Currency approaches have to be done in IMC or under the hood with a safety pilot. I wonder if the same applies for the holds?
The reason for the requirement: “(iii) Intercepting and tracking courses through the use of navigational electronic systems.” is to preclude using radar as the sole means of navigation. It is possible to fly 6 radar guided approaches and never use any VOR, localizer, GPS, DME, or ADF for navigation.
The vast majority of US approach procedures use a hold as part of the missed approach procedure and more than half of the RNAV (GPS) approaches use a hold in lieu of a procedure turn when a procedure turn is required. Usually, if one flies 6 approaches, particularly RNAV ones, they will encompass all of the requirements and merely have to be logged as such. Regardless, practicing a hold at a VOR, NDB, or waypoint is not a big deal and even if it is not charted, it only takes under 5 minutes of flight time to comply with the requirement.
Hodja, Clearly yes. 61.57 below:
Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane, powered-lift, helicopter, or airship, as appropriate, for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions using a view-limiting device that involves having performed the following—
(i) Six instrument approaches.
(ii) Holding procedures and tasks.
(iii) Intercepting and tracking courses through the use of navigational electronic systems.
Currency approaches have to be done in IMC or under the hood with a safety pilot. I wonder if the same applies for the holds?
Yes, as indicated by the clear language of the regulation 61.57 (c ) .
(1) Use of an airplane, powered-lift, helicopter, or airship for maintaining instrument experience. Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane, powered-lift, helicopter, or airship, as appropriate, for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions using a view-limiting device that involves having performed the following—
(i) Six instrument approaches.
(ii) Holding procedures and tasks.
(iii) Intercepting and tracking courses through the use of navigational electronic systems.
What does “in actual wx conditions” mean?
If it means the wx has to be down to minima, almost nobody will be able to log any approach.
That means the 6/6 rolling currency can be met only by flying under the hood, which requires a safety pilot. I am sure 99% of pilots are not doing that. What they do is they fly an approach and log it.
Has the FAA Chief Counsel ever rules on what constitutes acceptable “actual weather”?
Obviously all weather is “actual” 
Peter, from memory I believe it has been interpreted to be IMC at the FAF. So after that when you get visual doesn’t matter.
What they do is they fly an approach and log it
A lot of IFR pilots don’t know about the IMC / hood requirement & happily logs all approaches towards currency…
I am not aware of an FAA General Counsel opinion on the topic. It is one question that is best left ambiguous as the answer may not be one of your liking. Most use the following criteria, if any portion of the published approach is IMC, then it is logged as actual. Some restrict themselves to only logging it if IMC is encountered on the final approach segment. It is assumed that the published procedure is flown to the DA/MDA and the aircraft is not cleared for the visual approach.
The reason for the requirement: “(iii) Intercepting and tracking courses through the use of navigational electronic systems.” is to preclude using radar as the sole means of navigation. It is possible to fly 6 radar guided approaches and never use any VOR, localizer, GPS, DME, or ADF for navigation.
NCYankee,
I had thought about that, but let’s be picky: even a radar appraoch qualifies as “use of navigational electronic systems”…
Picky is as Picky does, but that is why it is added. 
