FAQ

FAQ & Regulations

Below are some of the most frequent questions and answers

Yes, in general, you need to have training that is proportionate to the category of drone you are going to operate.
Training is not required only if you are using very light drones:

A. if the drone bears a CE class mark 0, you only must be familiar with the manufacturer’s instructions; or

B. with privately built drones with a weight less than 250g, you are not required to undergo any training.
However, all other remote pilots must undergo the required training.

This means that, in the ‘open’ category, all remote pilots flying in subcategories A1, A2 and A3 are required to:
be familiar with the manufacturer’s manual;
complete an online training course provided by the IAA at https://iaa.mysrs.ie/auth/sign-in ; and
successfully complete an online theoretical knowledge examination (provided at the end of the online training) before they can fly the drone.

The test consists of 40 multiple choice questions testing your knowledge as a pilot.

Once completed the IAA will issue a certificate of completion of the online training. It enables you to fly in the in A1 and A3 subcategories. Avtrain will then provide all further training requirements.
Regulatory reference: Annex part A (DRONE.OPEN.020) of EU regulation 2019/947.
However, if you intend to operate in A2 subcategory, you must in addition to the above:
Complete practical training of yourself in order to familiarise yourself with the drone and ensure you reach a good level of control. This must be conducted in an area where you do not pose a risk to other people; and
Undergo an additional theoretical knowledge examination that will be provided by Avtrain;
The test consists of 30 multiple choice questions testing the pilot’s knowledge on mitigation of ground risks, meteorology and the drone’s flight performance.
On completion, Avtrain will issue a course completion certificate to the IAA who issue a ‘certificate of remote pilot competency’. With this certificate, you can fly in the A2 subcategory.


Regulatory reference: UAS.OPEN.030 Annex Part A of EU regulation 2019/947.

These EU Regulations adopt a risk-based approach, and as such, do not distinguish between leisure or commercial activities. They take into account the weight and specifications of the drone and the operation it is intended to undertake.
EU Regulation 2019/947 caters for most types of operation and their levels of risk. It does so through three categories of operations: the ‘open’, ‘specific’ and ‘certified’ categories.

A drone operator is any person, whether a natural person or an organisation, who owns the drone(s) or rents the drone. You can be both a drone operator and a remote pilot if you are also the person who actually flies the drone. However, you could be the remote pilot without being a drone operator, if, for example, you are a pilot working for a company which provides services with drones. In that case, the company is the drone operator and you are the remote pilot. If you bought a drone to fly it in your leisure time, you are both the drone operator and remote pilot. If you bought a drone to give away as a gift, the person who will receive the gift and then fly the drone will be the drone operator and the remote pilot.

According to the EASA website a drone is considered as a toy when it could be attractive to a child – at Avtrain we don’t agree with this or else we would be considered to be very childish!
More precisely, products designed or intended whether or not exclusively, for use in play by children under 14 years of age should be considered as a toy and comply with the Directive 2009/48/EC on the safety of toys. The compliance of a drone with that directive is declared in the corresponding EU declaration of conformity. In case of doubts, the fact that a product should be considered as a toy is assessed by market surveillance authorities based on a number of characteristics related to the attractiveness of the product for kids, accessibility, etc.
However, manufacturers may clearly exclude their product from the application of the Directive on the safety of toys (when a confusion is possible) by indicating clearly a minimum age > 13 years on their product (packaging, manual etc.) (e.g; “not for use under 14 years”).

Unless they are in the Certified Category, drones do not need to be registered, but you, as drone operator/owner, must register yourself. You do so with the Irish Aviation Authority at https://iaa.mysrs.ie/auth/sign-in
You register once, independently of how many drones you have operating in the ’open’ or the ’specific’ category. Your registration will be valid for a period of 5 years, after which you need to renew it.
However, you do not need to register yourself if your drone(s):

  1. weighs less than 250g and has no camera or other sensor able to detect personal data; or
  2. even with a camera or other sensor, weighs less than 250g, but is a toy (this means that its documentation shows that it complies with ‘toy’ Directive 2009/48/EC);

Relevant regulation: article 21 of EU regulation 2019/947.

