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

Closes 21 Nov 2025

Policy topic 2 - operations of large RPA without a certificate of airworthiness

Proposed Policy

For operations of large Remotely Piloted Aircraft (RPA) without a certificate of airworthiness, CASA proposes that regulation 101.046 of the Civil Aviation Safety Regulations 1998 (CASR), be amended to provide for the Part 101 Manual of Standards (MOS) to include circumstances under which a certificate of airworthiness would not be required for operation of a large RPA. The MOS would be amended to 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.

Policy Aim

The intent is to provide more flexibility for operations of large RPA whilst maintaining appropriate levels of safety.

The default policy position of the Civil Aviation Act 1988 is that aircraft must have a certificate of airworthiness, unless permitted otherwise.

This proposed amendment is intended to provide more flexibility around lower risk operations of large RPA without a certificate of airworthiness.

See policy topic 1 for operations of large RPA with a certificate of airworthiness.

Please provide any comments you may have on the proposed policy for operations of large RPA without a certificate of airworthiness.

Airworthiness certification requirements for large RPA

CASR 101.255 currently requires that a large RPA must have either a restricted category certificate of airworthiness or an experimental certificate. Regulation 101.046 does not provide for large RPA to be operated without a certificate of airworthiness.

CASA proposes that regulation 101.046 be amended provide for operation of large RPA without a certificate of airworthiness, subject to the associated provisions in the Part 101 MOS.