UAS.LUC.010 General requirements for an LUC

Regulation (EU) 2020/639

(1) A legal person is eligible to apply for an LUC under this Part.

(2) An application for an LUC or for an amendment to an existing LUC shall be submitted to the competent authority and shall contain all of the following information:

(a) a description of the UAS operator’s management system, including its organisational structure and safety management system;

(b) the name(s) of the responsible UAS operator’s personnel, including the person responsible for authorising operations with UASs;

(c) a statement that all the documentation submitted to the competent authority has been verified by the applicant and found to comply with the applicable requirements.

(3) If the requirements of this Part are met, an LUC holder may be granted the privileges, in accordance with point UAS.LUC.060.


UAS operators may decide to apply for authorisations or issue declarations, as applicable, for their operations, or apply for an LUC.

An LUC holder is considered to be a UAS operator; therefore, they must register according to Article 14 and can do it in parallel to the LUC application.


The application should include at least the following information:

(a) Name and address of the applicant’s principal place of business.

(b) Statement that the application serves as a formal application for a LUC.

(c) Statement that all the documentation submitted to the competent authority has been verified by the applicant and found to comply with the applicable requirements.

(d) Desired date for the operation to commence.

(e) Signature of the applicant’s accountable manager.

(f) List of attachments that accompany the formal application (the following is not an exhaustive list):

(i) name(s) of the responsible UAS operator’s personnel, including the accountable manager, operations, maintenance and training managers, the safety manager and security manager, the person responsible for authorising operations with UASs;

(ii) list of UASs to be operated;

(iii) details of the method of control and supervision of operations to be used;

(iv) identification of the operation specifications sought;

(v) OM and safety management manual (SMM). (Note: the OM and SMM may be combined under the LUC Manual);

(vi) schedule of events in the process to gain the LUC certificate with appropriate events addressed and target dates;

(vii) documents of purchase, leases, contracts or letters of intent;

(viii) arrangements for the facilities and equipment required and available; and

(ix) arrangements for crew and ground personnel training and qualification.

UAS.LUC.020 Responsibilities of the LUC holder

Regulation (EU) 2020/639

The LUC holder shall:

(1) comply with the requirements of points UAS.SPEC.050 and UAS.SPEC.060;

(2) comply with the scope and privileges defined in the terms of approval;

(3) establish and maintain a system for exercising operational control over any operation conducted under the terms of its LUC;

(4) carry out an operational risk assessment of the intended operation in accordance with Article 11 unless conducting an operation for which an operational declaration is sufficient according to point UAS.SPEC.020,

(5) keep records of the following items in a manner that ensures protection from damage, alteration and theft for a period at least 3 years for operations conducted using the privileges specified under point UAS.LUC.060:

(a) the operational risk assessment, when required according to point (4), and its supporting documentation;

(b) mitigation measures taken; and

(c) the qualifications and experience of personnel involved in the UAS operation, compliance monitoring and safety management;

(6) keep personnel records referred to in point (5)(c) as long as the person works for the organisation and shall be retained until 3 years after the person has left the organisation.


The organisation and methods established by the LUC holder to exercise operational control within its organisation should be included in the OM as an additional chapter in relation to the template provided in GM1 UAS.SPEC.030(3)(e).


‘Operational control’ should be understood as the responsibility for the initiation, continuation, termination or diversion of a flight in the interest of safety.

‘System’ in relation to operational control should be understood as the organisation, methods, documentation, personnel and training of those personnel for the initiation, continuation, termination or diversion of a flight in the interest of safety.


The record-keeping system should ensure that all records are stored in a manner that ensures their protection from damage, alteration and theft. They should be accessible on request of the NAA, whenever needed within a reasonable time. These records should be organised in a way that ensures traceability, availability and retrievability throughout the required retention period. The retention period starts when the record was created or last amended. Adequate backups should be ensured.

UAS.LUC.030 Safety management system

Regulation (EU) 2020/639

(1) An UAS operator who applies for an LUC shall establish, implement and maintain a safety management system corresponding to the size of the organisation, to the nature and complexity of its activities, taking into account the hazards and associated risks inherent in these activities.

