3.2 Excluded Categories and Operator Accreditation
Key Takeaways
- The excluded categories (CASR 101.237) allow certain low-risk commercial RPA operations without a RePL or ReOC.
- The four excluded categories are micro (≤250 g), very small (>250 g–2 kg) sub-2 kg commercial, small landholder (>2–25 kg over own land, no payment), and medium landholder (>25–150 kg over own land, which requires a RePL with a type rating).
- An RPA operator accreditation is free, completed online, valid for 3 years, requires the operator to be 16 or older, and needs an 85% quiz pass rate.
- Accreditation is not required if the operator already holds a RePL or a ReOC.
- Registration is driven by purpose, not weight: any drone flown for business or as part of your job must be registered, including a micro RPA of 250 g or less.
What the Excluded Categories Are
CASA divides commercial RPA work into three operation types: micro RPA operations, excluded RPA operations, and included RPA operations. Micro and excluded operations sit outside the full RePL/ReOC framework because they are assessed as low-risk; instead the operator completes a free RPA operator accreditation and registers the drone.
Under CASR 101.237, an excluded RPA operation is one flown in compliance with the standard operating conditions that is also one of: an RPA of not more than 2 kg; an RPA of not more than 150 kg flown over land owned or leased by the RPA owner; or an RPA of not more than 150 kg flown solely for training or experience. In practice that produces the following working categories:
(a) Micro RPA — ≤250 g (a standalone class, strictly speaking)
Commercial operations are permitted with accreditation and registration, flown within the SOC. AC 101-01 treats micro as its own operation type rather than a subset of "excluded", and notes that micro RPA cannot presently be operated under a ReOC. A micro operator may still apply to CASA for a flight authorisation such as BVLOS. Micro RPA also get one useful concession the heavier categories do not: they may be flown within 5.5 km of the measurement point of an aerodrome runway up to 45 m height, provided they stay clear of the movement area, the approach and departure paths, the aerodrome boundary at a controlled aerodrome, and create no collision hazard.
(b) Very small RPA — >250 g to 2 kg ("sub-2 kg commercial")
Commercial operations are permitted, flown under the SOC and in accordance with Subpart 101.G of CASR. The operator needs accreditation and, because the flight is for business, the drone must be registered. This is the most common entry point for paid drone work such as real-estate photography and small inspections.
(c) Small landholder RPA — >2 kg to 25 kg
Commercial-style use is permitted only over land owned or leased by the RPA owner, with no direct reward or compensation to the remote pilot, the RPA owner, or the landholder, and only for the purposes listed in CASR 101.237: aerial spotting, aerial photography, agricultural operations (weed and pest spraying, fertiliser application, seed broadcasting and similar), aerial communications re-transmission, carriage of cargo, and any similar activity. The remote pilot must be the RPA owner or a person flying on the owner's behalf. The operator needs accreditation and the drone must be registered when flown for business. A farmer flying their own drone over their own property fits here; paid work over a client's land does not.
(d) Medium landholder RPA — >25 kg to 150 kg
The same landholder restrictions apply (own/leased land, no reward, permitted purposes), plus the pilot must hold a RePL for the intended type and model of RPA. This is the only excluded category that still requires a RePL — the larger mass is high enough risk that a licensed pilot is required even though no ReOC is needed. The drone must be registered when flown for business.
(e) Training and experience-building RPA — up to 150 kg
The category candidates most often forget. A small RPA (>2 kg to 25 kg) may be flown under the excluded category solely to gain the experience needed to meet the 5-hour minimum for an initial RePL, or to gain practical competency on an RPA type not yet on the pilot's licence. No ReOC and no RePL are required. Experience-building on medium RPA is handled differently: CASA has issued an exemption (CASA EX91/23) that permits it without a ReOC or licence coverage, but flights under that exemption are not excluded-category operations, although the SOC still apply. Pilots building medium-RPA time must read the conditions of the exemption.
Operator Accreditation
An RPA operator accreditation is the lightweight credential that replaces a RePL/ReOC for excluded-category commercial operations. Its key features are:
- Free — completed online through the myCASA portal (CASR Subpart 101.FA).
- Valid for 3 years — must be renewed before expiry.
- Age 16 or older to obtain (CASR 101.374B(4)). A person under 16 may operate an RPA only when supervised by an accredited person aged at least 18.
- Requires you to view a short safety video, read the educational material, and pass an online quiz on the standard RPA operating conditions and drone safety rules. CASA does not publish a pass mark for that quiz — treat any specific percentage you see quoted as unverified.
- Proof on demand — if CASA or police ask, you must produce electronic or printed proof of accreditation or your RePL (CASR 101.374C).
- Not required if the operator holds a RePL or a ReOC — those credentials already demonstrate a higher level of competency.
