Specific category

A drone can be operated in the ‘in the ‘specific’ or the ‘certified’ category, when it does not meet the requirements laid out under the open category. See FAQ - How do I determine I fall under the ‘open’ category?

Regulatory reference: Article 4 and Article 20 of EU Regulation 2019/947; Annex part A and Article 5(1) of EU Regulation 2019/947, Parts 1 to 5 Annex of EU Regulation 2019/945.
 

For operation falling under the ‘specific’ category, the training depends on the operation you intend to conduct. So unless the operation falls into a standard scenario, after the risk assessment, you will need to propose a possible training course to the National Aviation Authority. The authority will, in each case, evaluate the adequacy of the training, and if they confirm it in the operational authorisation, the training will become the required training. 

If your operation falls into a standard scenario, the remote pilot must:

• hold a certificate of remote pilot theoretical knowledge for operation under standard scenarios;
• hold an accreditation of completion of the STS-01 practical skill training.

To do so, the remote pilot must complete and successfully pass an online training course.

Both the certificate and accreditation can be issued by a competent authority or an entity chosen to do so.

Regulatory reference: UAS.SPEC.050 (d) and UAS.SPEC.060 (b) of EU Regulation 2019/947
 

For standard scenarios, the National Aviation Authority is responsible for issuing the certificates. A certificate for Remote Pilot competency is valid for 5 years. If the revalidation is conducted before the certificate expires, the remote pilot may attend a seminar provided by the National Aviation Authority or by an entity recognised by it, otherwise competencies need to be re-demonstrated.

For operations in the ‘specific’ category that are not covered by standard scenarios, the training will be defined in the operational authorisation provided by the National Aviation Authority. 

Regulatory reference: Article 12 of EU Regulation 2019/947 and UAS.STS-01.020

Contact your National Aviation Authority for further information

(see https://www.easa.europa.eu/domains/civil-drones/naa).
 

Yes, training conducted in one EASA Member State will be recognised in all others. 

When operating under the ‘specific’ category, if the operations can be conducted within the limitation of a standard scenario and using an appropriate drone, the drone operator only needs to submit a declaration to the National Aviation Authority and wait for the confirmation of receipt and completeness. For all other operations in the ’specific’ category, an operational authorisation issued by the National Aviation Authority is needed.

Firstly check whether your operation can be accommodated within a standard scenario. If it can, you do not need an authorisation, but you do need to submit a declaration to the National Aviation Authority. A standard scenario is an operation defined in the Appendix to the drone regulation (EU Regulation 2019/947). You need to use a drone marked with the appropriate class identification label (5 or 6). After submitting the declaration to the National Aviation Authority, you will receive the confirmation of receipt and completeness from the National Aviation Authority and operate following the limitations of the standard scenario.
Otherwise, there are other means to obtain an operational authorisation under the ‘specific’ category, depending on the level of risk the operation poses. The drone operator can apply for:

1. An operational authorisation by conducting a risk assessment of the intended operation using a methodology for the risk assessment; one possible method is the SORA (specific operation risk assessment) that you can find as AMC1 to Article 11 to Regulation (EU) 2019/947. This methodology helps to identify the risk level of the operation and to identify the mitigations and operational safety objectives needed to make the operation safe. When the drone operator believes they have put in place satisfactory measures to ensure the safety of the operation, they send all the information to the National Aviation Authority and apply for an operational authorisation. When the National Aviation Authority is satisfied, it provides the drone operator with the authorisation, and the operation can be started.  
    
2. An operation authorisation through a predefined risk assessment’ (PDRA) as a simplification of the drone operator conducting a risk assessment. For those operations that will be the most common in Europe, EASA will carry out the risk assessment and will publish, as an acceptable means of compliance with the drone regulation, the list of the actions that the drone operator needs to put in place in order to conduct the operation safely. An application for an authorisation to the National Aviation Authority is still needed, however, both the drone operator and the National Aviation Authority will benefit from the standardised measures defined in the PDRA. The PDRAs are published by EASA as AMC to Art 11 to Regulation (EU) 2019/947; more are already under development.
    

3. Light UAS operator certificate (LUC): this is a voluntary certification, after which the National Aviation Authority may allocate some privileges to the drone operator.

   Drone operators may ask the National Aviation Authority to assess their organisation to evaluate whether they are capable of assessing the risk of an operation themselves. The requirements to be demonstrated by drone operators are defined in Part C of Regulation (EU) 2019/947. When the National Aviation Authority is satisfied, they will issue a light UAS operator certificate (LUC) and they will allocate privileges to the drone operators based on their level of maturity. The privileges may be one or more of the following:

• To conduct operations covered by standard scenarios without submitting a declaration; 
• To self-authorise operations conducted by the drone operator and covered by a PDRA without applying for an authorisation.
• To self-authorise all operations conducted by the drone operator without applying for an authorisation.
   

