Commercial Privileges & Limitations

14 CFR § 61.133 — Commercial pilot privileges

What a commercial certificate actually allows you to do:

• Act as PIC of an aircraft carrying persons or property for compensation or hire (within the privileges and limitations below)
• Act as PIC for compensation or hire generally — including ferry, banner-tow, photo work, etc.

Without an instrument rating in the same category and class:

• This limitation does not apply to a helicopter certificate. § 61.133(b)(1) reaches only the airplane and powered-lift categories: an applicant in one of those who holds no instrument rating in the same category and class gets a certificate stamped “The carriage of passengers for hire in (airplanes) (powered-lifts) on cross-country flights in excess of 50 nautical miles or at night is prohibited.” A commercial helicopter certificate carries no such limitation, with or without an instrument rating.
• It is commonly mis-taught as two rules. It is one limitation with two conditions, it bites on the carriage of passengers for hire rather than on all compensated flying, and it is lifted by meeting the § 61.65 instrument requirements in the same category and class. § 61.133(b)(2) is about balloons with an airborne heater — nothing to do with night or cross-country.

The instrument-rating limitation is the practical reason most commercial helicopter pilots pursue an IFR rating — without it, your commercial certificate is heavily restricted in real-world utility. (Many EMS, tour, and utility operations require it as a job prerequisite.)

14 CFR § 61.31 — Type ratings & authorizations

• Helicopter type ratings apply to helicopters > 12,500 lbs MTOW. Most civil helicopters fall under the category/class rating without a type rating.
• Aircraft requiring a type rating may be operated without the type rating for up to 60 days if all of the following apply:
  • The flight is only a ferry flight, training flight, test flight, or practical test for a certificate or rating
  • The flight is not for compensation or hire — except payment for use of the aircraft for the training or practical test itself
  • Only essential flight crewmembers are carried
• High-altitude training endorsement required for pressurized aircraft > FL250 (§ 61.31(g)).
• Complex / high-performance endorsements (§ 61.31(e)/(f)) — fixed-wing concerns, not relevant to most helicopter ops.

14 CFR § 61.55 — Second-in-Command requirements

• To act as SIC in an aircraft requiring more than one pilot, you must hold:
  • A private pilot certificate (or higher)
  • Category and class ratings appropriate to the aircraft
  • An instrument rating for that aircraft category if the flight is conducted under IFR
• Familiarisation training in that specific type within the previous 12 calendar months — § 61.55(b), not (d). Paragraph (d) is the route to an SIC type rating once that training is done, and (c) gives a grace month either side of when the training falls due.
• A type rating is not required to act as SIC for domestic operations within US airspace, even when the type rating is required for PIC. International operations may require it under ICAO conventions.
• Most light helicopters are single-pilot certified — § 61.55 mostly applies to larger transport-category rotorcraft (S-92, AW139 in some configs).

Operations that don't need a CPL

A subtle exam favorite: certain operations look "commercial" but legally aren't. From § 61.113 (private pilot privileges):

• Pro-rata expense sharing with passengers — fuel, oil, airport expenses, rental fees — provided the pilot pays at least their pro-rata share and there's a common purpose
• Charitable, nonprofit, or community-event flights per § 61.113(d), with restrictive conditions
• Aircraft sales demonstrations — § 61.113(f): a private pilot who is an aircraft salesman and has at least 200 hours logged may demonstrate an aircraft in flight to a prospective buyer. The rule turns on being a salesman and on the hours — it says nothing about who owns the aircraft.
• Aerial photography by a private pilot if compensation is incidental and the flight has another business purpose

Lines blur fast — Part 119 / 135 starts whenever "compensation or hire" exceeds these specific exceptions. AC 120-12A defines the difference between common and private carriage.

Part 91 vs Part 135 — the operational divide

• Part 91 — general operating rules. Where most CPL holders fly until they join an operator.
• Part 135 — commuter and on-demand operations. Stricter weather mins, duty/rest limits, training requirements. 14 CFR Part 135.
• Part 133 — external load operations (sling loads, longline). 14 CFR Part 133.
• Part 137 — agricultural aircraft operations. 14 CFR Part 137.

The CPL is the certificate. The Part the operator runs under determines the operating rules you fly by.