From the AFS-640 FAQ site:
....
"The FARs specifically permit time in a flight simulator or flight training device can be credited in lieu of the required flight time towards meeting the total aeronautical experience or recency of experience. [See § 61.57(c)(1) and (d)(1)(ii), § 61.58(e), § 61.65(e), § 61.109(i), § 61.129(i), § 61.157(i), § 61.187(c)(2), etc.] However, this is NOT flight time and CANNOT be logged as flight time. For example, an ATP applicant with 1,475 hours total time as a pilot in aircraft that includes at least 500 hours cross-country and 100 hours night, but only 50 hours instrument flight time would meet minimum aeronautical experience using 25 hours instrument training in a flight simulator or flight training device (FTD) in accordance with § 61.156(a)(3)(iii). Though the 25 hours in the sim/FTD can not logged as flight time, it may be used in lieu of flight time for the minimum aeronautical experience requirement of 1,500 hours total time. But, this is only because it is allowed under § 61.156(a)(3)(iii).
{Q&A-320}"
