Night Operations Training Requirements
The training/testing condition of 14 CFR 107.29(a)(1) is one of the most misunderstood parts of the night-operations rule, because it does not work the same way for every remote pilot — it depends on exactly when that pilot's most recent qualifying knowledge test or training took place. This lesson explains why April 6, 2021 is the key date, what it means for pilots certificated before versus after that date, and the alternate path available to pilots who also hold a Part 61 manned-aircraft pilot certificate.
What 107.29(a)(1) actually requires
14 CFR 107.29(a)(1) requires that the remote pilot in command has completed an initial knowledge test or training, as applicable, under 14 CFR 107.65, after April 6, 2021. This condition is entirely about the remote pilot, separate from the aircraft's anti-collision lighting condition covered in Lesson B. Both conditions must be satisfied together to fly at full night; this lesson focuses on the pilot-side condition specifically.
Why April 6, 2021 is the key date: what 107.73 added
14 CFR 107.65 requires every remote pilot to maintain currency by passing an initial aeronautical knowledge test or completing recurrent training within the preceding 24 calendar months, covering the knowledge areas listed in 14 CFR 107.73. Before the 2021 rule change, that list of knowledge areas did not include night operations at all, because night flight was still waiver-only and not a topic the standard knowledge test or recurrent training needed to cover. The 2021 final rule amended 107.73 to add a new required knowledge area, item (m), "Operation at night," to the list that both the initial knowledge test and recurrent training must cover. April 6, 2021 is the date this updated version of 107.73, including night operations content, took effect — which is exactly why 107.29(a)(1) uses that date as its cutoff.
Pilots who tested after April 6, 2021: automatically covered
A remote pilot whose initial knowledge test occurred after April 6, 2021 automatically satisfies 107.29(a)(1), because night operations content was already baked into 107.73's required knowledge areas by the time that pilot sat for the test. There is no separate application, endorsement, or additional step for these pilots — passing the initial test itself, taken after the cutoff date, is sufficient to meet the training/testing condition for night operations.
Pilots certificated before April 6, 2021: a post-cutoff recurrent training cycle is required
A remote pilot who was originally certificated before April 6, 2021 took their initial knowledge test under the older version of 107.73, which did not include night operations content. That pilot does not automatically meet 107.29(a)(1) on the strength of the original initial test alone. Instead, this pilot needs to complete a recurrent training cycle under 107.65(b), covering the current (post-2021) version of 107.73's knowledge areas including night operations, that occurs after April 6, 2021. This is not a special, separate "night operations course" — it is simply the pilot's ordinary 24-month recurrent training, which now includes night operations content as a required topic since the update to 107.73. Any recurrent training a pre-2021-certificated pilot completes after April 6, 2021, as part of maintaining normal currency, satisfies this condition.
The alternate path for Part 61 manned-aircraft pilot certificate holders
14 CFR 107.65(c) allows a person who holds a pilot certificate under Part 61 (other than a student pilot) and who meets the flight review requirements of 14 CFR 61.56 to satisfy recency through 14 CFR 107.74 instead of the standard Part 107 recurrent training. 107.74's list of required knowledge areas was also updated by the 2021 rule to add item (h), "Operation at night," mirroring the change made to 107.73. A remote pilot using this alternate path needs their most recent qualifying 107.74 training to have occurred after April 6, 2021, for the same reason as the standard recurrent-training path.
Determining whether the 107.29(a)(1) training/testing condition is already satisfied, based on the date of the most recent qualifying test or training.
View LargerScenario: expanding a certificate earned before the rule change
A remote pilot passed the initial knowledge test in 2019 and has maintained currency ever since through recurrent training completed roughly every 24 months, most recently in 2025. Because that most recent recurrent training cycle occurred well after April 6, 2021, and 107.73's knowledge areas have included night operations since that date, this pilot already satisfies 107.29(a)(1) through their normal, ordinary recurrent training — no separate night-specific course was required. If instead this same pilot's currency had lapsed and their last qualifying training had occurred only in early 2021, before the cutoff, they would need to complete a new recurrent training cycle (which, under current rules, automatically includes night operations content) before legally exercising night-operation privileges, even though that same training would also refresh their general 24-month currency at the same time.