(2) The UAS operator shall comply with all of the following:

(a) nominate an accountable manager with authority for ensuring that within the organisation all activities are performed in accordance with the applicable standards and that the organisation is continuously in compliance with the requirements of the management system and the procedures identified in the LUC manual referred to in point UAS.LUC.040;

(b) define clear lines of responsibility and accountability throughout the organisation;

(c) establish and maintain a safety policy and related corresponding safety objectives;

(d) appoint key safety personnel to execute the safety policy;

(e) establish and maintain a safety risk management process including the identification of safety hazards associated with the activities of the UAS operator, as well as their evaluation and the management of associated risks, including taking action to mitigate those risks and verify the effectiveness of the action;

(f) promote safety in the organisation through:

(i)             training and education;

(ii)           communication;

(g) document all safety management system key processes for making personnel aware of their responsibilities and of the procedure for amending this documentation; key processes include:

(i)             safety reporting and internal investigations;

(ii)           operational control;

(iii)          communication on safety;

(iv)          training and safety promotion;

(v)           compliance monitoring;

(vi)          safety risk management;

(vii)        management of change;

(viii)      interface between organisations;

(ix)          use of sub-contractors and partners;

(h) include an independent function to monitor the compliance and adequacy of the fulfilment of the relevant requirements of this Regulation, including a system to provide feedback of findings to the accountable manager to ensure effective implementation of corrective measures as necessary;

(i) include a function to ensure that safety risks inherent to a service or product delivered through subcontractors are assessed and mitigated under the operator’s safety management system.

(3) If the organisation holds other organisation certificates within the scope of Regulation (EU) 2018/1139, the safety management system of the UAS operator may be integrated with the safety management system that is required by any of those additional certificate(s).


(a) The accountable manager should have the authority to ensure that all activities are carried out in accordance with the requirements of the UAS Regulation.

(b) The safety manager should:

(1) facilitate hazard identification, risk analysis, and risk management;

(2) monitor the implementation of risk mitigation measures;

(3) provide periodic reports on safety performance;

(4) ensure maintenance of the safety management documentation;

(5) ensure that there is safety management training available and that it meets acceptable standards;

(6) provide all the personnel involved with advice on safety matters; and

(7) ensure the initiation and follow-up of internal occurrence investigations.

(c) Management and other personnel of the LUC holder should be qualified for the planned operations in order to meet the relevant requirements of the UAS Regulation.

(d) The LUC holder should ensure that its personnel receive appropriate training to remain in compliance with the relevant requirements of the UAS Regulation.


The accountable manager is a single, identifiable person who has the responsibility for the effective and efficient performance of the LUC holder’s safety management system.


(a) The safety policy should:

(1) be endorsed by the accountable manager;

(2) reflect organisational commitments regarding safety, and its proactive and systematic management;

(3) be communicated, with visible endorsement, throughout the organisation;

(4) include internal reporting principles, and encourage personnel to report errors related to UAS operations, incidents and hazards; and

(5) recognise the need for all personnel to cooperate with compliance monitoring and safety investigations.

(b) The safety policy should include a commitment to:

(1) improve towards the highest safety standards;

(2) comply with all applicable legislation, meet all applicable standards, and consider best practices;

(3) provide appropriate resources;

(4) apply the human factors principles;

(5) enforce safety as a primary responsibility of all managers; and

(6) apply ‘just culture’ principles and, in particular, not to make available or use the information on occurrences:

(i) to attribute blame or liability to someone for reporting something which would not have been otherwise detected; or

(ii) for any purpose other than the improvement of safety.

(c) The senior management of the UAS operator should:

(1) continually promote the UAS operator’s safety policy to all personnel, and demonstrate their commitment to it;

(2) provide the necessary human and financial resources for the implementation of the safety policy; and

(3) establish safety objectives and associated performance standards.


The safety policy is the means whereby an organisation states its intention to maintain and, where practicable, improve safety levels in all its activities and to minimise its contribution to the risk of an accident or serious incident as far as is reasonably practicable. It reflects the management’s commitment to safety, and should reflect the organisation’s philosophy of safety management, as well as be the foundation on which the organisation’s safety management system is built. It serves as a reminder of ‘how we do business here’. The creation of a positive safety culture begins with the issuance of a clear, unequivocal direction.

The commitment to apply ‘just culture’ principles forms the basis for the organisation’s internal rules that describe how ‘just culture’ principles are guaranteed and implemented.

For organisations that have their principal place of business in a MS, Regulation (EU) No 376/2014 defines the ‘just culture’ principles to be applied (refer in particular to Article 16(11) thereof).


