Overview

We are seeking your feedback on proposed changes to Civil Aviation Order (CAO) 100.24.

The intent of these changes is to reduce the administration and time involved in the maintenance authority application and approval process required for large Remotely Piloted Aircraft (RPA). The amendment would establish a more efficient administrative arrangement to streamline applications and improve processing times.

The proposed minor amendments to CAO 100.24 relate to Director of Aviation Safety (DAS) approval of applications for maintenance permissions specifically for large RPA.

The amendment is a response to CASA's RPAS and AAM Strategic Regulatory Roadmap initiative AA5: ‘progress the development of a fit for purpose continuing airworthiness policy for higher-risk RPAS’. This initiative includes consideration of maintenance personnel authorisations and continuing airworthiness management policies through risk and outcome-based principals. 

The proposed amendments / Principal changes that would occur

Under the CAO amendment, applicants must continue to demonstrate the current competency standards required for a maintenance permission for large RPA. If successful, approvals would now be made by CASA at a more efficient regulatory oversight level.

There will be no change to the competency standards and approval process required for maintenance permissions for conventionally piloted aircraft.

We also propose to:

• modernise language to use gender neutral terminology
• remove obsolete application forms and CAO references.
• modernise submission methods within CAO 100.23 and 100.24.

A consultation draft of the proposed amended legislation is provided with this consultation. 

Previous consultations

Prior to the release of this Summary of Proposed Change, CASA consulted internally and externally through the RPAS and AAM Strategic Regulatory Roadmap Technical Working Group (TWG), which includes representatives from CASA and industry.

The concept was also introduced to industry during CASA’s RPAS and AAM Strategic Regulatory Roadmap industry webinar in early 2025. This encouraged industry participants to share their experiences and provide input through TWG members.

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

The documents related to this consultation are:

• Summary of proposed change on CD 2524MS, which provides background on the proposed amendments and related technical guidance material.
• Consultation Draft - Civil Aviation Orders 100.23 and 100.24 Amendment Instrument 2025 (No. 1)
• 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.