Question about doing recreational flying in the US on ESTA and later using the hours toward IR/CPL
Posted by AgananZero@reddit | aviation | View on Reddit | 21 comments
Hi all,
I’m trying to get some opinions from people who’ve gone through FAA training or dealt with the visa/travel side of things.
Like many others, I’m trying to complete my flight training as economically as possible. I’m not a US resident or green card holder, but I would prefer to do my flying in the US because of the cost, the airspace, and the general availability of aircraft and instructors. My long‑term plan is to convert my FAA CPL to another authority later.
Here’s the idea I’m considering:
- I would visit the US on ESTA
- Do recreational flying with a CFI (not enrolled in a course)
- Log dual received and PIC time
- Then later, when I’m ready for the structured part of training, I would switch to an M‑1 visa and finish the IR/CPL properly at a school
- All the hours I built earlier would still count toward the FAA requirements
I know ESTA doesn’t allow enrollment in a course of study, but recreational flying with an instructor is allowed. My question is more about the practical side:
Has anyone here built time this way and later used those hours toward their IR or CPL without issues?
For context:
- I’m planning to take the FAA written exams first
- Then focus entirely on flying
- I’m trying to avoid unnecessary costs while staying within the rules
I’d really appreciate hearing from anyone who has done something similar, or from CFIs/schools who have seen students take this path.
Thanks in advance.
adoggman@reddit
No idea what is or isn’t legal, just letting you know to be very careful what you do in the US is allowed by your visa or you may never be let back in.
AgananZero@reddit (OP)
Thanks for the reply. And yes, to be clear, I have no intention of breaking any rules. From what I’ve researched, as long as I’m not enrolled in a course, it’s perfectly fine to fly recreationally with a CFI, even if I’m learning new things and logging the time as dual received.
What I’m really trying to understand is whether anyone has actually done this in practice, and whether they ran into any pushback from a flight school later. For example, something like: “Even though you logged those hours, you still need to redo the training with our CFIs.”
One thing I did learn is that if I go this route, I’d only qualify under Part 61 and not Part 141, which is totally fine for my goals.
adoggman@reddit
With all due respect, you say you have no intention of breaking the rules but this entire post is basically 'how can I skirt the rules and get some flight time in that will count without having the correct visa'
This post in and of itself might be a reason to deny your visa
If you're planning on doing this you better be speaking to a lawyer
AgananZero@reddit (OP)
I’m not trying to skirt anything, I’m just clarifying what’s allowed for a rated pilot on ESTA. Recreational flying, PIC time, XC, night, and basic hood work are all permitted and count toward FAA experience requirements. Actual IR/CPL training will be done properly on an M‑1. I’m just gathering information so I stay compliant.
ltcterry@reddit
This is another example of your plan to get training and pretend it's not training.
The Airman Knowledge Tests are very clearly part of specific ratings or certificates. And you plan to take them first.
Commercial is 250 hours. Instrument takes about 40-45. Commercial is about 10-15 for the maneuvers.
Visit the US on ESTA. Get a checkout. Fly the 50 hours of cross country. Fly to a total of about 190 hours. Then apply for a legit flight training visa and do the training for instrument and commercial. No secret head start.
I'm pretty flexible. I like to maximize the bang for the buck for my clients. But I would not do what you are trying to do. I would not encourage any of my friends and mentees to support what you are trying to do.
AgananZero@reddit (OP)
I hear what you’re saying. I’m not trying to get around anything. I’ll be doing the actual IR/CPL training properly on an M‑1. The written tests don’t require a training visa, and taking them early isn’t considered “starting a rating” by DHS or TSA.
For now I’m just flying, building hours, and staying current. When it’s time to begin the real IR/CPL training, I’ll switch to the proper visa and do it the standard way.
Pilot-Imperialis@reddit
No, this is pretty damn illegal without extra steps.
I don’t think there’s anything preventing you from doing this on an ESTA, technically but you’re not allowed to just come to the US and flight train and the esta won’t last long enough for you to complete a training course. For obvious reasons following 9/11, the tsa are not interested in you only doing part of a training course. You sign up to the full thing. (That being a certificate, while these days you only need to apply once, technically you have to have a separate tsa check for private, instrument and multi engine training).
You have to submit an application to the TSA and pass a background check. Part of this is done alongside a school who have to list what training course you are starting and when you are expecting to finish. You will also need to prove that you have all the funds you need to complete said course.