The functions of the safety manager may be fulfilled by the accountable manager or another person charged by the UAS operator with the responsibility of ensuring that the UAS operator remains in compliance with the requirements of the UAS Regulation.

Where the safety manager already fulfils the functions of the compliance monitoring manager, the accountable manager cannot be the safety manager.

Depending on the size of the organisation and the nature and complexity of its activities, the safety manager may be assisted by additional safety personnel for the performance of all the safety management tasks.

Regardless of the organisational set-up, it is important that the safety manager remains the unique focal point as regards the development, administration, and maintenance of the organisation’s management system.


A UAS operator may include a safety committee in the organisational structure of its safety management system and, if needed, one or more safety action groups.

(a) Safety committee

A safety committee may be established to support the accountable manager in their safety responsibilities. The safety committee should monitor:

(1) the UAS operator’s performance against safety objectives and performance standards;

(2) whether safety action is taken in a timely manner; and

(3) the effectiveness of the UAS operator’s safety management processes.

(b) Safety action group

(1) Depending on the scope of the task and the specific expertise required, one or more safety action groups should be established to assist the safety manager in their functions.

(2) The safety action group should be comprised of managers, supervisors and personnel from operational areas, depending on the scope of the task and the specific expertise required.

(3) The safety action group should at least perform the following:

(i) monitor operational safety and assess the impact of operational changes on safety;

(ii) define actions to mitigate the identified safety risks; and

(iii) ensure that safety measures are implemented within agreed timescales.


The UAS operator should appoint personnel to manage key fields of activity such as operations, maintenance, training, etc.


The safety management system documentation of the LUC holder should be included in an SMM or in the LUC manual. If that documentation is contained in more than one operator’s manual and is not duplicated, cross references should be provided.


The purpose of safety reporting and internal investigations is to use reported information to improve the level of safety performance of the UAS operator. The purpose is not to attribute blame or liability.

The specific objectives of safety reporting and internal investigations are to:

(a) enable assessments of the safety implications of each relevant incident and accident, including previous similar occurrences, so that any necessary action can be initiated; and

(b) ensure that knowledge of relevant incidents and accidents is disseminated so that other persons and UAS operators may learn from them.

All occurrence reports that are considered to be reportable by the person who submits the report should be retained, as the significance of such reports may only become obvious at a later date.


(a) The organisation should establish communication about safety matters that:

(1) ensures that all personnel are aware of the safety management activities as appropriate for their safety responsibilities;

(2) conveys safety-critical information, especially information related to assessed risks and analysed hazards;

(3) explains why particular actions are taken; and

(4) explains why safety procedures are introduced or changed.

(b) Regular meetings with personnel, where information, actions, and procedures are discussed, may be used to communicate safety matters.


Training, combined with safety communication and information sharing form part of safety promotion and supplement the organisation’s policies, encouraging a positive safety culture and creating an environment that is favourable to the achievement of the organisation’s safety objectives.

Safety promotion can also be the instrument for the development of a just culture.

Depending on the particular risk, safety promotion may constitute or complement a risk mitigation action and an effective reporting system.


(a) The accountable manager should designate a manager to monitor the compliance of the LUC holder with:

(1) the terms of approval, the privileges, the risk assessment and the resulting mitigation measures;

(2) all operator’s manuals and procedures; and

(3) training standards.

(b) The compliance monitoring manager should:

(1) have knowledge of, and experience in, compliance monitoring;

(2) have direct access to the accountable manager to ensure that findings are addressed, as necessary; and

(3) not be one of the other persons referred to in UAS.LUC.030(2)(c).

(c) The tasks of the compliance monitoring manager may be performed by the safety manager, provided that the latter has knowledge of, and experience in, compliance monitoring.

(d) The compliance monitoring function should include audits and inspections of the LUC holder. The audits and inspections should be carried out by personnel who are not responsible for the function, procedure or products being audited.

(e) An organisation should establish an audit plan to show when and how often the activities as required by the UAS Regulation will be audited.

(f) The independent audit should ensure that all aspects of compliance, including all the subcontracted activities, are checked within a period defined in the scheduled plan, and agreed by the competent authority.

(g) Where the organisation has more than one approved location, the compliance monitoring function should describe how these locations are integrated into the system and include a plan to audit each location in a risk-based programme as agreed by the competent authority.

(h) A report should be raised each time an audit is carried out, describing what was checked and the resulting findings against applicable requirements and procedures.

