bring anything related that you hold.
Qualification and instrument checks: AF Form 8, Certificate of Aircrew Qualification. AF Form 942, Record of Evaluation, covers the same ground for some evaluations.
Flight time: Your individual flight record printout from ARMS. Request both the flying history, which lists individual sorties, and the flying summary, which lists your qualifications over time.
Rating and graduation: Your Certificate of Aeronautical Rating, issued at the wings ceremony, along with your UPT training folder.
Recent UPT graduates: the Air Force no longer issues AF Form 8s to graduating UPT students. Your flying training squadron admin office issues a memorandum addressed to the Flight Standards District Office in its place. Request it by name before leaving the base.
Qualification and instrument checks: NATOPS evaluation reports, and OPNAV 3710/2, the NATOPS instrument rating request, which documents instrument qualification directly.
Flight time: Your flight logbook, OPNAV 3760/32, together with a monthly individual flight activity report from NAVFLIRS or IFARS.
Rating and graduation: Your designation letter as a Naval Aviator and your training jacket.
Form numbers on the NATOPS side have changed over the years and commands print different revisions. What matters is a check covering both airmanship and instruments, plus a record of hours by aircraft.
Flight time: DA Form 759, Individual Flight Record and Flight Certificate, with the 759-1 and 759-3 continuation forms. These are releasable to the FAA for licensing purposes.
Training and checks: DA Form 7122, Crew Member Training Record, and DA Form 7120 for your task list and evaluations.
Rating and graduation: Your Initial Entry Rotary Wing graduation certificate and aeronautical designation orders.
Army aviators generally receive Commercial Pilot, Rotorcraft-Helicopter with an Instrument Helicopter rating. Fixed-wing qualified Army pilots can reach airplane ratings on their fixed-wing records.
Flight time: OPNAV 3710/31, the Aviator's Flight Log Book, alongside Coast Guard flight activity records.
Qualification and instrument checks: Standardization and instrument check records, which follow the NATOPS pattern.
Rating and graduation: Designation as a Coast Guard Aviator plus training records. Coast Guard aviators train through the Navy pipeline, so early records will be Navy documents.
DD-214 if you have separated, showing an honorable discharge. If still serving, orders or a service record extract showing current status.
Government or state photo ID.
Your original FAA pilot certificate if you hold one, not a copy. If it is lost, order a replacement before the appointment.
Your original MCN test report. Examiners generally ask for the original rather than a copy.
Since October 2018 a single knowledge test covers all military applicants, replacing the earlier category-specific versions. The code is MCN, for Military Competence Non-Category.
| Questions | 50 |
| Time allotted | 2.0 hours |
| Passing grade | 70% |
| Minimum age | 18 |
| Endorsement required | None |
Those figures come from the FAA's Airman Knowledge Testing Matrix. The subject matter is set by 61.73(b)(2): commercial pilot privileges and limitations, air traffic and general operating rules, and accident reporting. It does not cover weight and balance, performance charts, or aerodynamics. The FAA publishes a dedicated ACS, FAA-S-ACS-12.
Most FAA knowledge tests require an instructor endorsement or a course completion certificate before a testing center will seat you. MCN is one of three tests in the matrix that requires neither, so you can schedule it through PSI directly.
On timing: 61.73(b)(2) attaches no expiration to the MCN result, unlike the instructor path in (g)(3)(i), which specifies 24 calendar months. In practice the offices processing these applications work to a 24-month convention, so plan around that.
Since there is no practical test, no instructor is required to review your missed questions. The PLT codes printed on the test report identify the subject areas, and the FAA suggests reviewing them yourself.
Complete FAA Form 8710-1 in IACRA. Register first and record your FTN, which you will be asked for at the appointment.
In the basis-for-application section you are claiming U.S. military competence. You will enter your service, the date you were first rated as a military pilot, your rank, and the military aircraft you have flown.
Allow a couple of days between the test and the appointment. Results are not transmitted to the FAA immediately.
Either a FSDO or a designee can process the application, and the resulting certificate is the same.
Locate a FSDO through the FAA office locator. Locate a designee through the FAA designee locator, searching pilot examiners and filtering to designee type MCFPE.
You leave with a temporary airman certificate valid for 120 days, and the permanent certificate arrives by mail.
Eligibility begins at graduation. 61.73(h)(2) requires graduation from a military undergraduate pilot training school and a rating qualification as a military pilot, and UPT checkrides are official military pilot and instrument proficiency checks. An operational aircraft qualification is not required.
Handle it before you PCS. Your training squadron's admin office can produce the paperwork while you are still assigned there. After a move, the same request goes to a unit you no longer belong to.
What to collect:
Your ratings depend on your track. See which ratings you get; in short, the T-6 supports single-engine land and the T-38 or T-1 supports multi-engine land.
A qualification and instrument check in an operational aircraft is the evidence described in 61.73(b)(3)(i), covering the category and class you were checked in. Bring that checkride along with your flying history and flying summary printouts.
Bring your UPT records as well. Class ratings follow your records airplane by airplane. If you went directly into a multi-engine platform, your operational checkride supports multi-engine land only. Single-engine land comes from your T-6 time. Without those records the single-engine rating is not on the certificate, and adding it later requires a civil practical test.
Bring your most recent instrument and qualification checkride along with the flying history and flying summary printouts. You do not need every Form 8 you have received, but include the ones covering each category and class you want rated.
