Does a CFI need an entry of 3 takeoffs and 3 landings in the last 90 days in his log book to carry a passenger?

As I have said before, we always get some interesting questions here in the PIC, and this week was no exception. The above question came in through email and I thought I would share it here.

The answer is no, but let me qualify that.

Flight instructors have no passenger carrying requirements as they carry no passengers; only students. If a person is acting as a flight instructor, then there is a student on board, not a passenger; therefore, no passenger currency requirements exist.

Instructors, of course, are also pilots. And pilots, on the other hand, do have passenger carrying currency requirements. So, if the instructor exercises his or her pilot privileges, then yes, the three takeoffs and three landings requirement in the past 90 days must be met prior to carrying passengers.

It comes down to what privilege you are exercising on any given flight. Instructor or pilot?

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Let's clarify this.  A CFI isn't always acting as an instructor and a second person in the plane isn't always a trainee ("student").  But when a CFI is giving instruction to a trainee ("student"), then the neither CFI nor the trainee are considered a passenger with respect to the other, and the requirements for passenger carriage in 61.57(a/b) are not applicable.  Here's the full interpretation from back in 2006:

Kortokrax_2006_Legal_Interpretation (