The Civil Aviation Safety Authority (CASA) undertook public consultation on discussion paper DP 2521US Uncrewed aircraft operations - Research and development pathways(the DP) to explore regulatory approaches that would better support research and development (R&D) activities involving remotely piloted aircraft (RPA).

This consultation sought to ensure that any proposed approaches maintain aviation safety outcomes consistent with CASA’s statutory obligations. Further, it sought to identify specific regulatory and administrative barriers within the current Part 101 of the Civil Aviation Safety Regulations 1998 framework that may limit innovation, experimentation and iterative development.

In particular, the DP examined whether existing certification, authorisation, licensing and registration arrangements adequately reflect the unique characteristics of R&D activities. These activities are often non routine, experimental in nature and are subject to frequent changes in aircraft configuration, operational concepts and risk profiles.

The DP outlined a range of potential initiatives for further consideration. These included streamlining authorisation pathways for R&D operations, examining alternative approaches to aircraft registration during development and testing, reviewing the scope and application of the excluded category and considering the use of regulatory sandboxes and accredited test range or facility-based approval models.

Stakeholders were invited to provide feedback on whether the DP accurately reflected industry experience and to identify the most significant regulatory barriers to conducting R&D operations. They were also asked to assess whether the proposed initiatives would support innovation while maintaining appropriate levels of safety assurance.

The consultation period has now closed. A summary of the feedback received is set out below.

About this consultation

The consultation opened 13 October 2025 and closed 9 December 2025. CASA received 26 submissions from a broad cross section of stakeholders across the uncrewed aviation ecosystem. Respondents included Remotely Piloted Aircraft Operator’s Certificate (ReOC) holders, Remote Pilot License (RePL) holders, universities and research institutions, test range and facility operators, industry and professional associations, technology developers, startups and individual contributors.

Several submissions were provided by organisations actively engaged in advanced R&D activities, including the development of medium category aircraft, autonomy enabled systems, detect and avoid technologies and beyond visual line of sight (BVLOS) operations.

Overall, respondents welcomed CASA’s recognition that existing regulatory arrangements do not always align with the operational realities of R&D activities. Respondents expressed support for CASA’s openness to adopt a more proportionate, risk based and outcomes focused approach.

While the DP was generally regarded as an appropriate starting point, many respondents emphasised the need for clearer, more predictable and operationally defined regulatory pathways that are specifically tailored to R&D activities, rather than adapted from existing commercial service delivery models.

A majority of respondents indicated that the DP reflected key industry concerns, while some respondents considered that it did not. A small number of respondents did not respond to this question.

Respondents who considered the DP reflective of industry experience welcomed CASA’s acknowledgement of the administrative burden, regulatory rigour and processing delays associated with existing approval processes.

Respondents who did not consider the DP reflective of their experience noted that, while high level challenges were identified, the DP did not sufficiently articulate detailed or implementable solutions to address the practical constraints faced by R&D programs.

Across submissions, respondents consistently emphasised that any future regulatory initiatives would need to deliver tangible improvements in timeliness, predictability and proportionality to meaningfully support R&D activity.

Views on expansion of the excluded category

Feedback on the proposed expansion of the excluded category was mixed, reflecting a tension between support in the industry for regulatory simplification and concerns about maintaining appropriate levels of safety assurance.

Operations of 2–25 kg RPA for remuneration over land owned or occupied by the RPA owner (no ReOC or RePL)

Roughly half of respondents supported this option, primarily on the basis that it could reduce administrative burden for lower risk operations conducted in controlled environments. Those who did not support the proposal cited concerns related to pilot competency, organisational accountability and the potential removal of formal safety management oversight.

Operations of 2–25 kg RPA for remuneration over land not owned or occupied by the RPA owner (no ReOC, RePL required)

Whilst responses to this option were mixed with about half of respondents supporting this option, with just under a third not supportive. Those opposing the proposal raised concerns regarding third party risk exposure, the appropriateness of higher mass thresholds and the removal of organisational certification for operations involving developmental or prototype aircraft.

Across both options, respondents commonly indicated that any expansion of the excluded category should be accompanied by the introduction of additional safeguards. Suggested measures included the retention of pilot licensing requirements, operational limitations, lower mass thresholds and restrictions on the types of R&D activities permitted.

Summary of feedback

A number of consistent and interrelated themes emerged from the consultation.