Once registered, you receive a ‘drone operator registration number’ that needs to be displayed with a sticker on all the drones you own, including those privately built. You must also, upload it into the ‘Drone’s remote identification system’ if this is available on your drone.


Regulatory reference: article 14 EU regulation 2019/947.

No, following Brexit the UK is no longer part of EASA so for now you will have to register yourself in the UK and get a UK Operator ID if you want to operate in that territory.

Each EASA Member State will determine drone geographical zones, which are areas where drones may not fly (e.g. national parks, city centres or near airports) or may fly only under certain conditions, or where they need a flight authorisation. Therefore, it is important for you to consult your National Aviation Authority to check where you can and cannot fly your drone. In Ireland there are restrictions on flying in controlled airspace unless you have permission to be there, please check out our airspace map tab to see if you are in controlled airspace. Also Please check IAA Aeronautical Notice Exemption from Controlled Airspace Permission Requirement for certain drone operations


These geographical zones apply to all categories.
In addition, you are not allowed to fly a drone close to or inside an area where there is an ongoing emergency response.

Regulatory reference: Article 15 and UAS.OPEN.060 (4) of EU regulation 2019/947.

Generally when you operate in the ‘open’ category, you are not allowed to fly over uninvolved people, unless you have a privately built drone with a weight below 250 g or a drone purchased on the market with a class identification label0 or 1 mark. In any case, try to minimise the time during which you fly over people.
If you have a drone with a CE class 2 mark, under subcategory A2, as a general rule, keep the UA at a lateral distance from any uninvolved person that is not less than the height at which the drone is flying (this is the ‘1:1 rule’, i.e. if the UA is flying at a height of 40 m, the distance from any uninvolved person should be at least 40 m), and never fly closer than 30 metres horizontally from any uninvolved person.

If your drone is equipped with a low-speed mode function and this is active, you can fly as close as 5 metres from uninvolved people.

Distance from uninvolved people in the case of flying with a class C2 drone
In all other cases (drones with class identification label3, 4, 5 or 6 marks or privately built and heavier than 250 g), you need to ensure that no uninvolved people are present within the range of the operation.

Regulatory reference: article 4 (1) (c) and UAS.OPEN.040 of EU regulation 2019/947.

‘An uninvolved person is a person who is not participating in the UAS operation or who is not aware of the instructions and safety precautions given by the UAS (drone) operator’.
A person is considered involved if he/she decides to be a part of the operation, understands the risk and is able to check the position of the drone while it is flying.
Therefore, in order to be considered ‘involved’ in the operation, a person needs to:

  • give consent to be a part of the operation (e.g. consent to be overflown by the drone); the consent needs to be explicit;
  • receive from the drone operator/remote pilot instructions and safety precautions to be applied in case of an emergency situation; and
  • not be busy with any other activities that would make the person unable to check the position of the drone and, in case of an incident, take action to avoid being hit.

Writing on a ticket that a drone will be used during an event is not considered sufficient, since the drone operator needs to receive individual explicit consent and make sure people understand the risk and the procedures to be taken in case of an emergency.
During the operation, it is expected that involved persons will follow the trajectory of the drone and be ready to take action to protect themselves in case the drone behaves unexpectedly. If, during the UAS operation, people are busy working or watching something that is not compatible with monitoring the trajectory of the drone, than they cannot be considered to be involved.
Examples of uninvolved people:

  • spectators gathered for sport activities, concerts or other mass events;
  • people in a beach or in a park, or walking on the streets.

An uninvolved person is not only a person who is directly exposed to a drone, but could also be a person who is in a bus, car, etc., and who is indirectly exposed. For example, if a drone is flying over a car, its driver should be considered to be an ‘uninvolved person’. The reason is that a drone flying close to a car (even if it does not impact it) could possibly distract its driver and therefore cause a car accident.

Regulatory reference: GM1 Article 2(18) Definitions, ED Decision 2019/021/R.

