The TSA has indicated that “inactive” CFIs are not subject to the Part 1552 requirements. Inactive CFIs, according to the TSA, are those not having direct student contact. It’s recommended, however, that all CFIs take the annual training to be sure of continued compliance with TSA’s rules. AOPA has a comprehensive breakdown of the rules and requirements on its website.
Be advised that the TSA conducts periodic audits of flight schools to check that the rules are being followed and that the requirements have been met. And, be reminded that independent CFIs are considered flight schools in the context of Part 1552. So, if the TSA comes knocking, you better have your records in order or be subjected to a civil penalty or, in extreme cases, a criminal referral.
By now, most CFIs are familiar with the TSA requirements contained in 49 CFR Part 1552. Subpart A of Part 1552 relates to alien flight training, and Subpart B relates to flight school security awareness training (initial and recurrent). Flight instructors who provide flight training to aliens or to TSA-designated individuals must abide by the rules in Subpart A, and Subpart B applies more generally to flight and ground instructors, whether or not the student is a U.S. citizen.