Under initiative AA5 of CASA's RPAS and AAM Strategic Regulatory Roadmap, this consultation sought comments on the proposed key changes to Civil Aviation Orders (CAO) 100.23 and 100.24, and the related section of guidance material at Draft AC 101-01 Remotely piloted aircraft systems - licensing and operations.

The intent of these changes is to reduce administration and time involved in the maintenance authority application and approval process required for large remotely piloted aircraft (RPA 150 kg and over).

The consultation ran from 21 October 2025 to 18 November 2025. Earlier in 2025, we invited input from industry during CASA’s RPAS and AAM Strategic Regulatory Roadmap industry webinar. We discussed the proposals with the CASA and industry co-chaired RPAS and AAM Strategic Regulatory Roadmap Technical Working Group (TWG).

About this consultation

The consultation sought feedback on the following 3 key changes:

Key change 1

This change reduces administration and timeframes for large RPA applicants, by moving maintenance authority approval to a more appropriate level within CASA.

This is achieved by inserting paragraph 1.1A within CAO 100.24, which states that paragraph 1.1 does not apply to an applicant for a maintenance authority for RPA maintenance. This would mean that the approval may be granted by a person other than the Director of Aviation Safety.
A consultation draft of the proposed CAO was provided to accompany this key change.

Key change 2

This change modernises language to use gender neutral terminology, remove obsolete application forms and references, and update application submission methods, within CAO 100.23 and 100.24. A consultation draft of the amendments was provided to accompany this key change.

Key change 3

This change updates related guidance material by supporting CAO 100.24 within section 7.3.4 of AC 101-01. A consultation draft of the AC section was provided with this key change.

In total, there were 4 respondents to the consultation. Of the respondents who made written submissions, 3 consented to having their submissions made public and one requested their submission be confidential.

All responses received were from people with affiliation to aviation, industry or related organisations. This included representation from RePL holders, ReOC holders, CPL holders, RPAS operators and industry associations.

Summary of feedback

All respondents supported the intent of the proposed changes and the legislative amendments set out in the consultation draft instrument provided.

Some respondents offered further comments, particularly on the safety risk assessment of RPAS operations, such as under Specific Operations and Risk Assessment (SORA). It is noted that whilst the proposed guidance update referenced SORA at a high level, the amendments are not tied to any particular kind of operational risk assessment.

We also received comments on matters that are not affected by the proposed amendments and therefore are outside the scope of the consultation. These comments covered:

• the current competency standards required for maintenance authorities
• the role of Maintenance Controllers (under CASR Part 101) in the medium sized RPA category
• CASA's internal resourcing for the assessment of applications
• ICAO Annex 1.

Next steps

Overall, respondents have supported the proposals. As a result, CASA will continue to implement the key changes to CAO 100.23 and 100.24 and further improve section 7 of the supporting guidance material in AC 101-01.

CASA will also continue to work with the RPAS and AAM Strategic Regulatory Roadmap TWG and broader industry on future improvements.

Published responses

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