Assuming that’s all good, once you arrive at the school then they take your photo and send it back to the tsa so they confirm the person who applied is the person that arrived. Oh, and you will need to be taken to a nearby police station to have your fingerprints taken. Once all those checks are good, training can begin.
All of the above must be done before any flight training is done (barring a single air experience flight), and once started, you’re expected to reasonably finish. Of course you can quit, and only do what you planned, but then you would have lied to the TSA and you also need to have proven you had the financing in the first place).
AgananZero@reddit (OP)
Thanks for the detailed reply, I appreciate you taking the time to write it out. I think there may be some mixing of different regulations here, so I just want to clarify my understanding and see if others have experience with this.
From what I’ve researched:
• TSA AFSP approval is only required when you’re actually starting a rating (PPL, IR, ME, or a type rating).
It doesn’t apply to general dual instruction, hour building, or recreational flying. TSA’s own guidance lists those activities as exempt.
• ESTA doesn’t prohibit flying with a CFI, as long as you’re not enrolling in a structured course of study or starting a rating. Recreational flying with an instructor is allowed, and foreign visitors do discovery flights, flight reviews, and dual instruction all the time.
• FAA hours are FAA hours. If a CFI signs the logbook, the time is valid later for Part 61 requirements, regardless of visa category.
So my question is really about the practical side:
Has anyone actually done recreational dual on ESTA and later used those hours toward IR/CPL without a school pushing back?
I’m not trying to avoid TSA or visa requirements, when I’m ready to start the actual IR/CPL training, I’ll switch to an M‑1 and go through the proper AFSP process. I’m just trying to understand whether the earlier dual time causes issues later.
Would love to hear from anyone who has gone down this path or seen it done.
ltcterry@reddit
You keep saying “dual instruction is allowed.” Yes, flight reviews, checkouts, aerobatics, etc. But not anything related to an instrument rating or commercial certificate. “It’s not a ‘formal/structured course’” does not change that.
No instrument approaches. No commercial maneuvers. Training toward a rating is not allowed. Not even pretend training.
You’re trying to rationalize something that you want to do.
AgananZero@reddit (OP)
I’m not doing IR or CPL training on ESTA. I’m just flying as a rated pilot and building experience.
Practicing maneuvers with a CFI is allowed as long as it’s not part of an actual IR/CPL syllabus. Rated pilots do hood work, commercial maneuvers, and general proficiency flying all the time without it being considered “starting a rating.”
I’m not doing approaches, checkride prep, or anything structured, just normal flying until I switch to an M‑1 for the real training.
ltcterry@reddit
You are trying to twist word into what you want it to be.
"Let's do eights on pylons but just call it Private Pilot fun flying" is training towards a rating.
Virtually no CFI is truly using a syllabus. So saying "as long as it's not part of an actual syllabus" is silly. 1) These maneuvers are part of an actual syllabus, even if 2) there isn't one printed w/ your name on it.
Rated pilots do indeed do a bit of hood work. It's called "flight by reference to instruments" at the Private Pilot level. It's not "instrument flying" and doesn't count. These hours during Private Pilot training don't even count towards the 15 hours required with a CFII for an instrument rating.
If you are a current pilot and want a checkout in something you are familiar with then 3-4 hours ought to be more than enough.
The vast majority of your time should be solo. Not dual. Unlike FAA Land where you can log dual as PIC, the rest of the world doesn't see it that way.
If you want to gain experience, competence, and confidence then go fly solo. Lots of cross country hours.
TSA mandated that every instructor create an account on their flight training portal. No legitimate instructor is going to give you any kind of training off the books.
Get checked out and fly. You don't need the crutch of an instructor beyond that. If you do then that's bad. Stop trying to twist things into what you want.
AgananZero@reddit (OP)
I get your point, I’m not trying to twist anything here. I’m just talking about normal flying and general proficiency, not IR/CPL syllabus work or checkride prep. Practicing maneuvers with a CFI doesn’t automatically mean I’ve “started a rating,” and I’m not doing anything structured on ESTA.
I’ll be doing the actual IR/CPL training properly once I’m on an M‑1. For now it’s just flying, staying sharp, and building hours. Nothing more complicated than that.
Pilot-Imperialis@reddit
You’re not quite right.
The regulation you need to read is 49 CFR 1552.