An assembly of people is a crowd of people. It is not defined by a specific number of people, but is related to the possibility for an individual to move around in order to avoid the consequences of a drone which is out of control. If a group of people are so densely packed that their possibility to freely escape or move away from the drone is limited, then it is considered to be an assembly of people.
Examples of assemblies of people are the people in:

  • sport, cultural, religious or political events;
  • beaches or parks on a sunny day;
  • commercial streets during the opening hours of the shops; or
  • ski resorts/tracks/lanes.

Regulatory reference: GM1 Article 2(3) Definitions, ED Decision 2019/021/R

Your maximum flight height is generally 120 m from the earth’s surface. Please check IAA Aeronautical Notice Exemption from Controlled Airspace Permission Requirement for certain drone operations
If you need to fly over an obstacle taller than 120 m, you are allowed to fly up to 15 metres above the height of the obstacle, but only if there is an explicit request from the owner of the obstacle (e.g. a contract with the owner to perform an inspection). In such a case, you may fly within a horizontal distance of 50 metres from the obstacle.


When you are operating in hilly environments, the height of the drone above the surface of the earth should be within the grey zone in the picture below: you need to keep the drone within 120 m of the closest point of the terrain. This means that there may be conditions such as on top of a hill where even if you keep your drone 120 m from the side of the hill, you are actually flying at a distance higher than 120 m above the bottom of the valley. So as long as you keep your drone within 120 m of the shoulder of the hill (as in the grey area in the picture below), your flight is legal.

Regulatory reference: UAS.OPEN.010 (2) (3) Annex Part A of EU Regulation 2019/947

The minimum age for remote pilots of drones in the ‘open’ and ’specific’ categories is 16 years old. If you are younger than this then you must be supervised by a registered operator.
However, there is no minimum age for flying a drone with a CE class 0 mark under subcategory A1.
Regulatory reference: Article 9 EU regulation 2019/947.

A drone can be operated in the “Open “category when it:

  • bears one of the class identification labels 0, 1, 2, 3 or 4; or
  • is privately built and its weight is less than 25 kg; or
  • it is purchased before 1 January 2023, with no class identification label as above;
  • will not be operated directly over people, unless it bears a class identification label or is lighter than 250 g. (Please refer to subcategories of operations: A1, A2 and A3 to find out where you can fly with your drone);
  • will be maintained in visual line of sight (VLOS) or the remote pilot will be assisted by a UA observer;
    is flown at a height of no more than 120 metres;
  • will not carry any dangerous goods and
  • will not drop any material.

Regulatory reference: Article 4 and article 20 of EU Regulation 2019/947; Annex part A and Article 5(1) of EU Regulation 2019/947, Part1 to 5 Annex of EU regulation 2019/945.

The Subcategory is determined either by:

  • the label showing the class identification label (0, 1, 2, 3 or 4), affixed to your drone; or
  • the weight of your drone, for a privately built drone or for a drone without class identification label (called legacy drones);

Caveat: in order to facilitate the transition, drones without class identification labels may fly until 1st of January 2023 according to the requirements defined in article 22 of EU regulation 2019/947 (please refer to FAQ below and on the EASA website on flying without CE Class Markings for additional information). The table below is only applicable for drones with class identification labels.

Applying the instructions above, please refer to the table below to determine the subcategory you must fly under. For instance, drones with CE class 2 marks can be only be flown under subcategory A2 (close to people) or A3 (far from people).

Please consider that your state may publish geographical zones that may restrict the use of your drone such as controlled airspace in Ireland.

According to the class identification label of the drone or the weight, in the case of privately built drones, they can be operated in different conditions as described below:
Drones bearing a CE class 0 mark or that are privately built and weigh up to 250 g can fly in subcategory A1, which means almost everywhere, except over assemblies of people, or areas that the state has forbidden by imposing a restriction on the flight of drones such as controlled airspace or prohibited areas.