Accreditation is tied to the individual operator, but an organisation conducting excluded-category work must ensure each pilot operating for it is accredited (or holds a RePL).
The Accreditation Process in Practice
The accreditation is completed through the myCASA online portal: the applicant watches a short safety video, reads the educational material, and sits an online quiz on the standard operating conditions and drone safety rules. There is no practical flight test — it is a knowledge-only credential, which is why it is free and quick compared with a RePL. Once issued, accreditation is valid for 3 years and is renewed by re-completing the online course before expiry.
The minimum age is 16. A person under 16 cannot obtain accreditation and so cannot independently conduct a commercial excluded-category operation, even with a micro drone; they may fly only under the supervision of an accredited person aged 18 or over. The accredited operator remains the legal operator of the flight and is responsible for staying within the SOC.
Registration Coupling
Drone registration is separate from accreditation, and it lives in a different part of the rules — CASR Part 47 (47.C.2), not Part 101. The test is purpose, not weight:
- You must register any drone flown for business or as part of your job, no matter how much it weighs — including a micro RPA of 250 g or less, and including a drone flown only indoors.
- You do not need to register a drone flown purely for sport or recreation, including micro drones under 250 g and model aircraft flown at CASA-approved model airfields.
- Registration is valid for 12 months and you must be at least 16 to register a drone.
- A registration levy may apply to drones used for business, scaled by weight.
- If CASA or police ask, you must produce proof of registration, electronic or printed (CASR 47.099B). Flying an unregistered drone for business attracts a penalty of up to $18,200.
The common exam trap is the sentence "only drones over 250 g need to be registered." That is the recreational framing and it is wrong for commercial work: a 200 g micro drone used for a paid real-estate shoot must be registered.
Category Quick-Reference Table
| Category | Weight range | Commercial OK? | RePL required? | ReOC required? | Accreditation required? | Register for business use? |
|---|---|---|---|---|---|---|
| Micro | ≤250 g | Yes | No | No | Yes (unless RePL/ReOC held) | Yes |
| Very small (sub-2 kg) | >250 g–2 kg | Yes (under SOC) | No | No | Yes (unless RePL/ReOC held) | Yes |
| Small landholder | >2 kg–25 kg | No reward; over own land | No | No | Yes (unless RePL/ReOC held) | Yes |
| Training/experience | >2 kg–25 kg | Not for hire; experience only | No | No | Yes (unless RePL/ReOC held) | Yes |
| Medium landholder | >25 kg–150 kg | No reward; over own land | Yes (type and model) | No | Not if RePL held | Yes |
| Included (any weight) | Any | Yes | Yes | Yes | No (RePL/ReOC covers it) | Yes |
Worked Scenarios
Scenario A: Real-estate photos with a 900 g drone
A photographer charges a client for stills using a 900 g drone. It falls in the very small excluded category (>250 g–2 kg). The photographer needs accreditation and registration (the flight is for business), and must fly within the SOC — no RePL, no ReOC. Night flight, BVLOS or flight above 120 m is not available at all in the excluded category, because excluded operations cannot be approved beyond the SOC.
Scenario B: Farmer's 40 kg drone over leased land, unpaid
A farmer flies their own 40 kg drone over land they lease to spot pests, receiving no payment. The drone is medium (>25–150 kg), so the medium landholder excluded category applies — but it requires a RePL with a type or model rating for that RPA, plus registration. No ReOC is needed for the unpaid landholder use; the moment the farmer charges a neighbour to fly over the neighbour's land, the landholder exclusion falls away and a ReOC is required.
Common Pitfalls
- Paid work over someone else's land with a >2 kg drone is not a small landholder operation — the landholder exclusion requires the RPA owner to own or lease the land; paid work over a client's farm with a 7 kg drone is an included operation needing a RePL under a ReOC.
- The medium landholder category still needs a RePL — the >25 kg landholder case is the only excluded category requiring a licence.
- Micro does not mean unregulated — micro operators still need accreditation (or a RePL/ReOC) and must fly within the SOC.
- Registration is purpose-based, not weight-based — a 1.5 kg drone flown for a paid job must be registered, and so must a 200 g micro drone flown for the same job. A 1.5 kg drone flown only for fun does not need registration.
- Sub-2 kg commercial still needs accreditation, registration, and the SOC — the excluded category removes the RePL/ReOC requirement but not the SOC limits, so night, BVLOS, or >120 m flight is not available without a ReOC.
A farmer wants to fly their own 18 kg drone over their own leased property to spot cattle, receiving no payment. What does the farmer legally need?
Which of the following is true about RPA operator accreditation?
A drone operator holds a valid RePL and wants to fly a 35 kg drone over their own leased land for unpaid agricultural spotting. What additional requirement applies under the medium landholder excluded category?