The scenario described touches on one of the most persistently misunderstood distinctions in Part 61: the difference between *logging* pilot-in-command time and *acting as* pilot-in-command. Under FAR 61.51(e)(1), a certificated pilot may log PIC time whenever they are the sole manipulator of the controls of an aircraft for which they hold the appropriate category and class rating. This provision makes no reference to instrument currency and is entirely separate from the operating rules that govern who may legally act as PIC in instrument meteorological conditions. FAR 61.57(c) prohibits a pilot from *acting as PIC* under IFR or in weather conditions less than VFR minimums unless the applicable recent experience requirements have been met — but this does not strip a non-current pilot of the right to log PIC time as sole manipulator when a current, qualified pilot assumes acting PIC responsibility for the flight.
In the arrangement described, Friend B's instrument currency is what makes the flight legally operable in actual IMC. Friend B is the acting PIC — the individual bearing regulatory accountability for the flight — while Friend A is the sole manipulator of the controls and logs PIC accordingly. Because Friend A holds the appropriate ratings for the aircraft and is physically flying it, the logbook entry is proper under 61.51(e)(1). Friend B logs nothing because Friend A is sole manipulator; if Friend B were to also log PIC, both would need to be logging on some distinct and simultaneous basis, which is not the case here. The CFI who objected is almost certainly conflating the *acting as PIC* currency requirement with the *logging PIC* provision — a conflation the FAA's own legal interpretations have consistently rejected. The sole manipulator rule is deliberately broad and does not condition logging rights on currency status.
The approaches Friend A logs in actual IMC are also valid for purposes of restoring instrument currency under 61.57(c) and (d). The regulation requires that the pilot have "performed and logged" the requisite approaches, holds, and tracking/intercepting tasks. Friend A, as sole manipulator flying actual instrument approaches in IMC, is performing those tasks. The logbook entry — which properly reflects PIC time — simultaneously satisfies the logging requirement for currency restoration. Once Friend A accumulates the required six approaches, one hold, and intercepting/tracking tasks within the relevant window, currency is restored and Friend B's presence as backstop acting PIC is no longer necessary for those conditions. The critical caveat is that during this entire process, Friend B must remain instrument current and appropriately rated, because if the legality of the flight were ever questioned, Friend B is the person on the hook as acting PIC.
From a practical and professional standpoint, this arrangement is a well-established mechanism for pilots to work through an instrument currency lapse without resorting to a flight simulator or BATD, and it carries real operational considerations. Friend B is not merely a legal formality — as acting PIC, Friend B holds authority over the safety of the flight and can be held accountable for deviations, emergencies, and any ATC enforcement action. Both pilots should have a clear pre-flight understanding of roles, including who will communicate with ATC and who will handle abnormal situations. Operators in Part 91K and 135 environments should be aware that company operations specifications and training requirements may impose additional constraints on this kind of arrangement, even where it is technically permissible under Part 61. The broader principle — that logging and acting are legally distinct functions — is foundational to understanding multi-crew PIC logging, safety pilot arrangements, and simulator currency, and working pilots who misunderstand it expose themselves to logbook errors with potential certificate consequences during FAA audits or enforcement proceedings.