Processing time and administrative delay

Respondents consistently identified CASA processing times for approvals, authorisations and variations as a significant constraint on R&D activity. Delays were most pronounced for BVLOS operations, medium category aircraft and proposals involving novel technologies or complex safety cases.

Respondents noted that R&D programs often operate within fixed funding, grant or academic timelines. As a result, regulatory delays can materially affect project viability, collaboration arrangements and investment confidence.

Need for proportionate R&D specific pathways

A strong and recurring theme was the need for regulatory pathways that recognise the distinct nature of R&D activities. Respondents emphasised that unlike regular operations, R&D operations are exploratory, iterative and subject to frequent change. They are therefore not always well suited to existing frameworks designed for stable and ongoing commercial operations.

While the ReOC framework was generally viewed as appropriate for service delivery, many respondents considered it disproportionate for early-stage testing and prototype development. Suggested approaches from respondents included staged or maturity-based approval models, use of predefined R&D operational scenarios and for evidence requirements to be scaled to experimental risk rather than commercial maturity.

Accredited test ranges and facility level approvals

There was strong and consistent support for accredited test range and facility level approval models. Respondents considered that CASA assessed facilities operating under defined procedures and oversight arrangements could host multiple R&D operators without duplicative approvals.

Such models were seen as a way to improve access to suitable airspace and infrastructure. They were also viewed as a means of reducing regulatory burden and supporting smaller organisations.

Regulatory sandboxes

Support for regulatory sandboxes was high. Respondents viewed sandboxes as a mechanism to enable controlled experimentation outside existing regulatory constraints. This was seen as particularly valuable where current rules do not readily accommodate novel technologies or concepts of operation.

However, respondents emphasised that sandbox arrangements would require clearly defined scope, eligibility criteria, operating conditions and timeframes. Transparent CASA engagement and clearly articulated exit pathways were also considered essential to maintaining safety assurance.

Licensing, training and cost barriers

Several respondents raised concerns about the cost, accessibility and flexibility of licensing and training requirements particularly for universities, students and early-stage innovators.

Respondents suggested that limited scope or research specific competency pathways could be considered for short term or constrained R&D projects. They emphasised that appropriate safety standards and supervision arrangements would need to be maintained.

Excluded category safeguards

While respondents generally supported reducing regulatory burden for genuinely low risk operations, they expressed caution about expanding the excluded category to higher weight thresholds.

Concerns focused on reduced organisational oversight and safety management, particularly for developmental or prototype aircraft that may present elevated technical and operational risk. Suggested safeguards included retaining pilot licensing requirements, limiting operations to owner occupied land and adopting lower mass thresholds for R&D specific exclusions.

Registration and weight-based thresholds

Respondents identified challenges associated with weight-based thresholds and registration requirements during iterative development. Frequent configuration changes can trigger repeated regulatory transitions and additional administrative burden.

Respondents suggested more flexible approaches to aircraft identification and registration during development. Examples included serial number-based identification and tolerance bands around weight thresholds.

Autonomy, detect and avoid and BVLOS development

Respondents engaged in autonomy, detect and avoid and BVLOS development emphasised the importance of CASA oversight for safe integration into the aviation system. At the same time, they noted that current approval pathways can be resource intensive and time consuming.

Suggested improvements included clearer development maturity tiers, staged approvals aligned with technical progress and more predictable testing pathways to support incremental advancement toward operational capability.

Guidance and awareness

Many respondents indicated that existing guidance relating to R&D pathways is fragmented and difficult to navigate. Respondents recommended the development of consolidated, R&D focused guidance material.

Suggested resources included worked examples, decision tools and flowcharts. These were seen as particularly important for new entrants and organisations with limited aviation regulatory experience.

CASA thanks all respondents for their detailed and constructive submissions. The consultation has provided valuable insight into how existing regulatory arrangements operate in practice for R&D activities.

It has also identified clear opportunities to improve regulatory proportionality, clarity, and efficiency, while maintaining appropriate levels of aviation safety.

CASA will undertake further analysis of the feedback received, including consideration of the safety, policy, legislative, and implementation implications of potential changes to the excluded category.

CASA will continue targeted engagement with industry. Some initiatives may be progressed through guidance or administrative change, while others may require further targeted consultation or regulatory amendment. CASA will communicate future steps and opportunities for continued engagement as this work progresses.  CASA's program of works to support the RPAS sector is guided by the RPAS and AAM Strategic Regulatory Roadmap, which is maintained in consultation with industry and used to inform CASA priorities for regulatory development work.