Regulatory reference: article 12 of EU regulation 2012/947.

As a drone operator flying in the ’specific’ category, you must:

• ensure that the drone displays the drone operator registration number (e.g. with a sticker) and the same number is uploaded into the remote identification;
• develop operational procedures (written procedures are required when the drone operator employs more than one remote pilot, otherwise it is enough that the remote pilot follows the procedures defined by the manufacturer in the user’s manual); 
• ensure that there is no radio interference that may affect the command and control link of the drone;
• designate a remote pilot for each operation; it is important that it is clear who is the person responsible for each flight;
• ensure that the remote pilot and the personnel supporting the operation of the drone are familiar with the user’s manual and with the drone operator’s procedures, have appropriate competency, and are provided with the relevant information concerning any geographical zones published by the MS;
• ensure that the maps in the geo-awareness system of the drone are up to date, unless you are flying in a geographical zone where geo-awareness is not required; 
• ensure that, unless you are using a privately built drone, it has a declaration in conformity to the CE class mark and its class label (0 to 4) is affixed to the aircraft; and
• ensure that the persons involved in the operation of the drone is aware of the risks involved in operations under subcategories A2 and A3.
• carry out each operation within the limitations defined in the declaration or operational authorisation;
• develop procedures to ensure the security of the operation;
• establish measures against unlawful interference and unauthorised access;
• ensure that the privacy of people is protected, and there may also be a requirement to conduct a data protection impact assessment if requested by the National Aviation Authority;
• provide the remote pilot with guidelines on how to minimise the nuisance caused by noise and emissions;
• ensure that the pilot conducting the operation and the other personnel in charge comply with all the conditions required for operating in the ’specific’ category;
• keep a record of the drone operation; and
• maintain the drone in a suitable condition to ensure safe operation.

Regulatory reference: UAS.SPEC.050 of EU Regulation 2019/947
 

As a remote pilot you must: 
Before the flight:

• complete the training and examination required for the type of operation you will be involved in;
• have relevant up-to-date information about any geographical zones published by the National Aviation Authority;
• check for obstacles and the presence of people not involved in the operation of the drone (unless operating in the A1 subcategory with a privately built drone or a drone with a CE class 0 mark;
• check that the drone is fit for flight and the operation it will undertake;
• check that the remote control works properly (if applicable); and
• ensure that the weight of the drone is within the limit of the category or subcategory of the intended operation.
• ensure that the operating environment is compatible with the authorised or declared limitations, and
• ensure that Air Traffic Services , airspace users and other stakeholders are informed of the intended operation. 
• During the flight in the ’specific’ category, you must:
• not operate the drone when you are unfit either due to the consumption of psychoactive/ hallucinogenic substances or alcohol, or unfit due to sickness;
• keep the drone at a distance such that you can clearly see it; you may use a UA observer to scan the airspace when you want to fly in first person view. UA observers must be located alongside you such that they can immediately communicate in case they see an obstacle and give you instructions such as to immediately land the drone.
• if you or the UA observer see a manned aircraft, give way to it, and make sure you are far away from it. If you have any doubt about the operation, you should land the drone immediately. 
• comply with the limitation of the geographical zones;
• operate the drone according to the manufacturer’s user manual;
• comply with the operator’s procedure; and
• do not operate where an emergency response service is ongoing (e.g. in the case of an accident, keep away from that location since an emergency helicopter may be required to be used);
• Comply with the authorised or declared limitations.

 
Regulatory reference: UAS.SPEC.060 of EU Regulation 2019/947
 

The operator is responsible for obtaining a reasonable confidence that the drone he/she is acquiring complies with requirements applicable to its C class 1 - 6 (ref: Annex of Delegated Regulation (EU) 2019/945).

In particular, the operator needs to ensure that:

• buying directly from outside the EU should be avoided as the UAS may not be intended for the EU market and may not comply with EU legislation.
• the drone bears the appropriate class label from 1 to 6 and it comes with a declaration of conformity showing compliance with the Drone Regulation (EU) 2019/945.
• when buying a second hand UAS, obtain reasonable confidence that the UAS has not been damaged or modified in a way that affect its initial compliance with the Drone Regulation (EU) 2019/945.
• the initial compliance of the UAS to the requirements of its C Class is maintained throughout its lifetime, in particular that the UAS is not damaged or modified in a way that could affect it.