(i) The feedback part of the compliance monitoring function should address who is required to rectify any non-compliance in each particular case, and the procedure to be followed if rectification is not completed within appropriate timescales. The procedure should lead to the accountable manager.

(j) The LUC holder should be responsible for the effectiveness of the compliance monitoring function, in particular for the effective implementation and follow-up of all corrective measures.


The primary objective of the compliance monitoring function is to enable the UAS operator to ensure a safe operation and to remain in compliance with the UAS Regulation.

An external organisation may be contracted to perform compliance monitoring functions. In such cases, that organisation should designate the compliance monitoring manager.

The compliance monitoring manager may use one or more auditors to carry out compliance audits and inspections of the LUC holder under their own responsibility.


The LUC holder should have a safety management system that is able to perform at least the following:

(a) identify hazards through reactive, proactive, and predictive methodologies, using various data sources, including safety reporting and internal investigations;

(b) collect, record, analyse, act on and generate feedback about hazards and the associated risks that affect the safety of the operational activities of the UAS operator;

(c) develop an operational risk assessment as required by Article 11;

(d) carry out internal safety investigations;

(e) monitor and measure safety performance through safety reports, safety reviews, in particular during the introduction and deployment of new technologies, safety audits, including periodically assessing the status of safety risk controls, and safety surveys;

(f) manage the safety risks related to a change, using a documented process to identify any external and internal change that may have an adverse effect on safety; the management of change should make use of the UAS operator’s existing hazard identification, risk assessment, and mitigation processes;

(g) manage the safety risks that stem from products or services delivered through subcontractors, by using its existing hazard identification, risk assessment, and mitigation processes, or by requiring that the subcontractors have an equivalent process for hazard identification and risk management; and

(h) respond to emergencies using an ERP that reflects the size, nature, and complexity of the activities performed by the organisation. The ERP should:

(1) contain the action to be taken by the UAS operator or specified individuals in an emergency;

(2) provide for a safe transition from normal to emergency operations and vice versa;

(3) ensure coordination with the ERPs of other organisations, where appropriate; and

(4) describe emergency training/drills, as appropriate.


In very broad terms, the objective of safety risk management is to eliminate risk, where practical, or reduce the risk (likelihood/severity) to acceptable levels, and to manage the remaining risk to avoid or mitigate any possible undesirable outcome. Safety risk management is, therefore, integral to the development and application of effective safety management.

Safety risk management can be applied at many levels in an organisation. It can be applied at the strategic level and at operational levels. The potential for human error, its influences and sources, should be identified and managed through the safety risk management process. Human factors risk management should allow the organisation to determine where it is vulnerable to human performance limitations.


Unless properly managed, changes in organisational structures, facilities, the scope of work, personnel, documentation, policies and procedures, etc. can result in the inadvertent introduction of new hazards, which expose the organisation to new, or increased risk. Effective organisations seek to improve their processes, with conscious recognition that changes can expose the organisations to potentially latent hazards and risks if the changes are not properly and effectively managed.

Regardless of the magnitude of a change, large or small, proactive consideration should always be given to the safety implications. This is primarily the responsibility of the team that proposes and/or implements the change. However, change can only be successful if all the personnel affected by the change are engaged and involved, and they participate in the process. The magnitude of a change, its safety criticality, and its potential impact on human performance should be assessed in any change management process.

The process for the management of change typically provides principles and a structured framework for managing all aspects of the change. Disciplined application of change management can maximise the effectiveness of the change, engage staff, and minimise the risks inherent in change.

Change is the catalyst for an organisation to perform the hazard identification and risk management processes.

Some examples of change include, but are not limited to:

(a) changes to the organisational structure;

(b) a new type of UAS being employed;

(c) additional UASs of the same or similar type being acquired;

(d) significant changes in personnel (affecting key personnel and/or large numbers of personnel, high turn-over);

(e) new or amended regulations;

(f) changes in financial status;

(g) new location(s), equipment, and/or operational procedures; and

(h) new subcontractors.

A change may have the potential to introduce new human factors issues, or exacerbate pre-existing issues. For example, changes in computer systems, equipment, technology, personnel (including the management), procedures, the work organisation, or work processes are likely to affect performance.

The purpose of integrating human factors into the management of change is to minimise potential risks by specifically considering the impact of the change on the people within a system.

