FAA Part 142 vs Part 141: A Plain-English Guide for Simulator Training Centers

If you operate flight simulators in the United States, you're almost certainly working under one of two FAA rule sets — Part 141 or Part 142 of Title 14 of the Code of Federal Regulations. They sound similar and they share regulatory DNA, but they govern very different operations and impose different obligations on the center running the program. Confusing them when you buy software, when you write SOPs, or when you talk to an FSDO is the kind of mistake that costs days during an audit.

The thirty-second answer

Part 141 is for pilot schools — the FAA-approved programs that teach private, instrument, commercial, ATP, and CFI candidates. Part 142 is for training centers — facilities that train already-certificated pilots in specific aircraft, typically as part of a type rating, recurrent training, or proficiency check program for an airline or corporate flight department.

Put another way: Part 141 produces new pilots. Part 142 produces new captains on a 737, or recurrent ATP holders proficient on a Bombardier Global 7500, or first officers signed off on a Citation X. The customers, the equipment, the curriculum length, and the regulatory burden are all different.

What Part 141 actually covers

A Part 141 school holds an FAA Air Agency Certificate that authorizes it to deliver one or more FAA-approved courses. Each approved course has a syllabus, a stage-check structure, a TCO (Training Course Outline) document, and a Part 141 chief instructor (CI) attached to it. Students who complete the course can use the reduced flight-hour minimums baked into the Part 141 framework — for example, a Part 141 commercial course can be completed in 190 hours of flight time, vs. 250 under Part 61.

Part 141 schools usually own or lease real aircraft, employ Part 141-approved CFIs, and operate at a specific airport. The FSDO that issued the certificate inspects the school on a recurring basis. Equipment-wise, Part 141 schools may use simulators, but the regulatory backbone is built around real aircraft + structured ground school.

What Part 142 actually covers

A Part 142 training center holds a Training Center Certificate authorizing it to deliver FAA-approved curricula on specific aircraft, almost always built around full-flight simulators (FFS), flight training devices (FTD), or aviation training devices (AATD/BATD). Part 142 centers sit downstream of Part 60 — the rule that governs simulator qualification — and most of their day-to-day equipment is a Level C, Level D FFS, or a Level 6/7 FTD evaluated by the National Simulator Program (NSP).

The customers are airlines (initial type-rating training, recurrent, line-oriented evaluation), corporate flight departments (initial + recurrent on Citations, Globals, Falcons, Embraers), and military / contractor pilots needing civilian type ratings. Sessions are short — typically 4 to 8 hours of sim time across briefing, sim, and debrief. A center might run 40+ sim sessions a week per FFS.

The compliance burden looks different

Both rule sets have approval and recordkeeping obligations, but the moving parts are different.

• Part 141: TCOs per course, stage-check pass rates, CI/AC qualifications, student progress records, and FAA inspector visits.
• Part 142: simulator NSP evaluations (annual recurring), instructor + evaluator currency, training program approval per aircraft, training records per crewmember, and FAA inspector visits.
• Both: instructor certification currency (CFI, CFII, ATP), facility/equipment maintenance logs, and the standard Air Agency obligations.

If you're running both, you're running two operations

Some centers hold both a Part 141 certificate and a Part 142 certificate — typically a Part 141 ab initio program feeding into a Part 142 type-rating arm. Operationally, these are two distinct businesses sharing a roof. Ground school for Part 141 students happens on a different track than recurrent training for ATP captains. Records live in different file cabinets (or different software). Audits are scheduled separately by the FAA.

The right answer for your operation

If you're training people who don't yet have certificates, you want Part 141. If you're training people who already have certificates and are getting type-rated or recurrent on a specific aircraft, you want Part 142. If you're doing both, you'll need software (and SOPs) that respect the boundary.