Drones in the ’specific’ category do not need a class identification label (except if operating in a standard scenario).

Any certificates of remote pilots’ competency issued by national authorities will remain valid until 1 January 2022, after which your National Aviation Authority will have to convert your national certificate(s) to new one(s) that comply with this Regulation. 

Whether or not you have to undergo more training after that date will depend on the conversion process that your National Aviation Authority decides to put in place.

As of 31 December 2020, if you do not have a national certificate for your remote pilot competency, you will have to undergo the required competency training as required for the ‘open’ category. 

Regulatory reference: Article 21 and Annex part A (UAS.OPEN.020) and (UAS.OPEN.040) of EU Regulation 2019/947. 
 

Normally drone races are organised by clubs and associations. In such cases, they may have received operational authorisations from their National Aviation Authorities in accordance with Article 16 of Regulation (EU) 2019/947, which also covers the organisation of such events.

If there are spectators, the operation falls into the ‘specific’ category, and you need to apply for an authorisation from the National Aviation Authority
 

The Regulation allows you to fly without keeping direct eye contact with the drone, provided you have a person next to you, a UA observer, keeping direct visual contact with the drone, scanning the airspace to make sure that you do not endanger other parties (e.g. aircraft or buildings or persons). The UA observer must be located alongside you so they can immediately communicate with you in case they see an obstacle, and give you instructions, such as to immediately land the drone.

Regulatory reference: Article 4(d) of EU Regulation 2019/947
 

If the event is organised by a club or association that received an authorisation from the National Aviation Authority, or the organiser received an operational authorisation for an operation in the ’specific’ category, then spectators are allowed.

NB This answer applies only to non-racing FPV operation.

One of the conditions to operate in the open category is for the remote pilot to keep the drone in visual line of sight (VLOS) at all times. There are only two exceptions where VLOS is not strictly applied:

• when using the follow-me mode with a drone with C0 or C1 label or below 250 g; and/or
• when operating in first person view (FPV) and using an unmanned-aircraft observer that is always looking at the drone.

It is important to note that the open category catalogues all lower-risk drone operations without the need for prior authorisation; this lighter provision is compensated by more restrictive conditions of operation.

FPV googles by nature do not allow to have a wide field of view to see potential threats around the drone, so they do not enable VLOS.  Hence, the requirement for an unmanned-aircraft observer for any FPV operation when operating in the open category. The unmanned-aircraft observer must look at the drone and be alongside the remote pilot so that the unmanned-aircraft observer can immediately inform the remote pilot in case of any threat around the drone.

With the above conditions, you are allowed to fly FPV in the open category. However, you need to be mindful of the risk to hit a person or other aircraft.

If you want to have a drone race in FPV, spectators are not allowed; please note that drones with a speed higher than 19 m/s are only allowed to operate in open subcategory A3 (far from people). Therefore, in case you want to have spectators, the FPV race should be conducted in the specific category (including standards scenarios). For more information, please refer to the following FAQ: I am into drone racing and/or flying drones with goggles (FPV) ‘open’ category | EASA (europa.eu).

For standard scenario (STS) 2, nothing prevents the remote pilot to fly in first person view when:

• an airspace observer scans the sky; and
• the remote pilots is assisted by an unmanned-aircraft observer.

The same person may be the airspace observer and the unmanned-aircraft observer, if that person complies with the requirements imposed for the two observers.

For STS 1, it is correct that at the moment, operating in FPV is not possible since the remote pilot is required to maintain VLOS.

Privately built drones of any weight can be operated in the ’specific’ category, if included in the operational authorisation issued by the National Aviation Authority.

By 31 December 2020, any authorisation given by one MS will be valid in the rest of Europe. The drone operator is required to first submit the declaration (if intending to conduct an operation covered by a standard scenario) or receive an operational authorisation from the National Aviation Authority of the state of registration. 

For an operation covered by a standard scenario (SS), the drone operator must send to the National Aviation Authority where it intends to operate, a copy of the declaration and a copy of the confirmation of receipt and completeness received by the National Aviation Authority of the state of registration. Then the drone operator may start the operation following the requirement of the standard scenario and verifying the geographical zone published by the National Aviation Authority where the operation is conducted.

For operations not covered by a standard scenario in the ’specific’ category, the drone operator must ensure that the mitigating measures submitted in his original risk assessment are appropriate to the new environment it plan to operate in or update them is necessary. 

Then the drone operator must provide the National Aviation Authority of the Member State of the intended operation with an application, which must include:    

(a) a copy of the operational authorisation granted by the National Aviation Authority of the Member State of registration; with

(b) the location (s) of the intended operation, including the updated mitigation measures.

