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:

• Summary of proposed change on CD 2512MS, which provides background on the proposed standards
• Exposure Draft - Civil Aviation Safety Amendment (Minor Changes) Regulations 2025: large RPA and certificates of airworthiness
• Consultation Draft - Part 101 (Unmanned Aircraft and Rockets) Manual of Standards 2019 Amendment Instrument 2025
• MS Word copy of online consultation for ease of distribution and feedback within your organisation.

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.