A Part 61 pilot can become a remote pilot without sitting the UAG, and only on a narrow path. Section 107.61(d)(2) lets a person who holds a pilot certificate other than a student pilot certificate, and who meets the §61.56 flight review, complete training covering §107.74 instead of the initial knowledge test. The manned certificate does not already include small UAS privileges.
The initial path, then the in-person check
Section 107.63(a)(2) says the application includes a certificate of completion for that initial training course. The FAA's certification page names the free Part 107 Small UAS Initial course, ALC-451, on the FAA Safety Team site, for pilots with a flight review within the previous 24 months. The application goes to a responsible Flight Standards office, a designated pilot examiner, an airman certification representative, a certificated flight instructor, or another person authorized by the Administrator. That person verifies identity. The applicant must show the §61.56 flight review by logbook endorsement or another manner the Administrator accepts. TSA security vetting still applies. English, age 16, and the fitness standard in §107.61 still apply. The age and medical list is on the age and medical page. Applicants who are not on this path schedule the UAG as described on the test day page.
After the temporary certificate is issued, acting as remote pilot in command still requires §107.65. Within the previous 24 calendar months the pilot must pass an initial knowledge test covering §107.73, complete recurrent training covering §107.73, or, if still qualified, complete the §107.74 training. The usual recurrent course for the non-Part-61 method is ALC-677. The usual §107.74 course is ALC-515. Meeting §61.56 is the ticket into that third method. The flight review alone does not satisfy §107.65. Currency details are on the recurrent training page.
Night knowledge expires with recency
A remote pilot certificated in 2019 who has done no test or training since, even with a compliant anti-collision strobe visible for 3 statute miles, may not fly at night tonight. The light satisfies only §107.29(a)(2). Section 107.29(a)(1) requires an initial knowledge test or training under §107.65 completed after 6 April 2021. A 2019 test is outside that window, and §107.65 recency has lapsed. She must meet §107.65 again before she acts as remote pilot, including at night. Pre-2021 certificates are not grandfathered into night privileges. She does not need a night waiver once the training condition and the light are both met. A Part 61 flight review, without the §107.74 training, does not close the gap.
The same clock catches a pilot who passed the updated initial test 26 calendar months ago and has taken nothing since. That test is outside the previous 24 calendar months, so it no longer satisfies §107.65. He may not act as remote pilot in command, including on a paid night inspection with a legal light. The updated test does not permanently satisfy the night training condition. Section 107.29(a)(1) points at a test or training under §107.65, and §107.65 is the 24-calendar-month rule. He restores it by passing an initial knowledge test covering §107.73, completing recurrent training covering §107.73, or, if he holds a non-student Part 61 certificate and meets §61.56, completing the §107.74 training. Recurrent training can restore currency. A flight review alone cannot. He is not forced to retake the initial test at a center if another §107.65 method fits.
The light is a separate condition
Current night knowledge is not the whole of §107.29. A remote pilot who finished free online recurrent training last month, and whose aircraft has no anti-collision lighting, may not fly at 10 p.m. in a bright stadium parking lot. Ground lighting does not substitute for onboard anti-collision lighting. Part 107 sets no 9 p.m. curfew. The flight is legal only if the aircraft has anti-collision lighting visible for at least 3 statute miles, or he holds a waiver of the light paragraphs, §107.29(a)(2) and (b). Section 107.205(b) allows a waiver of those light paragraphs only. It does not waive the training requirement in §107.29(a)(1). A Part 61 certificate does not waive the light either.
Put the two conditions on one preflight card. Training or a test under §107.65 after 6 April 2021, still inside the 24-calendar-month window. One anti-collision light visible for at least 3 statute miles, with a flash rate sufficient to avoid a collision, unless a waiver covers the light. A manned flight review sits beside that card only as the qualification for §107.74 training. It is not a third night condition and it is not a substitute for either one. More of the lighting rule is on the night operations page.
Use the free practice test on the Part 61 path, recency, and the night light. The course is listed at pricing.