2.1 Safety Assurance Declarations (Standard 922)

2.1 Safety Assurance Declarations (Standard 922)

Quick Answer: Under CAR 901.69, most advanced RPAS privileges require a Safety Assurance Declaration (SAD)—or, for higher-risk medium operations, a Pre-Validated Declaration (PVD)—that the specific model meets the applicable section(s) of Standard 922. Controlled airspace, near people, over people, medium VLOS, and sheltered-in-controlled-airspace privileges each map to different 922 sections. Confirm the model on Transport Canada's declared-drone list for the exact operation before you fly.

Holding a Pilot Certificate – Advanced Operations is necessary but not sufficient. Transport Canada separates pilot qualifications from aircraft qualifications. The pilot must be certified and current; the Remotely Piloted Aircraft System (RPAS) must be declared as meeting the technical safety requirements for the intended advanced operation. That aircraft-side gate is the Safety Assurance Declaration framework in CAR 901.69 and Standard 922—RPAS Safety Assurance.

Why declarations exist

Advanced operations increase risk to people on the ground and to manned aircraft. A small multirotor flown within a few metres of bystanders needs different failure protections than the same airframe flown only in open Class G airspace more than 30 m from people. Medium RPAS (more than 25 kg up to 150 kg) store far more kinetic energy; a single system failure near people can reasonably be assumed to cause serious injury or death. Standard 922 therefore sets performance-based technical requirements—position accuracy, containment, injury protection, reliability, command-and-control behaviour, and related design qualities—that manufacturers (or other declaring entities) must demonstrate before pilots may use that model for the listed advanced privileges.

CAR 901.69: declaration for permitted advanced operations

CAR 901.69 is the operational "permission table." To conduct a listed advanced operation, a declaration (and, where required, an acceptance letter / pre-validation) must have been made in accordance with CAR 901.194 for that model of RPAS against each technical requirement in Standard 922 that applies to the operation. If no declaration covers the model and the intended privilege, you cannot lawfully conduct that advanced operation with that aircraft—even if you hold Advanced pilot privileges.

Think of 901.69 as a matrix: size of RPAS × type of operation → Standard 922 section(s) → type of declaration. The official Advanced operations page (date modified 2026-03-19) and Standard 922 Table 1 align on the same mapping.

Small RPAS (250 g to 25 kg) — ordinary Safety Assurance Declarations

922.04 (controlled airspace) focuses on the pilot's ability to report position with confidence. The RPAS must indicate lateral position to at least ±10 m and altitude to at least ±16 m while operating in controlled airspace. Controllers and other airspace users need a minimum confidence in those reports when deconflicting traffic.

922.05 (near people) and 922.06 (over people) escalate ground-risk protections as horizontal standoff shrinks. Over-people is the stricter of the two small-drone standards. A model declared only for 922.05 may operate near people in the 5–30 m band but is not automatically cleared for over-people flight inside 5 m.

Medium RPAS (more than 25 kg to 150 kg) — declarations and pre-validation

Pre-Validated Declaration (PVD) is the higher-assurance path. For medium VLOS near and over people, Transport Canada pre-validates the safety case before the declaration is accepted for operational use. Standard 922.07 (safety and reliability) drives a formal system safety assessment: how subsystems fail, how failures interact, and whether severe injury to uninvolved persons remains extremely remote. Do not confuse a simple manufacturer self-declaration under 922.04/922.05/922.06/922.08 with a PVD under 922.07.

Who declares, and what pilots must verify

Declaring entities are typically the designer/manufacturer of the RPAS or configurable element, or a party that builds or modifies a system and can substantiate compliance. Pilots do not "self-declare" a consumer drone into advanced category by filling a form on exam day. Instead, pilots:

1. Identify the exact advanced privilege they need (controlled airspace, near people, over people, medium away/near/over, sheltered in controlled airspace, and so on).
2. Confirm the manufacturer model has a published declaration covering the matching Standard 922 section(s).
3. Operate within the declared limits of that model and configuration—payloads, software versions, and modifications matter. Modifying an RPAS can void the declaration pathway (see the later chapter on declarations and modifications / CAR 901.70 themes).

Transport Canada publishes a list of drones with safety assurance declarations on the "Choosing the right drone for advanced and complex operations" page. That list is the operational checklist: if your model/version is not shown as declared for the Standard you need, choose a different aircraft or stay within privileges that do not require that declaration.

Matching the drone to the operation (exam and real-world trap)

Meeting one Standard 922 section does not unlock all advanced operations. Common traps:

• A small drone declared for 922.04 (controlled airspace accuracy) is not automatically declared for 922.06 (over people).
• A small drone declared for 922.05 (near people) still needs 922.06 before you may operate within 5 m / over people.
• Medium away from people (922.08) is a different path from medium near/over people (922.07 PVD).
• Medium in controlled airspace requires both 922.04 and 922.08 (1, 2) under 901.69(h), plus ATC authorization—declaration alone is never a clearance.

Penalties for flying without the required declaration

Transport Canada's Advanced operations page lists explicit administrative monetary penalties for flying without the required drone safety assurance declaration:

• Individuals: up to $1,000
• Corporations: up to $5,000

Those amounts sit alongside other listed fines (for example, flying without a pilot certificate, flying where not allowed, or flying unregistered/unmarked drones). Breaking more than one rule can produce multiple penalties. From an exam perspective, remember the declaration-specific pair: $1,000 individual / $5,000 corporation—do not mix it up with the higher fines for unregistered aircraft or putting people and aircraft at risk.

Study workflow for Standard 922 questions

When a scenario names an operation, reverse-map it:

1. Size? Small (250 g–25 kg) or medium (more than 25 kg–150 kg).
2. Proximity / airspace? Controlled airspace, away/near/over people, or sheltered.
3. Standard number? 922.04 / .05 / .06 / .07 / .08 as above.
4. Declaration type? Ordinary declaration vs Pre-Validated Declaration.
5. Pilot + ATC extras? Advanced certificate always for advanced privileges; ATC authorization for controlled airspace; Level 1 Complex is a different certificate for lower-risk BVLOS—not a substitute for Standard 922 advanced VLOS declarations.

Master that five-step map and most declaration items on the Advanced written exam become table lookups rather than guesswork.