IFR Currency in Canada: What CARS 401.05 Requires

Having an instrument rating doesn't automatically mean you're legal to fly IFR. You also need to be current — and currency lapses faster than most pilots expect. CARS 401.05 is the regulation. Here's what it requires and the specific scenarios the INRAT will test.

What CARS 401.05 requires for IFR currency

To act as pilot-in-command of an aircraft under IFR in Canada, you must have completed, within the preceding six months, all of the following in an aircraft or an approved flight simulator:

All three elements must be completed in the six-month window. Doing six approaches without doing any holding doesn't make you current. The exam will test this — a question might describe a pilot who completed five approaches and two holds, and ask whether they're current. They aren't.

What counts toward currency

Instrument approaches must be conducted under actual or simulated IMC — you need to be on instruments, either in cloud or under the hood with a safety pilot. An approach done in VMC without a hood or safety pilot doesn't count.

An approved flight simulator counts for all three requirements. This is how many instrument pilots maintain currency during winter or when scheduling is difficult. The simulator must be approved — not just any consumer flight sim. Check that the simulator is listed as an approved Flight Training Device (FTD) or Full Flight Simulator (FFS) by Transport Canada.

A safety pilot is required when flying under the hood. The safety pilot must hold at least a private pilot licence and have a current medical. They act as PIC during simulated IMC since the flying pilot's visibility is restricted.

What doesn't count

• Visual approaches in VMC without a view-limiting device
• Flying through broken cloud on a VFR flight (not instrument flight)
• Approaches in a non-approved simulator or consumer flight sim
• Holding patterns done more than six months ago
• Any element completed without the aircraft being operated under IFR or simulated IFR

This comes up in exam questions as a list of a pilot's recent flying activity, asking you to determine whether they're IFR current. Read each item carefully — VFR approaches, no matter how well executed, don't contribute to IFR currency.

If you've lapsed

A lapsed IFR currency doesn't mean your rating is gone — it means you can't act as PIC under IFR until you re-establish currency. To do so, you must complete the required approaches, holds, and tracking — but you must do this with a qualified safety pilot (at minimum a PPL holder with a current medical), or with a flight instructor, since you can't act as PIC under IFR while lapsed.

Some candidates confuse currency lapse with rating expiry. Your instrument rating doesn't expire. Your currency does. Getting currency back is a matter of completing the required experience, not re-passing the written or flight test.

How this compares to the FAA

The FAA IFR currency rule (14 CFR 61.57) is similar: six instrument approaches, holding procedures, and intercepting/tracking within six months. The structure is nearly identical. The main difference is in what constitutes an "approved" simulator and some specifics of what counts as actual vs simulated IMC. On the INRAT, always cite CARS 401.05 — never the FAA regulation.

Also note: the INRAT covers 15 exam categories. Currency requirements fall under Pilot Qualifications. It's not the heaviest category, but questions on it tend to be very specific about whether a pilot is or isn't legal — exactly the type of black-and-white question that shows up regularly.