trainee
 lvl.4
Flight distance : 185686 ft
United Kingdom
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I'm not sure how DJI can foresee upcoming changes in drone regulation so I would be reluctant to take their word on transitional matters in the UK at least where new regulations are due soon because our withdrawal from the EU has left some temporary gaps. To see the direction of travel, I would urge UK pilots to read the CAA's consultation response last month at
https://consultations.caa.co.uk/ ... inal_2ndedition.pdf
Some key excerpts:
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Currently, all flights in the A1 sub-category cannot take place over groups of uninvolved people, but UAS <250g and C0 UAS can fly over uninvolved individuals. C1 UAS (<900g) must reduce, as much as possible, flights over uninvolved persons. Our view is that this complexity could make it harder for UAS remote pilots to understand and comply with this requirement. We are proposing to allow C1 UAS to overfly uninvolved people, whilst maintaining the requirement not to overfly groups of uninvolved people. This would, in effect, harmonise requirements for flying over uninvolved persons in the A1 sub-category for different types of UAS.
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At present, the regulation only explicitly allows C0 and C1 UAS to fly in the A1 sub-category. We are proposing to explicitly allow C0 and C1 UAS to fly in the A3 sub-category. Whilst this will not impact the actual operational privileges for these UAS, it will clarify that C0 and C1 can be used in these sub-categories, and help CAA communicate how class-marks relate to operational requirements.
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We are proposing to change the names of UAS sub-categories from A1, A2, and A3, to ‘Over’, ‘Near’ and ‘Far’. These revised names aim to reflect the key operational differences between each sub-category – i.e. the distance to uninvolved persons.
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We are proposing to extend the requirement for a remote pilot to take the Flyer ID test for UAS operations in the ‘Open’ category, to include when flying a UAS less than 250g with and without a camera.
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We are proposing to require C0, C1, C2 and C3 UAS to display important regulatory information, via a digital information notice, on the user interface or controller app during the product set-up. However, we also agree with Call for Input respondents, who argued that more frequent displays of this information would inconvenience experienced fliers. As such, we do not propose to require manufacturers to display the digital information notice more frequently.
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We are proposing to implement class-marking and product standards from 1st January 2026 for UAS intended to be used in the Open category. In effect, manufacturers and other economic operators placing UAS on the market for use in the Open category would need to meet class-marking requirements from this point.
We recognise the benefits of international alignment. However, we also consider there to be areas where divergence is in the UK’s interests. We are proposing to align to EU regulations for class-marking and product standards, unless there is a safety, security or user benefit that requires divergence. Chapters 3 and 5 describe specific proposals that diverge from EU regulations, relating to Remote ID, geo-fencing, and user guidance.
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However, as is described in the above section, we do not expect to fully align to EU product requirements in all cases, and the UK and EU may diverge further over time. Consequently, EU class identification labels cannot be an enduring solution to physically identify compliant products under the UK jurisdiction. Using the same label as the EU would introduce practical challenges for stakeholders to understand whether the product is compliant under the UK or EU jurisdictions, or both.
We are proposing to replace the EU class identification label with a UK-specific identification label. We expect that replacing the letter ‘C’ with ‘UK’ provides the simplest solution (i.e. replacing C1 with UK1). We believe this proposal is necessary to ensure class identification labels can be used to demonstrate compliance with the regulations under the UK and/or EU jurisdictions.
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Remote ID is proposed to be mandated for all UAS with a maximum take-off mass of 250g or more, or under 250g with a camera, in both the Open and Specific category.
We propose to implement technical mitigations that ensure Remote ID is active before a UAS takes flight.
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The current operational requirements allow legacy (i.e. non-class marked) UAS to be operated in the A1 and A3 sub-category indefinitely. Our view is that these regulations for legacy UAS would undermine the benefits of Remote ID, by allowing malicious operators to operate lawfully without Remote ID indefinitely, and by reducing the ability for police to differentiate between lawful, negligent and criminal operations. We are therefore proposing to require legacy UAS to be operated with active Remote ID from 1st January 2028 onwards (excluding UAS <250g without cameras). This requirement could be met through either remotely upgrading a UAS with inactive Remote ID capabilities, or through users attaching a compliant Remote ID add-on module to their device.
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We are also proposing to place a requirement on UAS operators and remote pilots in the Open category to have an active geo-fencing function during UAS operations of C1-C3 UAS and C0 UAS with cameras, in addition to existing regulatory requirements for geo-awareness to be used. This will provide an additional layer of assurance that UAS operators do not attempt to disable or override this capability during operations.
We do not propose to apply this requirement to legacy UAS operations, given the challenges in applying this retrospectively.
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In addition, Article 20 sets out that UAS weighing less than 250g can be used in the A1 sub-category indefinitely, and UAS weighing less than 25kg can be used in A3 sub-category indefinitely. These requirements reflect regulatory changes made by the government, following our consultation and recommendation provided in 2022.28
6.3. In the Call for Input, we asked whether the CAA should change the transitional arrangements for legacy UAS (Question 8). Of those who provided a view, 74.8% of responses were positive, citing the impacts of the current transitional arrangements, such as the costs to UAS operators of needing to replace legacy UAS with new models.
6.4. Our view is also that the current transition period set out in Article 22, due to end on 1st January 2026, could create some challenging impacts for the UAS sector. For example, these arrangements could result in some UAS operators needing to replace their aircraft in a short timeframe. It could also have undesirable environmental impacts from many UAS being disposed of earlier than necessary and/or incorrectly, undermining the sustainability of the UAS sector.
6.5. However, we also consider that an indefinite transition period for all legacy UAS may delay the safety and security benefits of class-marked UAS. We expect this to become more important over time, as the UAS sector grows.
6.6. We are proposing to extend the transitional arrangements set out in Article 22 of UK Regulation (EU) 2019/947 to 2 years after the introduction of class-marking requirements on UAS manufacturers – 1st January 2028. This aims to mitigate some of the impacts on the UAS sector of the current arrangements, whilst also ensuring we transition to using safe and secure UAS in a timely manner. It aims to reduce the regulatory burden for UAS users, where possible.
6.7. As is described in Chapter 5, we are also proposing to continue to allow the use of legacy UAS under the arrangements of Article 20 (as described in paragraph 6.2), provided that the UAS is flown with active Remote ID from 1st January 2028 onwards (excluding UAS <250g without cameras). These proposals are summarised in the below table.
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