Proposed Part 101 amendments - flexibility for airworthiness certification of large RPA - (CD 2512MS)

Feedback updated 27 Jan 2026

We asked

From 21 October to 21 November 2025, we asked for feedback on proposed changes to the regulations and associated Manual of Standards (MOS), that would provide more flexibility for airworthiness certification of large Remotely Piloted Aircraft (RPA).

The proposed changes are intended to provide more flexibility both in the kinds of certificates of airworthiness that are permitted for operations of large RPA, and in the circumstances where a certificate of airworthiness would not be required.

The consultation has now closed. A summary of the feedback is below.

About this consultation

The consultation survey asked for comments in relation to the 2 proposed changes, as well as any other general comments on the proposals.

You said

We received 5 responses to the consultation. Four respondents consented to having their response published and one asked for their submission to remain confidential.

Respondents included RPA owners, operators, manufacturers and representative organisations.

Summary of feedback

Overall, respondents strongly supported the proposed changes.

They broadly agreed that the current rules are too prescriptive and restrictive, particularly for lower risk operations. Respondents also noted that the current rules have constrained innovation and the scaling of advanced RPA operations.

Respondents indicated strong support for risk management controls that are robust, but practical and proportionate, so that acceptable levels of safety assurance are maintained. They emphasised that the risk assessments needed to include appropriate airworthiness assessments by competent personnel.

Several respondents commented on the JARUS Specific Operational Risk Assessment (SORA). They generally supported it, provided it is expanded and developed in a way that is practical and effective for industry. They also noted that other appropriate assessment methodologies should be acceptable.

We did

Given this strong support, CASA will continue to progress the proposed regulation and MOS amendments, with the aim of the amendments being made in the first half of 2026.

CASA will continue to work with industry stakeholders and the RPAS and AAM Strategic Regulatory Roadmap Technical Working Group on implementation arrangements, including targeted explanatory material for these amendments and further development of the SORA.

Published responses

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

Closed 21 Nov 2025

Opened 21 Oct 2025

Contact

Airworthiness Standards

131757

regulatoryconsultation@casa.gov.au

Overview

We are seeking your feedback on proposed amendments to the current requirements for airworthiness certification of large Remotely Piloted Aircraft (RPA). This action is part of the RPAS and AAM Strategic Regulatory Roadmap.

The proposed amendment would provide flexibility in 2 areas:

  • The types of certificates of airworthiness that may be used for operations of large RPA
  • The circumstances where a certificate of airworthiness may not be required for operations of large RPA.

 In both cases, the regulation amendments would be supported by associated amendments to the Part 101 Manual of Standards (MOS).

These changes aim to better support current, emerging and future technologies and operations, while maintaining an acceptable level of safety.

The proposed amendments

Operations with a certificate of airworthiness

 We propose to amend regulation 101.255 of the Civil Aviation Safety Regulations 1998 (CASR) to replace the current prescriptive requirements. This would allow any type of certificate of airworthiness, provided the operation meets the related provisions in the Part 101 MOS. The MOS would be amended to include requirements that a large RPA operated under a certificate of airworthiness must comply with the conditions and limitations of the certificate of airworthiness.

Operations without a certificate of airworthiness

We propose to amend regulation 101.046 of CASR to allow the Part 101 MOS to include circumstances where a certificate of airworthiness would not be required for operation of a large RPA. The MOS would include corresponding risk and outcome-based provisions including:

  • the RPA does not carry any occupants
  • the operation of the RPA would not have an adverse effect on safety, as demonstrated by a Specific Operations Risk Assessment (SORA) or other acceptable means; and
  • The operation is approved by CASA.

Previous consultations

Before releasing this Summary of Proposed Change, CASA engaged internally and externally via the RPAS and AAM Strategic Regulatory Roadmap Technical Working Group.

Why your views matter

Your feedback will help us make sure the proposed requirements are suitable, the final legislation is clear, and 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 regulatoryconsultation@casa.gov.au for advice.

Documents for review

Documents related to this consultation are:

What happens next

At the end of the response 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.

Audiences

  • Commercial drone operator
  • Drone manufacturers
  • Drone operators
  • Drone repairers
  • Drone training organisations
  • Holder of RPAS and remote pilot licence (RePL)
  • Holder of RPAS remotely piloted aircraft operator’s certificate (ReOC)
  • Unmanned balloon operators

Interests

  • Aircraft certification and design
  • Airworthiness/maintenance
  • Drones/uncrewed aircraft systems
  • First person view (FPV)
  • New and emerging technology
  • Unmanned balloons