Guidance on airworthiness related operational safety objectives (OSO) for Australian specific operational risk assessment (AusSORA)

In this consultation, we asked for views on draft Annex A to advisory circular AC 101-06 -Guidance for compliance with airworthiness operational safety objectives for Australian specific operational risk assessment, which provided guidance on airworthiness-related criteria and means of compliance for AusSORA.

The consultation opened on 7 April 2026 and closed on 5 May 2026. A summary of the feedback is below.

About this consultation

AC 101-06 provides information on AusSORA. The proposed annex supplements the AC and focuses on 3 operational safety objectives (OSO):

• OSO #04 - design to an Airworthiness Design Standard (ADS)
• OSO #05 - system safety and reliability
• OSO #24 - adverse environmental conditions.

The Annex is mainly intended for drone designers, manufacturers, operators, system integrators, engineers, and consultants involved in preparing compliance to support AusSORA applications. The annex forms part of the RPAS and Advanced Air Mobility regulatory roadmap.

CASA asked whether the annex is clear, practical, and sufficient to support operational approvals and compliance with airworthiness-related safety objectives under AusSORA.

The feedback will help determine if the guidance meets industry needs and supports regulatory development.

We received 11 responses to the consultation. Seven respondents consented to having their response published and 4 asked for their submission to remain confidential.

Respondents included drone designers, manufacturers, system integrators, operators, engineers, flight test organisations, consultants and representative organisations.

Summary of feedback

The consultation responses indicate a clear level of support for Annex A, with most stakeholders recognising it as a valuable and necessary development. Most respondents supported the proposal. A small number raised concerns regarding implementation and potential impacts, while still supporting the regulatory direction.

Annex A is consistently described as a strong foundation that aligns with the broader AusSORA framework and international SORA principles. Respondents noted that the structure is logical and generally consistent with established airworthiness and risk-based regulatory approaches.

However, stakeholders identified opportunities to improve clarity and practical application, particularly with evidence expectations. Many respondents said further clarity would help in understanding what makes up acceptable evidence, how submissions should be structured, and the level of assurance expected across different SAIL levels. While the Annex provides this information through the Means of Compliance and Additional Guidance sections, many suggested additional supporting materials to support interpretation.

Feedback also highlighted the importance of ensuring proportionality is clearly reflected in practice. Several respondents noted that unclear evidence expectations could lead to conservative implementation, with some concerned that SAIL III and IV requirements might resemble traditional certification. CASA intends the Annex to remain risk-based and proportionate, with requirements scaling by SAIL level and robustness. Higher SAIL levels will bring increased airworthiness expectations but, these are not intended to replicate the rigour of type certification, particularly at SAIL IV and below.

Stakeholders emphasised the need for flexible compliance pathways, including alternative, data-driven and operational approaches. This was often linked to practical considerations such as access to design data, particularly for COTS-based systems, and the respective roles of operators and manufacturers. CASA acknowledges these constraints and intends to maintain flexibility while ensuring an appropriate level of safety assurance consistent with the intended SAIL of the operation.

Additional comments touched on broader framework aspects, including reuse of accepted evidence, treatment of configuration changes over time, and alignment with international approaches. Some respondents raised detailed technical observations about terminology, table structure and parameter derivation. These are being considered as part of ongoing refinement.

Given the broad stakeholder support for Annex A, the guidance will proceed as planned with targeted refinements. The changes will be implemented together with further guidance for additional airworthiness OSOs.

Consistent with stakeholder feedback, updates will focus on improving clarity, proportionality, and usability, including consideration of additional supporting material. Broader issues, such as application processes, evidence reuse, and roles within the framework, will continue to be addressed through the ongoing development of AC 101‑06 and the wider AusSORA framework, with continued engagement with industry as the guidance matures.