Drones bearing a class identification label 1 can also be operated in subcategory A1 with the difference that you are required to minimise flying over uninvolved people

Drones bearing a class identification label 2 can be operated in subcategory A2, which means in urban environments, however, you are required to keep a safe distance from any uninvolved people. As a rule, this minimum distance should be equal to the height at which the drone is flying (e.g. if you are flying at a height of 30 m, make sure that the closest uninvolved person is at least 30 m from the position where the drone would vertically fall in the event of an incident). In any case, this distance must never be less than 5 m. In addition, you can also fly in the conditions defined for subcategory A3. Finally, you must avoid flying in areas that the state has forbidden by imposing a restriction on the flight of drones such as controlled airspace or prohibited areas.


Drones bearing a class identification label 3 or 4 , or that are privately built and weigh up to 25 kg, can be operated in subcategory A3. That means that they can never be operated in urban environments that you need to keep the drone at least 150 m from residential, commercial or industrial areas, and to only operate in areas where no uninvolved people are present in the range where the drone can be operated. In any case, you must avoid flying in areas that the state has forbidden by imposing a restriction on the flight of drones such as controlled airspace or prohibited areas.

For the full image of requirements and limitations applicable to different classes of drones and conducted operations, please refer to the table below:

* The minimum age can be lowered by the state to 12, in which case, this new threshold will be valid only in that state however at the current time Ireland will be retaining 16 as the remote pilot minimum age.

As a drone operator flying in the ’open’ category, you must:

  • ensure that the drone displays the drone operator registration number (e.g. with a sticker) and the same number is uploaded into the remote identification;
  • develop operational procedures (written procedures are required when the drone operator employs more than one remote pilot, otherwise it is enough that the remote pilot follows the procedures defined by the manufacturer in the user’s manual);
  • ensure that there is no radio interference that may affect the command and control link of the drone;
  • designate a remote pilot for each operation; it is important that it is clear who is the person responsible for each flight;
  • ensure that the remote pilot and the personnel supporting the operation of the drone are familiar with the user’s manual and with the drone operator’s procedures, have appropriate competency, and are provided with the relevant information concerning any geographical zones published by the MS;
  • ensure that the maps in the geo-awareness system of the drone are up to date, unless you are flying in a geographical zone where geo-awareness is not required;
  • ensure that, unless you are using a privately built drone, it has a declaration in conformity to the CE class mark and its class label (0 to 4) is affixed to the aircraft; and
  • ensure that the persons involved in the operation of the drone is aware of the risks involved in operations under subcategories A2 and A3.

Regulatory reference: UAS.OPEN.050 under Annex 1 and art.19 (2)

Before the flight:

  • complete the training and examination required for the type of operation you will be involved in;
  • have relevant up-to-date information about any geographical zones published by the IAA;
  • check for obstacles and the presence of people not involved in the operation of the drone (unless operating in the A1 subcategory with a privately built drone or a drone with a CE class 0 mark;
  • check that the drone is fit for flight and the operation it will undertake;
  • check that the remote control works properly (if applicable); and
  • ensure that the weight of the drone is within the limit of the category or subcategory of the intended operation.

During the flight in the ’open’ category, you must:

  • not operate the drone when you are unfit either due to the consumption of psychoactive/ hallucinogenic substances or alcohol, or unfit due to sickness;
  • keep the drone at a distance such that you can clearly see it; you may use a UA observer to scan the airspace when you want to fly in first person view. UA observers must be located alongside you such that they can immediately communicate in case they see an obstacle and give you instructions such as to immediately land the drone.
  • if you or the UA observer see a manned aircraft, give way to it, and make sure you are far away from it. If you have any doubt about the operation, you should land the drone immediately.
  • comply with the limitation of the geographical zones;
  • operate the drone according to the manufacturer’s user manual;
  • comply with the operator’s procedure; and
  • do not operate where an emergency response service is ongoing (e.g. in the case of an accident, keep away from that location since an emergency helicopter may be required to be used);

Regulatory reference: UAS.OPEN.060 under Annex part A EU regulation 2019/947.