Now the bit we’re debating about is the definition of flight training. 1552.3 defines it as:
The issue we run into here is “instruction that is consistent with the requirements to obtain a new skill, certificate or type rating”
Honestly, the new “skill” reading stops you dead here. Are you learning to fly at all? If you’re logging dual, you are by definition. You’re not qualified to fly a plane yet so yes, you’re learning a new skill.
Even if you could get around that, the verbiage “consistent with the requirements to obtain a new certificate” trips you up here. Any basic flying skills a CFI shows you (because remember whenever you log dual instruction received, they must log Flight Instruction Given”) would be consistent with the skills required for a private pilot certificate regardless of whether you intend to get one or not. Ergo it cannot be provided without tsa approval due to 1552.1(c) (this is you), 1552.5(a) (also you) and 1552.7 (the meat of the law as it were).
AgananZero@reddit (OP)
Just to clarify up front, I already hold an FAA PPL. Sorry for not making that clear earlier.
Thanks for laying out your interpretation of 49 CFR 1552. I think the main issue here is that the TSA definition of “flight training” in 1552.3 is being applied much more broadly than TSA actually uses it in practice. That definition is specifically for determining when AFSP approval is required, not for determining whether any dual instruction is prohibited.
TSA AFSP approval is only required when a non‑U.S. citizen begins training toward:
TSA’s own guidance lists several activities that do not require AFSP approval, including:
If “any new skill” automatically triggered AFSP, then foreign pilots wouldn’t be allowed to do discovery flights, BFRs, IPCs, or even a simple checkout, yet all of those are explicitly permitted without AFSP approval.
The distinction TSA makes is intent: AFSP applies when you are starting training toward a certificate or rating. It doesn’t apply to general dual instruction or recreational flying that isn’t part of a rating syllabus.
I’m not starting IR or CPL training on ESTA, and I’m not enrolling in a course. When I’m ready to begin actual IR/CPL training, I’ll switch to an M‑1 visa and go through the proper AFSP process with the school.
I appreciate ya debating this with me. I'm not saying I'm right or you're wrong. Just curious and wondering if whether schools later accept those hours under Part 61 without insisting everything be redone.
Pilot-Imperialis@reddit
Wait, that changes everything significantly haha.
So to confirm you are a FAA PPL and just want to build hours towards a future rating before you actually work on it ? That’s totally allowed you don’t even need a CFI, it’s just time building and of course you can do that on an esta. You can even go up with a CFI as long as you don’t do any instrument training you’re fine. Hell, use that time to get a head start on learning the commercial maneuvers, you don’t need further approval for those, and yes the flight hours would count towards conversion in another country (if not the skills).
If I’m misunderstanding you still, I apologize. I would definitely add you hold a FAA PPL on your original post as that changes the scenario completely.
AgananZero@reddit (OP)
Haha yeah, my bad, I definitely should’ve mentioned the FAA PPL part from the start. That probably would’ve saved everyone a few paragraphs of regulation‑digging. Sorry about that!
And yes, you’ve got it right now. I’m already a PPL, just looking to build time and sharpen skills before I actually start IR/CPL training on an M‑1. Nothing sneaky, nothing structured, just flying and getting more comfortable in the airplane.
Totally agree that basic time building, commercial maneuvers, etc. are all fair game without extra approvals. I just wanted to make sure I wasn’t missing some weird TSA/ESTA crossover rule that would bite me later.
Appreciate you sticking with the thread even after my slightly confusing first post.
Pilot-Imperialis@reddit
No problem! Glad I could help and I’m happy you’ll be able to get some flying in!
ltcterry@reddit
What is the dual that you’ll be logging?
Anything beyond basic Private Pilot skills is probably training towards an instrument rating or Commercial Certificate. Neither allowed w/o a flight training visa. It’s not “enrolled in a course” that matters since in most cases that isn’t a thing.
Get a checkout and go solo.
You can’t “finish properly at a school” since you can’t start training towards a rating w/o being on a flight training visa.
“No officer, these lazy eights were just for fun, not for the Commercial checkride in a few months.” Yeah. Right.
I suppose you could get a CFII and log it as un-safety pilot time. But probably still a no go.
AgananZero@reddit (OP)
I’m not trying to sneak in IR or CPL training on an ESTA. The dual I’m talking about is just normal flying and general proficiency stuff, not approaches or checkride prep. Practicing maneuvers with a CFI isn’t the same as starting a rating, and I’m not doing anything structured.
I’ll save the actual IR/CPL work for when I’m on an M‑1. For now it’s just flying and staying sharp, nothing more dramatic than that.
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