Proposed Part 101 Chief Remote Pilot Licence Instructor and other matters - (CD 2401US)

Closed 28 Feb 2024

Opened 1 Feb 2024

Feedback updated 28 Mar 2024

We asked

The Part 101 Manual of Standards (MOS) consultation was open for public consultation from 1 to 28 February 2024. The consultation sought feedback on:

  • proposed Chief Remote Pilot Licence (RePL) Instructor (CRI) framework
  • improved standards
  • transitional requirements
  • other minor amendments.

We received 14 submissions from a variety of remotely piloted aircraft (RPA) training organisations and operators.

About this consultation

We are proposing to amend the Part 101 MOS to provide:

  • more fit-for-purpose standards
  • flexibility within the RePL instructor qualification framework
  • clarity of the requirements for RPA operations near aerodromes.

Feedback on these proposed changes was sought including:

  • implementation and consequential matters
  • impact to training organisations and their personnel
  • any other issues that may arise from these amendments.

This consultation has now closed.

You said

There were 14 responses. Nine respondents consented to CASA publishing their feedback, while 5 requested their submissions remain confidential.

The responses represented the remotely piloted community across: RePL training organisations (8), Remotely Piloted Aircraft Operator's Certificate (ReOC) holders (3), and RePL pilots/instructors (1), while 2 respondents marked themselves as ‘other’.

Eleven respondents stated they are representing an organisation, while 3 respondents identified as personal views.

Summary of feedback

In assessing whether industry agreed the proposed changes will benefit RePL training organisations and their personnel, 8 respondents expressed agreement, while 4 disagreed, and 2 respondents chose not to provide a response.

Feedback focused on issues relating to RePL training regulations specifically raising concerns regarding RPA global positioning system (GPS) requirements and advocating for transparent revisions to the syllabus. Recognition of overseas training providers was also highlighted.

Training organisations expressed concern that the introduction of the CRI position would impact resources due to internal changes and alterations required to manuals and training materials. While some respondents believe they already meet the requirements, others anticipate significant increases in workload. Three respondents expressed intent to nominate someone other than the organisations CRP for the CRI position.

We did

We appreciate the valuable contributions made by industry and acknowledge the significance of the feedback to inform and shape the consultation process.

We intend to implement the introduction of the CRI position, along with the other proposed amendments consulted in CD 2401US - Proposed Part 101 Chief Remote Pilot Licence Instructor and other matters with the following changes:

Extended commencement date

Based on stakeholder feedback, we will provide RePL training organisations more time to prepare for the changes.

Commencement of the introduction of the CRI position is to be delayed to 10 July 2024.

The additional time will assist RePL training organisations to identify and review:

  • qualification and experience requirements
  • potential CRI candidates
  • operational documentation requirements and amendments.

Alignment of deemed CRI requirement dates

We will simplify transition arrangements and align the deemed CRI qualification transition date to 10 January 2025. A person that is the deemed CRI will be required to hold qualifications and experience as prescribed in subsection 2.29A(3) of the amended Part 101 MOS by 10 January 2025.

Alternate qualifications recognition

We will also introduce an amendment to provide flexibility for us to assess and approve a person who does not hold the qualifications prescribed in paragraph 2.29A(3)(c) of the amended Part 101 MOS, based on their alternate qualifications and experience.

Next steps

We are committed to working with industry stakeholders to provide clarification on various aspects of the proposed changes, including:

  • timeline of changes
  • qualification requirements
  • the assessment process for those involved.

We will communicate this information with training organisations and RePL holders and provide guidance.

We will consider incorporating a work program review that will be aimed at clarifying the proposed regulatory structure for RePL training and will have a focus on establishing clear standards and reassessing the syllabus.

Published responses

View submitted responses where consent has been given to publish the response.


We are seeking feedback on proposed changes to the Part 101 Manual of Standards (MOS).

These changes include:

  • a new Chief Remote Pilot Licence Instructor (CRI) position in the remote pilot licence (RePL) instructor qualification framework
  • improved standards and flexibility
  • transition plans
  • other minor amendments to make it clearer.

The summary of proposed change document outlines:

  • the new CRI policy
  • how the CRI and other changes will be implemented
  • how the CRI changes may impact training organisations, instructors, and chief remote pilots (CRP)
  • minor clarifications for certain operations near aerodromes.

Proposed changes

Chief Remote Pilot Licence Instructor

The CRI will be required to:

  • hold one of the prescribed educational requirements and be assessed by CASA as suitable
  • make sure training organisations have a person who is skilled in providing internal training and assessing the competence of RePL instructors.

Replacement of RePL instructor qualification requirements

RePL instructor qualification requirements will be replaced with a requirement for the instructor to:

  • complete suitable internal training and checking
  • be assessed by the CRI.

Other minor amendments

Other minor changes will be included in the MOS to provide clarity and remove ambiguities.

More information

For detailed information on the proposed amendments, please read the Summary of Proposed Change.

Previous consultations

Previous consultations include:

We have also received ministerial support to introduce the CRI position.

Why your views matter

Your feedback will help us make sure:

  • the proposed requirements are suitable
  • the final legislation is clear
  • it will work as intended.

Please submit your comments using the survey link on this page.

If you are unable to provide feedback via the survey link, please email

Documents for review

All documents related to this consultation are attached in the ‘Related’ section at the bottom of the overview page. They are:

What happens next

At the end of the consultation period, we will:

  • review all comments received
  • make responses publicly available on the consultation hub (unless you request your submission remain confidential)
  • publish a Summary of Consultation which summarises the feedback received and outlines any intended changes and next steps.

All comments received on the proposed legislation will be considered. Relevant feedback that improves upon the proposed instrument will be incorporated into the final instrument.

Post-implementation review

CASA will monitor and review the new rules during the transition phase and on an ongoing basis. We will also continue work on further changes to the Part 101 regulations to achieve suitable remote pilot instructor qualification outcomes, without affecting the overall standards of RePL instructors.


  • Drone operators
  • Drone training organisation
  • Holder of RPAS remotely piloted aircraft operator’s certificate (ReOC)
  • Holder of RPAS and remote pilot licence (RePL)
  • VET and tertiary sector organisations providing aviation theory training


  • Drones/uncrewed aircraft systems