On type ratings: 61.73(e) permits a type rating only for an aircraft with a comparable civilian type designation, as determined by the Administrator. Military airframes derived from airliners or business jets have a counterpart to map to. Purpose-built military aircraft generally do not. Trainers including the T-6, T-38, and T-45 have no civil type designation, so no type rating follows from them.
If you have separated, your records may now be held at the National Personnel Records Center. Request them before scheduling anything else, since that request usually sets the timeline for the rest of the process.
Ratings follow your records airplane by airplane. The category and class you were checked in, or logged 10 hours in, is what you can claim.
| What you flew | What it supports |
|---|---|
| T-6A/B Texan II, T-34 | Airplane single-engine land |
| T-38 Talon, T-1 Jayhawk, T-37 | Airplane multi-engine land |
| T-45 Goshawk | Airplane single-engine land |
| T-44 / TC-12 | Airplane multi-engine land |
| Rotary-wing training and operational aircraft | Rotorcraft-helicopter |
| Any of the above, with an instrument check | Instrument airplane or instrument helicopter |
The instrument rating is not restricted to the aircraft you were checked in. Once issued it applies to that category generally.
Anything your records do not cover is earned the civilian way, through training and a practical test. If that turns out to be the multi-engine rating, what multi-engine training involves covers the process.
Privileges you held on an FAA certificate before military training carry forward and are not affected by the new certificate.
61.73 contains no medical certificate requirement. Issuance is not conditioned on holding one, and since there is no practical test, the medical prerequisite in 61.39 does not apply. The certificate can be issued without an FAA medical.
Flying on it is a separate question. 61.23(b)(11) is often summarized as allowing military pilots to fly on their military physical, but the provision is narrower than that. It applies only where the flight requires no higher than a third-class medical and only to domestic flight operations within U.S. airspace.
Commercial privileges require at least a second-class medical under 61.23(a)(2)(ii), so the military physical does not cover the commercial flying the certificate authorizes. It covers private-privilege flying, domestically. The provision also refers to a military pilot, so it stops applying once you separate.
To obtain an FAA medical:
Request second class if you intend to fly commercially. A first-class exam issued to an applicant under 40 also carries second-class privileges for the remainder of its duration.
Military instructor pilots and pilot examiners have a separate path in 61.73(g), which likewise omits the practical test. You need to hold the commercial or ATP with the appropriate category and class, hold an instrument rating or instrument privileges appropriate to the rating sought, and present four things:
The 24-month limit here is explicit, where the commercial path has none. If you intend to do both, sequencing them close together avoids retaking the test. The CFI guide covers what the certificate is worth once you hold it.
61.73 stops at commercial. For the ATP, 61.160(a) allows a military or former military pilot to apply for a restricted-privileges ATP with a multi-engine class rating at 750 hours total time rather than 1,500.
You present a DD-214 showing honorable discharge, or a record showing current service, along with the record showing you graduated undergraduate pilot training and received a rating qualification. The removed-from-flying-status exclusion in 61.73 appears in 61.160 as well.
Once you are flying civil aircraft, flight record-keeping becomes your responsibility rather than the unit's. Part 61 record-keeping covers what you are required to retain, and the currency tracker handles the recurring dates.
This describes 14 CFR 61.73 as published and is not legal advice. The office or designee processing your application determines whether your records satisfy the rule. Form numbers vary by service and era; the rule specifies the content a document must show, not a particular form. Verify against the eCFR before filing.
No. 14 CFR 61.73 does not include a practical test. Your military pilot and instrument proficiency checks serve in its place. The MCN knowledge test is the only test involved.
Not under the current rule. 61.73(b)(3) requires the check or the 10 hours of pilot time to have occurred before the date of the application, with no calendar limit. The 12-month requirement that still gets cited was in the earlier version of the rule and was removed in the August 2009 amendment.
50 questions, 2.0 hours allotted, 70% to pass, minimum age 18. It covers commercial pilot privileges and limitations, air traffic and general operating rules, and accident reporting. It requires no instructor endorsement to sit for, which is uncommon among FAA knowledge tests.
UPT checkrides count. 61.73(h)(2) requires graduation from a military undergraduate pilot training school and a rating qualification as a military pilot, both of which you hold once you have wings. Air Force UPT graduates no longer receive AF Form 8s at graduation, so their squadron issues a memorandum addressed to the FSDO instead.
You receive the category and class your records support. T-6 or T-34 time supports airplane single-engine land. T-38, T-1, or T-37 time supports multi-engine land. A pilot who flew only multi-engine aircraft receives AMEL alone, and adding single-engine later requires a civil practical test.
Only if you graduated a manned-aircraft pilot training program. A pilot who completed manned UPT and later moved to RPAs remains eligible. A pilot whose training was entirely in unmanned aircraft does not qualify under 61.73.
Within limits. 61.23(b)(11) permits a current military pilot to fly on an up-to-date military medical examination, but only for flights not requiring higher than a third-class medical and only for domestic operations inside U.S. airspace. Commercial privileges require at least a second-class medical, so the military physical does not cover flying for hire, and the provision does not apply to former military pilots.
Military instructor pilots and pilot examiners can, under 61.73(g). It is a separate application with its own knowledge test (MCI, 125 questions, 3.0 hours), and that test must have been passed within the preceding 24 calendar months.