Upon receipt of the application, the National Aviation Authority of the Member State of the intended operation will review the updated mitigation measure proposed. They will confirm to the drone operator that the application is satisfactory. Once the operator receives the confirmation, they may start the intended operation. 
If the drone operator has been granted, by the National Aviation Authority of the state of registration, an LUC (a light UAS operator certificate) with privileges to self-authorise its operations, they must provide the National Aviation Authority of the State of the intended operation with

• a copy of the term of approval of the LUC and
• the location or locations of the intended operation;

Regulatory reference: article 13 of EU regulation 2019/947.
 

After 31 December 2020, all existing approvals/certificates/authorisations/declarations issued by National Aviation Authorities will still be valid until 1 January 2022. 

After 1 January 2022, all approvals, certificates, authorisation and declarations must be converted to the EU Regulation. New applications for authorisations/certificate submitted after 1 January 2022 need to follow the new EU Regulation.

All drone operations conducted in the EASA Member States must comply with the Drone Regulation, no matter what the nationality of the operator or remote pilot is. Therefore, as a non-EU resident, you are also required to register with the National Aviation Authority of the first EU country where you intend to operate.

You will then be issued with a ‘drone operator registration number’ that needs to be displayed with a sticker on all the drones you own. You must also upload it into the ‘remote identification system’ of your drone(s). 

Once registered in the host country, the drone operator’s registration will be valid across Europe and the operator will be required to follow all the provisions of the Drone Regulation.

If you intend to operate in the ’specific’ category, you must submit a declaration for a standard scenario or apply for an operational authorisation to the National Aviation Authority of the EU Member State(s) where you registered. 

If you want to conduct operations in a Member State different from the one in which you registered, you need to follow the same procedure as all other national citizens of the Member State where you registered. 

Regulatory reference: Art.41 (1) and (2) of EU Regulation 2019/945
 

Given that there is not yet any mutual recognition established between EASA and other countries, in the domain of drones, the training or qualification obtained in your country of residence will not be accepted in the EU. Therefore, you will have to undergo the required training before you can fly your drone. In the meantime, other nations may develop regulations that may be considered by the EU commission as equivalent to those in Europe. Information on future recognition will be published on the EU Commission website as soon as it is finalised.

A light UAS operator certificate (LUC) is an organisational approval certificate. Drone operators may ask the National Aviation Authority of registration to have their organisation assessed to demonstrate that they are capable of assessing the risk of an operation themselves. The requirements to be demonstrated by drone operators are defined in Part C of Regulation (EU) 2019/947. When the National Aviation Authority is satisfied, they will issue a light UAS operator certificate (LUC) and they will assign privileges to the drone operators based on their level of maturity. The privileges may allow the organisation to self-authorise operations without applying for an authorisation.

The privileges may be one or more of the following:

• Conduct operations covered by standard scenarios without submitting the declaration; 
• self-authorise operations conducted by the drone operator and covered by a PDRA without applying for an authorisation;
• self-authorise all operations conducted by the drone operator without applying for an authorisation.
   

You need to be an organisation to be eligible to apply for a LUC, however you can subcontract some of the activities.

Regulatory reference: UAS.LUC.010.

It depends on the privileges granted by the National Aviation Authority.

Regulatory reference: Article 5 of EU Regulation 2019/947.
 

The validity of a LUC is unlimited as long as the organisation remains compliant with the LUC’s requirements. An LUC can be revoked or surrendered.

Regulatory reference: UASE.LUC.080 of EU regulation 2019/947.

When you intend to conduct an operation in the specific category, in a state other than the one you are registered, firstly you need to get an operational authorisation from the competent authority of the state you are registered. This competent authority will evaluate your risk assessment identifying if the mitigation means you propose and the safety objectives are adequate to conduct such type of operation. 

Then you need to apply to the competent authority of the state of operation for a confirmation of a cross border operation, providing them evidences on how you apply the mitigations means to the location and in case how you comply with the local conditions.

Regulatory reference Article 13 of EU Regulation 2019/947

The authorisation process requires that the authority agrees with the proposal of the operator ensuring the safety of the operation. The level of verification from the authority depends on the level of risk of the operation and on the level of trust on the maturity of the operator. Therefore applying always to the same authority allows to build this trust. Moreover all authorities needs to conduct periodical oversight audits to all operators they issued an operational authorisation or a LUC or received a declaration, being responsible of their national operators is more convenient for both authorities and operators.

Regulatory reference Article 18(h) of EU Regulation 2019/947