Yes, from 31 December 2020 to 1 January 2023, you may fly your drone without class Identification label in the ’open’ category under the following conditions:

  • drones with less than 500 g MTOM cannot fly over people, and pilot competency is determined by your IAA;
  • drones with less than 2 kg MTOM can fly 50 metres or more (horizontally) from people and the pilot must undergo training equivalent to subcategory A2;
  • drones with less than 25 kg MTOM, can fly in areas free from people, 150 metres or more away from properties, and the pilot must undergo training equivalent to subcategory A3.

After 1 January 2023, you can still fly your drone without class identification labels, however, only under the following subcategories of operation, for which you have to fully comply with:

  • Subcategory A1 when the drone’s maximum take-off weight (MTOM) is less than 250 g; or
  • Subcategory A3 when the drone’s maximum take-off weight is less than 25 kg.

You will not need to apply any retrofit/sticker to the drone in subcategories A1 or A3.

Regulatory reference: Article 20 and Annex part A of EU regulation 2019/947 and EU regulation 2019/945

T

The drone operator should develop procedures adapted to the type of operations and to the risks involved. Therefore, written procedures should not be necessary if the drone operator is also the remote pilot, or employs just one remote pilot. In this case the remote pilot may use the procedures defined by the manufacturer’s manual.
If a drone operator employs more than one remote pilot, the drone operator should:

(a) develop procedures for drone operations in order to coordinate the activities between its employees; and
(b) establish and maintain a list of their personnel and their assigned duties.

Regulatory reference: UAS.OPEN.50 under annex part A 2019/947.

A drone can be operated in the ‘in the ‘specific’ or the ‘certified’ category, when it does not meet the requirements laid out under the open category. See above FAQ on how do I determine if I fall into the Open Category.

Regulatory reference: Article 4 and Article 20 of EU Regulation 2019/947; Annex part A and Article 5(1) of EU Regulation 2019/947, Parts 1 to 5 Annex of EU Regulation 2019/945.

For operation falling under the ‘specific’ category, the training depends on the operation you intend to conduct. So unless the operation falls into a standard scenario, after the risk assessment, you will need to complete a course with Avtrain as this is acceptable to the IAA to meet the requirements.
If your operation falls into a standard scenario, the remote pilot must:

  • hold a certificate of remote pilot theoretical knowledge for operation under standard scenarios;
  • hold an accreditation of completion of the STS-01 practical skill training.

To do so, the remote pilot must complete and successfully pass an online training course.
Both the certificate and accreditation can be issued by a competent authority or Avtrain.

Regulatory reference: UAS.SPEC.050 (d) and UAS.SPEC.060 (b) of EU Regulation 2019/947

Yes, training conducted in one EASA Member State will be recognised in all others.

First, check whether your operation can be accommodated within a standard scenario. If it can, you do not need an authorisation, but you do need to submit a declaration to the IAA. A standard scenario is an operation defined in the Appendix to the drone regulation (EU Regulation 2019/947). You need to use a drone marked with the appropriate class identification label (5 or 6). After submitting the declaration to the IAA, you will receive the confirmation of receipt and completeness from the IAA and operate following the limitations of the standard scenario. Otherwise, there are other means to obtain an operational authorisation under the ‘specific’ category, depending on the level of risk the operation poses. The drone operator can apply for:

  1. An operational authorisation by conducting a risk assessment of the intended operation using a methodology for the risk assessment; one possible method is the SORA (specific operation risk assessment) that you can find as AMC1 to Article 11 to Regulation (EU) 2019/947. This methodology helps to identify the risk level of the operation and to identify the mitigations and operational safety objectives needed to make the operation safe. When the drone operator believes they have put in place satisfactory measures to ensure the safety of the operation, they send all the information to the IAA and apply for an operational authorisation. When the IAA is satisfied, it provides the drone operator with the authorisation, and the operation can be started.
  2. An operation authorisation through a predefined risk assessment’ (PDRA) as a simplification of the drone operator conducting a risk assessment. For those operations that will be the most common in Europe, EASA will carry out the risk assessment and will publish, as an acceptable means of compliance with the drone regulation, the list of the actions that the drone operator needs to put in place in order to conduct the operation safely. An application for an authorisation to the IAA is still needed, however, both the drone operator and the IAA will benefit from the standardised measures defined in the PDRA. The PDRAs are published by EASA as AMC to Art 11 to Regulation (EU) 2019/947; more are already under development.
  3. Light UAS operator certificate (LUC): this is a voluntary certification, after which the IAA may allocate some privileges to the drone operator.