Special consideration, including any human factors issues, should be given to the ‘transition period’. In addition, the activities utilised to manage these issues should be integrated into the change management plan.

Effective management of change should be supported by the following:

(a) implementation of a process for formal hazard analyses/risk assessment for major operational changes, major organisational changes, changes in key personnel, and changes that may affect the way a UAS operation is carried out;

(b) identification of changes likely to occur in business which would have a noticeable impact on:

(1) resources — material and human;

(2) management guidance — processes, procedures, training; and

(3) management control;

(c) safety case/risk assessments that are focused on aviation safety; and

(d) involvement of key stakeholders in the change management process as appropriate.

During the change management process, previous risk assessments and existing hazards are reviewed for possible effects.


Safety risk management processes should specifically address the planned implementation of, or participation in, any complex arrangements (such as when multiple organisations are contracted, or when multiple levels of contracting/subcontracting are included).

Hazard identification and risk assessment start with the identification of all parties involved in the arrangement, including independent experts and non-approved organisations. This extends to the overall control structure, and assesses in particular the following elements across all subcontract levels and all parties within such arrangements:

(a) coordination and interfaces between the different parties;

(b) applicable procedures;

(c) communication between all the parties involved, including reporting and feedback channels;

(d) task allocation, responsibilities and authorities; and

(e) the qualifications and competency of key personnel.

Safety risk management should focus on the following aspects:

(a) clear assignment of accountability and allocation of responsibilities;

(b) only one party is responsible for a specific aspect of the arrangement — there should be no overlapping or conflicting responsibilities, in order to eliminate coordination errors;

(c) the existence of clear reporting lines, both for occurrence reporting and progress reporting; and

(d) the possibility for staff to directly notify the organisation of any hazard by suggesting an obviously unacceptable safety risk as a result of the potential consequences of this hazard.

Regular communication between all parties to discuss work progress, risk mitigation actions, changes to the arrangement, as well as any other significant issues, should be ensured.


(a) When an LUC holder uses products or services delivered through a subcontractor that is not itself approved in accordance with this Subpart, the subcontractor should work under the terms of the LUC.

(b) Regardless of the certification status of the subcontractor, the LUC holder is responsible for ensuring that all subcontracted products or services are subject to the hazard identification, risk management, and compliance monitoring of the LUC holder.

UAS.LUC.040 LUC manual

Regulation (EU) 2020/639

(1) An LUC holder shall provide the competent authority with an LUC manual describing directly or by cross reference its organisation, the relevant procedures and the activities carried out.

(2) The manual shall contain a statement signed by the accountable manager that confirms that the organisation will at all times work in accordance with this Regulation and with the approved LUC manual. When the accountable Manager is not the Chief Executive Officer of the organisation, the chief executive officer shall countersign the statement.

(3) If any activity is carried out by partner organisations or subcontractors, the UAS operator shall include in the LUC manual procedures on how the LUC holder shall manage the relationship with those partner organisations or subcontractors.

(4) The LUC manual shall be amended as necessary to retain an up-to-date description of the LUC holder’s organisation, and copies of amendments shall be provided to the competent authority.

(5) The UAS operator shall distribute the relevant parts of the LUC manual to all its personnel in accordance with their functions and duties.


(a) The LUC holder should ensure that all personnel are able to understand the language in which those parts of the LUC manual which pertain to their duties and responsibilities are written.

(b) The LUC manual should contain a statement signed by the accountable manager that confirms that the organisation will at all times work in accordance with the UAS Regulation, as applicable, and with the approved LUC manual. When the accountable manager is not the chief executive officer of the organisation, then the chief executive officer shall countersign the statement.


The LUC manual may contain references to the OM, where an OM is compiled in accordance with GM1 UAS.SPEC.030(3)(e).

The LUC manual should contain at least the following information, customised according to the complexity of the UAS operator.


