One of the most misunderstood aspects of flight instructor currency is the so‑called “grace period” after a CFI’s recent experience lapses.
Yes, a limited reinstatement window does exist.
But it is not a grace period to keep teaching.
This article explains exactly how the 3‑calendar‑month reinstatement window under 14 CFR §61.199 works, who it applies to, and where instructors get into trouble.
First: What Triggers §61.199?
Section 61.199 only becomes relevant after a flight instructor has failed to meet the recent experience requirements of §61.197 within the required 24 calendar months.
At that point:
Your CFI certificate remains valid
Your flight instructor privileges lapse
You must immediately stop instructing and endorsing
There is no automatic extension and no authority to continue teaching.
The 3‑Calendar‑Month Reinstatement Window
Under 14 CFR §61.199, the FAA allows a limited reinstatement pathway if no more than 3 calendar months have passed since the end of your 24‑month recent experience period.
This is what most people loosely (and incorrectly) call the “CFI grace period.”
What the rule actually allows
If you are within this 3‑month window, you may reinstate your flight instructor privileges by completing an FAA‑approved Flight Instructor Refresher Course (FIRC) instead of taking a flight instructor practical test.
This is a reinstatement provision, not a continuation of privileges.
What You May and May Not Do During the Window
This distinction is critical.
What you may NOT do
During the 3‑month reinstatement window, you may not:
Provide flight instruction requiring a CFI
Sign logbook endorsements
Recommend applicants for knowledge or practical tests
Teaching during this period is a regulatory violation.
What you MAY do
You may:
Enroll in and complete an FAA‑approved FIRC
Prepare documentation for reinstatement
Resume instructing only after reinstatement is completed and processed
Why FIRC Is Allowed After a Lapse (But Only Briefly)
The FAA’s intent with §61.199 was to avoid forcing an immediate practical test for instructors who:
Simply missed a deadline, and
Correct the lapse quickly
The 3‑month limit draws a hard line between:
Administrative lapse (handled via FIRC), and
Extended inactivity (handled via re‑examination)
After the window closes, the FAA expects a demonstration of instructional competence via a flight instructor practical test.
What Happens If the 3‑Month Window Is Missed?
If more than 3 calendar months have passed since the end of your recent experience period:
The FIRC option is no longer available
Reinstatement typically requires:
Passing a CFI, CFII, or MEI practical test.
This is more time‑consuming, more expensive, and higher‑risk than completing a FIRC on time.
Common (and Dangerous) Misunderstandings
“The grace period lets me keep teaching.”
False. Privileges are already lapsed.
“If I finish the FIRC later, I’m covered retroactively.”
False. There is no retroactive authority to instruct.
“This is the same as the 3‑month FIRC look‑back in §61.197.”
False. §61.197 addresses maintaining currency before lapse. §61.199 addresses reinstating after lapse.
Best‑Practice Guidance from CFI Academy
Professional instructors should:
Treat the §61.197 deadline as a hard stop
Avoid relying on §61.199 except for true short‑term lapses
Complete a FIRC 30–60 days early whenever possible
Document completion and reinstatement cleanly
The 61.199 window is a safety net, not a strategy.
How This Fits Into the Bigger Picture
For a full explanation of:
CFI renewal vs. recent experience
All qualifying methods under §61.197
What happens when privileges lapse
For a full explanation of CFI renewal vs. recent experience, see our pillar guide:
CFI Renewal vs. CFI Recent Experience (14 CFR §61.197 & §61.199)
Final Takeaway
§61.199 provides a 3‑calendar‑month reinstatement window
You may not instruct during that window
Completing a FIRC within the window avoids a practical test
Missing the window generally requires re‑testing
Understanding this distinction is part of being a professional flight instructor, not just a certificated one.