Drone operators may ask the IAA to assess their organisation to evaluate whether they are capable of assessing the risk of an operation themselves. The requirements to be demonstrated by drone operators are defined in Part C of Regulation (EU) 2019/947. When the IAA is satisfied, they will issue a light UAS operator certificate (LUC) and they will allocate privileges to the drone operators based on their level of maturity. The privileges may be one or more of the following:

  • To conduct operations covered by standard scenarios without submitting a declaration;
  • To self-authorise operations conducted by the drone operator and covered by a PDRA without applying for an authorisation.
  • To self-authorise all operations conducted by the drone operator without applying for an authorisation.

Regulatory reference: article 12 of EU regulation 2012/947.

As a drone operator flying in the ’specific’ category, you must:

  • ensure that the drone displays the drone operator registration number (e.g. with a sticker) and the same number is uploaded into the remote identification;
  • develop operational procedures (written procedures are required when the drone operator employs more than one remote pilot, otherwise it is enough that the remote pilot follows the procedures defined by the manufacturer in the user’s manual);
  • ensure that there is no radio interference that may affect the command and control link of the drone;
  • designate a remote pilot for each operation; it is important that it is clear who is the person responsible for each flight;
  • ensure that the remote pilot and the personnel supporting the operation of the drone are familiar with the user’s manual and with the drone operator’s procedures, have appropriate competency, and are provided with the relevant information concerning any geographical zones published by the MS;
  • ensure that the maps in the geo-awareness system of the drone are up to date, unless you are flying in a geographical zone where geo-awareness is not required;
  • ensure that, unless you are using a privately built drone, it has a declaration in conformity to the CE class mark and its class label (0 to 4) is affixed to the aircraft; and
  • ensure that the persons involved in the operation of the drone is aware of the risks involved in operations under subcategories A2 and A3.
  • carry out each operation within the limitations defined in the declaration or operational authorisation;
  • develop procedures to ensure the security of the operation;
  • establish measures against unlawful interference and unauthorised access;
  • ensure that the privacy of people is protected, and there may also be a requirement to conduct a data protection impact assessment if requested by the IAA;
  • provide the remote pilot with guidelines on how to minimise the nuisance caused by noise and emissions;
  • ensure that the pilot conducting the operation and the other personnel in charge comply with all the conditions required for operating in the ’specific’ category;
  • keep a record of the drone operation; and
    maintain the drone in a suitable condition to ensure safe operation.

Regulatory reference: UAS.SPEC.050 of EU Regulation 2019/947

As a remote pilot you must: Before the flight:

  • complete the training and examination required for the type of operation you will be involved in;
  • have relevant up-to-date information about any geographical zones published by the IAA or the State in which you are operating;
  • check for obstacles and the presence of people not involved in the operation of the drone (unless operating in the A1 subcategory with a privately built drone or a drone with a CE class 0 mark;
  • check that the drone is fit for flight and the operation it will undertake;
    check that the remote control works properly (if applicable); and
  • ensure that the weight of the drone is within the limit of the category or subcategory of the intended operation.
    ensure that the operating environment is compatible with the authorised or declared limitations, and
    ensure that Air Traffic Services , airspace users and other stakeholders are informed of the intended operation.

