This consultation sought feedback on proposed changes to allow foreign non-civil aircraft to be type certified in the restricted category for special purpose operations (such as aerial firefighting).

We also sought feedback on 2 other miscellaneous amendments, specifically:

• European standards (certification specifications) for light sport aeroplanes and very light rotorcraft
• criteria and standards for approval of equipment used for the carriage of persons external to a rotorcraft.

The consultation opened on 28 October 2025 and closed on 25 November 2025. A summary of the feedback is below.

About this consultation

The consultation asked respondents for comments on 3 areas of change relating to Part 21, as well as any other general comments on the proposals.

We received a total of 18 responses to the consultation. The following responses were received for each area of change, where some respondents provided feedback on more than one area of change:

• sixteen responses relating to restricted category type certification for foreign non-civil aircraft
• ten responses relating to the adoption of European standards (certification specifications)
• eleven responses relating to the approval of equipment used for the carriage of persons external to a rotorcraft
• twelve respondents agreed to have their response published.

Summary of feedback

The proposal to amend the legislation and expand eligibility for aircraft to apply for type certification in the restricted category was generally supported. Most respondents were positive about shifting the focus from sovereign source requirements to operational history and supporting technical data when assessing airworthiness. One respondent was strongly opposed to the policy. The response raised concerns that the approach taken is a significant departure from the traditional Type Certificate process.

Other notable responses included the following:

• Questions were raised regarding the ability to correctly interpret the technical data if the original documentation was not developed in English.
• Concerns were raised about whether operators might have limited choice with aircraft availability and potentially have no option but to accept aircraft without the same level of airworthiness assurance as those certified to established standards.
• Suggestions were made to improve alignment between civil aviation legislation and Australian Defence Force processes to facilitate easier transfer of surplus military aircraft onto the Australian register.
• The importance of defining an appropriate certification basis was highlighted to ensure suitable designs for in-service repairs and modifications.

The proposed policy to adopt European standards (certification specifications) for light sport aeroplanes and very light rotorcraft was broadly supported. The potential for confusion was highlighted with the use of the term 'normal' when referencing airworthiness category as it has two meanings dependent on the scenario. CASA will need to further clarify the term normal when used by EASA in a Type Certificate issued under CS-LSA is in relation to the issue of a Standard Certificate Of Airworthiness and not a claim of design approval against an alternate airworthiness standard (such as CS-23).

The proposed policy amendment to update criteria and standards for approval of equipment used for the carriage of persons external to a rotorcraft was broadly supported. Some responses indicated agreement with the proposal on the condition that certification bodies that are being accepted by the policy are accountable for the products being certified.

However, some concerns were raised with some aspects of the policy, suggesting that approval for each item of equipment was burdensome on industry regarding both cost and the time to implement into an operation. It was suggested that acceptance of existing equipment used in global aviation rescue operations would provide for more innovative solutions and a 'fast track' for operators.

Some concerns were raised regarding the ability for CASA to accept particular standards by issuing an Advisory Circular. CASA believes the approach is appropriate for the purpose of the acceptance of established standards or equipment and aligns with similar approaches taken by the airworthiness authorities of both the United States and Europe.

We have completed our review of stakeholder feedback. 

Next steps

We will now undertake to implement changes to Part 21 of CASR, including its Manual of Standards and the associated guidance materials.

Each element of feedback will be considered in detail and incorporated as appropriate. No significant alterations are expected to the policy because of the feedback; however, we will endeavour to publish informative guidance materials where necessary to support these policies.