Operator’s name

Table of contents

1. Introduction (the information under Chapter O, points 1-6 of the OM may be duplicated here or simply referenced to the OM)

2. SMM

2.1. Safety policy (provide details of the UAS operator’s safety policy, safety targets)

2.2. Organisational structure (include the organogram and brief description thereof)

2.3. Duties and responsibilities of the accountable manager and key management personnel; (in addition, clearly identify the person who authorises operations)

2.4. Safety management system (provide a description of the safety management system, including the lines of responsibilities with regard to safety matters)

2.5. Operational control system (provide a description of the procedures and responsibilities necessary to exercise operational control with respect to flight safety)

2.6. Compliance monitoring (provide a description of the compliance monitoring function)

2.7. Safety risk management (the information about hazard identification, safety risk assessment and mitigation under Chapter A of the OM may be duplicated here or simply referenced to the OM)

2.8. Management of change (description of the process to identify safety-critical changes within the organisation and its operation and to eliminate or modify safety risk controls that are no longer needed or effective due to such changes)

2.9. Development and approval of an operational scenario (provide a description of the process)

2.10. Interface with subcontractors and partners (describe the relationship with any subcontractor delivering products or services to the UAS operator as well as with partners, if available)

2.11. Documentation of key management system processes

3. OM (the information under Chapters 2-11 of the OM may be duplicated here or references to the OM may be provided)

4. Handling, notifying and reporting accidents, incidents and occurrences

5. Handling of dangerous goods (specify the relevant regulations and instructions to crew members concerning the transport of dangerous goods such as pesticides and chemicals, etc. and the use of dangerous goods during operations such as batteries and fuel cells, engines, magnetising materials, pyrotechnics, flares and firearms)


If any activity is carried out by partner organisations or subcontractors, the LUC manual should include a relevant statement of how the LUC holder is able to ensure compliance with UAS.LUC.030(2)(i), and should contain, directly or by cross reference, descriptions of, and information on, the activities of those organisations or subcontractors, as necessary to substantiate this statement.

UAS.LUC.050 Terms of approval of the LUC holder

Regulation (EU) 2020/639

(1) The competent authority shall issue an LUC after it is satisfied that the UAS operator complies with points UAS.LUC.020, UAS.LUC.030 and UAS.LUC.040.

(2) The LUC shall include:

(a) the UAS operator identification;

(b) the UAS operator’s privileges;

(c) authorised type(s) of operation;

(d) the authorised area, zone or class of airspace for operations, if applicable;

(e) any special limitations or conditions, if applicable;




(Terms of approval of an LUC holder)



State of the operator (1):


Issuing competent authority(2):

LUC # (4):

Operator name (5):

Registration number of the UAS operator (6):

Operator address (8):

Telephone (9):

Email (10):

Contact details, at which operational management can be contacted without undue delay (7):


This certificate certifies that ……………………..(5) is authorised to perform UAS operations, as defined in the attached UAS operations specifications, in accordance with the LUC manual, with the Annex to Regulation (EU) No 2019/947 and with Annex IX to Regulation (EU) 2018/1139.

Date of issue (11):____

Name and signature (12):________

Title: _______

1. Enter the name of the State of the operator.

2. Enter the identification of the issuing competent authority.

3. Reserved for use of the competent authority.

4. Enter the approval reference (digital and/or letter code) of the LUC, as issued by the competent authority.

5. Enter the name of the legal entity of the UAS operator and UAS operator’s trading name, if different from the name of the legal entity.

6. Enter the registration number of the UAS operator, provided according to Article 14 of the UAS Regulation.

7. Enter contact details such as the telephone numbers, including the country code, and the email address at which operational management can be contacted without undue delay for issues related to UAS operations, the airworthiness of UAS, remote crew competency and other matters as appropriate.

8. Enter the UAS operator’s principal place of business address.

9. Enter the UAS operator’s principal place of business telephone details, including the country code.

10. Enter the UAS operator’s email.

11. Enter the issue date of the LUC (dd-mm-yyyy).

12. Enter the title, name and signature of the competent authority representative. In addition, an official stamp may be applied on the LUC.


LUC (1):  

Operator name (2):

The UAS operator (2)__________ has the privilege to ___________________(3), subject to the following:

UAS model (4): _______________;     UAS serial number or registration mark (5): _________________

Type(s) of UAS operation (6) or :

Specifications (7):

Special limitations (8):


1. _____________;

2. _____________;




Issuing competent authority (10):



Date (13): 


1. Enter the approval reference (digital and/or letter code) of the LUC, as issued by the competent authority.

2. Enter the name of the legal entity of the UAS operator and UAS operator’s trading name, if different from the name of the legal entity.

