Quote Originally Posted by Frank Giger View Post
No, it's not required, but in the limitations it will note you can't go under the Mode C veil.
IFR vs. VFR has nothing to do with it. IFR doesn't change the mode C requirement.

You need mode C:

In class A, B, C airspace.
Inside the mode C veil (up to 10,000 feet).
Under class B and C tiers and above the ceiling
Above 10,000 (and more than 2500 AGL) in the lower 48

Nowhere in 91.215 does it give you an out for VFR-only. You get a break on SOME (but not all) of these requirements if you have no engine-driven electrical system.