| Pilot situation | What satisfies 107.29(a)(1) | Extra step required? | Source |
|---|---|---|---|
| Initial knowledge test taken after April 6, 2021 | The initial test itself, since it already covered 107.73(m) | No | 14 CFR 107.29(a)(1); 14 CFR 107.73(m) |
| Certificated before April 6, 2021, standard Part 107 recurrent training path | Any recurrent training cycle under 107.65(b) completed after April 6, 2021 | No, ordinary recurrent training already covers it | 14 CFR 107.65(b); 14 CFR 107.73(m) |
| Holds a Part 61 pilot certificate, using the flight review alternate path | 107.74 training completed after April 6, 2021, covering item (h) | No, ordinary 107.74 training already covers it | 14 CFR 107.65(c); 14 CFR 107.74(h) |
Confirming the night-operations training condition is met
Do this before accepting the first night job on a certificate earned before April 6, 2021, or after any lapse in currency.
Identify the date of your most recent qualifying knowledge test or training
Locate the completion date of your initial knowledge test, or your most recent recurrent training under 107.65(b) or 107.74, whichever applies to you.
Compare that date to April 6, 2021
If it is after April 6, 2021, the training/testing condition of 107.29(a)(1) is satisfied. If it is before, or if currency has lapsed entirely, an additional step is needed.
If needed, complete a recurrent training cycle
Complete recurrent training under 107.65(b) (or 107.74 for Part 61 certificate holders using the flight review path), which will cover night operations content as a required knowledge area.
Confirm the aircraft's lighting condition is also met
Remember that 107.29(a) requires both the training condition and the anti-collision lighting condition together — satisfying this training step alone does not clear an aircraft for night flight.
| Mistake | Why it happens | Correct understanding | Regulation / source |
|---|---|---|---|
| Believing a separate, dedicated "night operations exam" or endorsement is required | Adding a genuinely new privilege, like night flight, sounds like it should require its own distinct certification step | Night operations content is simply one required knowledge area, 107.73(m), within the ordinary initial test or recurrent training — there is no separate exam or endorsement | 14 CFR 107.73(m) |
| Assuming a remote pilot certificated before 2021 can never fly at night | The historical waiver-only framework and the pilot's original pre-2021 test create the impression that their credential is permanently limited | Once that pilot completes any recurrent training cycle after April 6, 2021, which now covers night operations content, they meet 107.29(a)(1) the same as any other pilot | 14 CFR 107.65(b); 14 CFR 107.73(m) |
| Thinking the April 6, 2021 date refers to when the aircraft was manufactured or when Remote ID compliance began | This course covers several different 2021 rule-change dates across multiple modules, which can blur together | April 6, 2021 specifically marks when 107.73 was updated to add night operations as a required knowledge area, tied to the remote pilot's training, not the aircraft's manufacture date or Remote ID compliance dates covered in Module 12 | 14 CFR 107.29(a)(1) |
| Assuming Part 61 pilot certificate holders are exempt from any night-operations training requirement | These pilots already use an alternate recency path and may assume it was not updated the same way as the standard path | 107.74's knowledge areas were also updated to add night operations as item (h), so this alternate path carries the same requirement | 14 CFR 107.74(h) |
Do I need a special night-flying endorsement to operate at night?
No. There is no separate endorsement or dedicated exam. Night operations content, 107.73(m), is simply one required knowledge area within the standard initial knowledge test or recurrent training under 107.65.
I earned my certificate in 2019 and have not done anything special for night flying. Can I fly at night?
It depends on your most recent recurrent training date. If your most recent recurrent training cycle occurred after April 6, 2021, you already satisfy the training condition, since night operations content has been part of standard recurrent training since that date. If your currency has lapsed since before that date, you would need to complete a current recurrent training cycle first.
Does taking the initial knowledge test today automatically cover night operations?
Yes. Since the initial knowledge test currently covers all of 107.73's required knowledge areas, including item (m), "Operation at night," passing the initial test today automatically satisfies the training/testing condition of 107.29(a)(1).
Test Your Knowledge
Answer the questions below to check your understanding. Every answer can be found in the lesson above.