Drone qualifications obtained in the UK will not always be valid in EU member countries.
Operators flying under certain criteria within the new Open Category will need to obtain an A2 CofC.
Meanwhile, the GVC - geared towards enterprise drone users flying in the new Specific Category - will be needed to apply for an Operational Authorisation, which will replace the PfCO.
One of the aims of the new drone laws is to harmonise operations across the Continent, but the UK’s pending withdrawal from the EU has changed the landscape.
However, permissions obtained in the UK will not always be valid in other EU member states.
UK Operators Flying In EU Member States
So, a UK operator who wants to fly in an EU member state or an EASA Associate Member State (Iceland, Liechtenstein, Norway and Switzerland), must comply with the requirements of the EU versions of the new drone laws.
What does this mean?
UK operators must register with the Member State they wish to fly in.
Open Category Flights
A2 Subcategory: You need to obtain a new A2 CofC in the EU Member State you wish to fly. Once you have this, the European version of the A2 CofC will be valid in all other EU Member States and EASA associate Member States. For example, if you complete an A2 CofC for operations in Germany, you can then use this for flights in France, Italy, Spain etc.
A1 and A3 Subcategories: You can fly without drone training, as is the case in the UK. Please note that flights using A1 Transitional aircraft in the A1 subcategory will require an A2 CofC, so follow the process outlined above.
Specific Category Operations
If you have completed the UK GVC and have an Operational Authorisation, your next steps depend on the specific aviation authority of the EU Member State you wish to operate in.
Some will recognise the UK GVC/Operational Authorisation. In this case, you will need to amend your Operations Manual to recognise your operation in the specific Member State, such as changing your PDRA to a Standard Scenario.
However, some aviation authorities will require you to complete a separate GVC and apply for a new Operational Authorisation for operations in that Member State.
To understand your position, check with the relevant aviation authority ahead of your operations. Access to the websites of individual EU Member States, including a link to their ‘drones’ webpages, can be obtained at EASA Light-MS.
UK Operators Flying In Non EU-Member States
UK UAS Operators wishing to operate within any State other than one which is a member of the EU or EASA Associate Member must comply with the requirements that are set out for UAS operations within that State.
In the first instance, operators should consult the guidance documentation that has been prepared by the relevant NAA.
Operators From EU Member States Flying In The UK
A 'third-country' UAS operator (whose principal place of business, establishment, or residence is outside of the UK), who wants to operate in the UK will need to register as a UK operator, abide by UK rules, and apply for UK authorisation.
For instance, a third-country operator wanting to use their A2 CofC to fly in the UK Open Category would need to obtain a UK-version of the A2 CofC.
However, a drone operator who has registered and obtained an A2 CofC and/or GVC in an EU member location, like Germany, can use the same certificate throughout other member states.
CE Drone Marking To Be Replaced By UK Marking
Under the new rules, a CE-class marking system will be introduced, based on drones meeting certain criteria to receive a certain class marking. These class markings will define how and where a drone can be flown in the Open Category.
Today, the CAA said that drones in the UK will receive a UK marking, instead of a CE class marking - but there will be no difference in the class criteria.
PfCO Holders To Receive Temporary Exemption
The CAA has also said that operators with a valid PfCO after December 31, 2020, will be issued with a temporary exemption to bridge the gap between that which is stated in their PfCO and the retained regulations.
This will also see a change to the Air Navigation Order contained within CAP 393 with the deletion of a number of articles applicable to Small Unmanned Aircraft (SUA) in lieu of their inclusion in the Implementing Regulation.
This will mean that they need to abide by the permission afforded by an Operational Authorisation, rather than their PfCO. This will enable PfCO holders to operate in accordance with UKPDRA01 in the Specific Category.