3.1 RePL vs ReOC: Pilot Licence vs Operator Certificate

Pilot vs Operator: Two Different Credentials

Australian drone regulation distinguishes between who flies and who runs the operation. The Remote Pilot Licence (RePL) is a CASA-issued pilot licence held by an individual person — it attests that the holder has the aeronautical knowledge and competency to remotely pilot an RPA (Remotely Piloted Aircraft). The Remotely Piloted Aircraft Operator's Certificate (ReOC) is an organisational certificate held by a business or operator; it is the CASA authorisation that allows an organisation to conduct commercial RPA operations and to employ or engage RePL holders to fly for it.

The relationship is hierarchical: a RePL holder does not operate a commercial drone business on their own licence. For commercial work that falls outside the excluded categories, the pilot must fly under a ReOC. The ReOC holder is the legal operator of the flight, holds the approvals, carries the insurance, and is responsible for the conduct of the operation; the RePL holder is the pilot in command executing the flight under that operator's procedures.

Privileges of a RePL

A RePL allows the holder to act as a remote pilot for:

• Included RPA operations conducted under a ReOC (operations outside the excluded categories, where the operator holds the required approvals).
• Medium excluded landholder RPA (>25 kg to 150 kg) flown over land owned or leased by the RPA owner, provided the pilot holds a type or model rating for that RPA and no payment is received for the flight.
• Large RPA (>150 kg), which are always included operations and require both a RePL with an appropriate rating and a ReOC.

A RePL alone does not authorise night flying, BVLOS (Beyond Visual Line of Sight), flight above 120 m AGL, operations over populous areas, or flying more than one RPA at a time — each of these requires a CASA approval held by the ReOC and the pilot must be trained and assessed competent for that operation.

Solo Privileges, Currency and the ARN

A RePL is obtained through a CASA-approved training organisation and requires the applicant to hold an Aviation Reference Number (ARN) — the unique CASA identifier that follows a person across all their aviation credentials. Three things must be completed before the licence is issued: the provider theory component, the practical skills component for the category and type you will fly, and 5 hours of logged RPA flight time under the standard operating conditions. CASA publishes no question count or pass mark for the theory paper; providers set both, and 85% is the common industry convention. There is no minimum age for a RePL.

Once issued, a RePL holder may fly solo only within the scope the licence itself grants: medium excluded landholder RPA (with a type rating) and — if the holder also operates their own RPA over their own land unpaid within the small landholder rules — private landholder use. For any commercial work outside the excluded categories, the RePL holder must be employed or engaged by a ReOC holder. The ReOC holder is the employer/operator; the RePL holder is the pilot. A RePL does not let the holder set up a commercial drone business on their own — that requires a ReOC.

AC 101-01 states plainly that there are no CASA requirements for continuing flight proficiency or currency for RePL holders. That is not a licence to get rusty: the AC warns that a lack of proficiency or currency that contributes to an accident may later be assessed as hazardous operation under CASR 101.055. A ReOC's documented practices and procedures will normally impose their own recency, recurrent-training and competency-check requirements before a pilot is signed off for a particular operation. A RePL is not renewed on a fixed cycle, but it can be suspended or cancelled by CASA for breaches.

Your licence is also endorsed with what you may fly. For RPA below 25 kg, CASA endorses a generic grouping — for example multi-rotor, < 7 kg or aeroplane, < 25 kg. RPA above 25 kg are treated as individual qualifications and are listed on the licence by name and maximum take-off weight. Flying a different category or type requires RePL upgrade training with an approved training organisation.

When a RePL Is Required vs Not Required

A RePL is required whenever the operation is an included operation — that is, commercial work outside the four excluded categories — and for the medium excluded landholder category and all large RPA. A RePL is not required for:

• Micro RPA (≤250 g) — commercial operations permitted under the micro excluded category with accreditation.
• Very small (sub-2 kg) commercial RPA (>250 g–2 kg) — commercial work permitted under the very small excluded category with accreditation, flown under the standard operating conditions (SOC).
• Small landholder RPA (>2 kg–25 kg) — flown over land owned/leased by the RPA owner, with no payment or remuneration, for permitted purposes, with accreditation.

In these excluded cases the operator holds an RPA operator accreditation (free, online, valid 3 years) instead of a RePL or ReOC. Registration is a separate obligation and 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.

Comparison: RePL vs ReOC vs Accreditation

Holding a RePL or ReOC exempts the holder from the separate accreditation requirement — the accreditation is only for operators who do not hold either credential.

Practical Scenarios

• A sole trader charging a client for aerial photos with a 1.5 kg drone flies under the very small excluded category: no RePL, no ReOC, but accreditation and registration are required, and the flight must stay within the SOC.
• A RePL holder employed by a surveying company that holds a ReOC may fly a 7 kg multirotor over a client's property for paid work — an included operation under the ReOC.
• A RePL holder who wants to fly at night for paid work needs a ReOC that holds a CASA night-operations approval and must be trained and assessed competent for night operations.
• A sole RePL holder with no ReOC who is offered paid mapping work with a 7 kg drone over a client's farm must either decline, work under a ReOC-holding employer, or obtain their own ReOC — the RePL alone does not authorise the commercial operation.
• A 15-year-old can hold a RePL — CASA sets no minimum age for the licence — but cannot hold an RPA operator accreditation, for which the minimum age is 16 (CASR 101.374B(4)). A person under 16 without a RePL may only operate an RPA when supervised by an accredited person aged at least 18. Individual training providers may still impose their own enrolment age, and a person under 16 cannot register a drone in their own name.