During the flight in the ’specific’ category, you must:

  • not operate the drone when you are unfit either due to the consumption of psychoactive/ hallucinogenic substances or alcohol, or unfit due to sickness;
  • keep the drone at a distance such that you can clearly see it; you may use a unmanned aircraft (UA) observer to scan the airspace when you want to fly in first person view. UA observers must be located alongside you such that they can immediately communicate in case they see an obstacle and give you instructions such as to immediately land the drone.
  • if you or the UA observer see a manned aircraft, give way to it, and make sure you are far away from it. If you have any doubt about the operation, you should land the drone immediately.
    comply with the limitation of the geographical zones;
  • operate the drone according to the manufacturer’s user manual;
    comply with the operator’s procedure; and
  • do not operate where an emergency response service is ongoing (e.g. in the case of an accident, keep away from that location since an emergency helicopter may be required to be used);
  • Comply with the authorised or declared limitations.

Regulatory reference: UAS.SPEC.060 of EU Regulation 2019/947

From the 1st January 2021 any authorisation given by one MS will be valid in the rest of Europe. The drone operator is required to first submit the declaration (if intending to conduct an operation covered by a standard scenario) or receive an operational authorisation from the National Aviation Authority of the state of registration.
For an operation covered by a standard scenario (SS), the drone operator must send to the National Aviation Authority where it intends to operate, a copy of the declaration and a copy of the confirmation of receipt and completeness received by the National Aviation Authority of the state of registration. Then the drone operator may start the operation following the requirement of the standard scenario and verifying the geographical zone published by the National Aviation Authority where the operation is conducted.
For operations not covered by a standard scenario in the ’specific’ category, the drone operator must ensure that the mitigating measures submitted in his original risk assessment are appropriate to the new environment it plan to operate in or update them is necessary.
Then the drone operator must provide the National Aviation Authority of the Member State of the intended operation with an application, which must include:


(a) a copy of the operational authorisation granted by the National Aviation Authority of the Member State of registration; with
(b) the location (s) of the intended operation, including the updated mitigation measures.
Upon receipt of the application, the National Aviation Authority of the Member State of the intended operation will review the updated mitigation measure proposed. They will confirm to the drone operator that the application is satisfactory. Once the operator receives the confirmation, they may start the intended operation. If the drone operator has been granted, by the National Aviation Authority of the state of registration, an LUC (a light UAS operator certificate) with privileges to self-authorise its operations, they must provide the National Aviation Authority of the State of the intended operation with

  • a copy of the term of approval of the LUC and
  • the location or locations of the intended operation;

Regulatory reference: article 13 of EU regulation 2019/947.

A light UAS operator certificate (LUC) is an organisational approval certificate. Drone operators may ask the National Aviation Authority of registration to have their organisation assessed to demonstrate that they are capable of assessing the risk of an operation themselves. The requirements to be demonstrated by drone operators are defined in Part C of Regulation (EU) 2019/947. When the National Aviation Authority is satisfied, they will issue a light UAS operator certificate (LUC) and they will assign privileges to the drone operators based on their level of maturity. The privileges may allow the organisation to self-authorise operations without applying for an authorisation.
The privileges may be one or more of the following:

  • Conduct operations covered by standard scenarios without submitting the declaration;
  • self-authorise operations conducted by the drone operator and covered by a PDRA without applying for an authorisation;
  • self-authorise all operations conducted by the drone operator without applying for an authorisation.

You need to be an organisation to be eligible to apply for a LUC, however you can subcontract some of the activities.

Regulatory reference: UAS.LUC.010.

An autonomous drone is able to conduct a safe flight without the intervention of a pilot. It does so with the help of artificial intelligence, enabling it to cope with all kinds of unforeseen and unpredictable emergency situations. This is different from automatic operations, where the drone flies pre-determined routes defined by the drone operator before starting the flight. For this type of drone, it is essential for the remote pilot to take control of the drone to intervene in unforeseen events for which the drone has not been programmed. While automatic drones are allowed in all categories, autonomous drones are not allowed in the ’open’ category.


Autonomous drones need a level of verification of compliance with the technical requirements that is not compatible with the system put in place for the ’open’ category. Autonomous operations are, instead, allowed in the ’specific’ category, where the Regulation includes a tool flexible enough to verify requirements with the appropriate level of robustness.
Autonomous operations are also allowed in the ’certified’ category.