3. Enter any privilege listed in AMC1 UAS.LUC.060 that has been granted.

4. Enter the UAS model.

5. Enter the UAS serial number or the UAS registration mark if applicable.

6. Specify the type(s) of UAS operation (e.g. STS, PDRA when applicable, or type of UAS operations in case the operation is not covered by an STS or a PDRA; the type of UAS operation may be: survey, linear inspection, urban delivery; agricultural, photography, advertising, calibration, construction work, stringing power line, aerial mapping, pollution control, news media, television and movie, flying display, competition, etc.).

7. Enter the relevant specifications describing where the operation is allowed to take place (area of operation or class of airspace for operations; maximum height, BVLOS/VLOS; range; etc.).

8. Enter the limitations related to: restriction of the ground area (i.e. controlled ground area, population density; ground risk buffer); the UAS performance and equipment (i.e. maximum speed; maximum weight etc.); data link or communications; external systems or loads; carriage of dangerous goods, possibility of handover, etc.

9. Enter remarks such as the remote pilot’s competency; normal, contingency and emergency procedures.

10. Enter the identification of the issuing competent authority.

11. Enter the telephone number of the competent authority, including the country code.

12. Enter the email address of the competent authority.

13. Issue date of the operations specifications (dd-mm-yyyy).

14. Signature of the competent authority representative.

UAS.LUC.060 Privileges of the LUC holder

Regulation (EU) 2020/639

When satisfied with the documentation provided, the competent authority:

(1) shall specify the terms and conditions of the privilege granted to the UAS operator in the LUC; and

(2) may, within the terms of approval, grant to an LUC holder the privilege to authorise its own operations without:

(a) submitting an operational declaration;

(b) applying for an operational authorisation.


Within the terms of its approval, the LUC holder should be able:

(a) without prior declaration to the competent authority, to authorise its own operations based on an STS; and

(b) without prior approval of the competent authority, to authorise one or more of the following types of own operations:

(1) one based on a PDRA that requires an authorisation;

(2) one based on one or more modifications of an STS (variants), which does not involve changes in the ConOps, the category of UAS used or the competencies of the remote pilots; or

(3) one that does not correspond to a PDRA, but falls within a type of activity already performed by the UAS operator.

In case of UAS operations that are conducted at SAIL V and VI, the competent authority requires the LUC holder to use a UAS with an EASA TC. In case of UAS operations that are conducted at SAIL III and IV, the competent authority specifies if the LUC holder is required to use a UAS with an EASA TC.


For the purpose of granting privileges to LUC applicants, the competent authority may apply a gradual approach. Depending on the UAS operator’s past safety performance and safety record over a defined period of time (e.g. the previous 6 months), the competent authority may expand the scope of the UAS operator’s privileges.

The gradual approach should not be understood as preventing the competent authority from granting privileges with a greater scope to a first-time LUC applicant who has an adequate structure and competent personnel, an effective safety management system and has demonstrated a good compliance disposition.

For operations that are conducted at SAIL III and IV, and to facilitate harmonisation among EASA Member States, EASA recommends that the competent authority always requires LUC holders to use a UAS with an EASA TC.

UAS.LUC.070 Changes in the LUC management system

Regulation (EU) 2020/639

After an LUC is issued, the following changes require prior approval by the competent authority:

(1) any change in the terms of approval of the UAS operator;

(2) any significant change to the elements of the LUC holder’s safety management system as required by point UAS.LUC.030.


A change of the accountable manager is considered a significant change that requires a prior approval.

UAS.LUC.075 Transferability of an LUC

Regulation (EU) 2020/639

Except for the change to the ownership of the organisation, approved by the competent authority in accordance with point UAS.LUC.070, an LUC is not transferable.

UAS.LUC.080 Duration and validity of an LUC

Regulation (EU) 2020/639

(1) An LUC shall be issued for an unlimited duration. It shall remain valid subject to:

(a) the LUC holder’s continuous compliance with the relevant requirements of this Regulation and of the Member State that issued the certificate; and

(b) it not being surrendered or revoked.

(2) Upon revocation or surrender of an LUC, the LUC holder shall provide an acknowledgment in digital format that must be returned to the competent authority without delay.

UAS.LUC.090 Access

Regulation (EU) 2020/639

For the purpose of demonstrating compliance with this Regulation, the LUC holder shall grant any person, that is duly authorised by the competent authority, an access to any facility, UAS, document, records, data, procedures or to any other material relevant to its activity, which is subject to certification, operational authorisation or operational declaration, regardless of whether or not its activity is contracted or subcontracted to another organisation.