2.3 RPA Registration, Marking & Record Keeping

2.3 RPA Registration, Marking & Record Keeping

Exam Focus: Every drone from 250 g up to 25 kg must be registered before its first flight. Memorize owner eligibility criteria (age 14+, Canadian citizen/PR/Canadian corporation/government), the marking standard (C- plus ten digits, clearly visible on the aircraft), certificate carriage rules, and the two different retention periods in CAR 901.48(2): 12 months for flight and crew records, 24 months for maintenance records.

Mandatory Aircraft Registration (CAR 900.13)

Under CAR 900.13(1), no person shall operate an RPAS that includes a remotely piloted aircraft having an operating weight of 250 g (0.55 pounds) or more unless that aircraft is registered in accordance with Division III of Part 900. Registration is mandatory before the aircraft's first take-off in Canadian airspace. CAR 900.13(2) is the only carve-out: an unregistered RPA may be flown under a special flight operations certificate — RPAS issued under CAR 903.01.

Key statutory provisions governing registration include:

• Scope: Applies to every RPA with an operating weight of 250 g or more — small (250 g to 25 kg) and medium (over 25 kg to 150 kg) alike. Sub-250 g microdrones need not be registered or marked, but they remain subject to CAR 900.06.
• Registration Portal: Conducted online through Transport Canada's Drone Management Portal.
• Statutory Fee: CA$10 per aircraft (paragraph 3(d) of Schedule II to Subpart 4 of Part I of the CARs, as amended by SOR/2025-70). This charge is indexed to the Consumer Price Index and adjusted each April 1 under CAR 104.06.1, so confirm the amount in the Drone Management Portal before you pay.
• Non-Transferable Airframe Identity: Each registration number is tied to a specific manufacturer serial number. If an aircraft is replaced, the registration number cannot be moved to the new airframe; the replacement aircraft must be registered separately.

Eligibility Criteria for Registered Owners (CAR 900.15)

Under CAR 900.15, an applicant must meet strict statutory criteria to register an RPA in Canada:

1. Age Requirement: The owner must be at least 14 years of age. If a minor under 14 owns an RPA, a qualified parent or guardian must register as the legal owner.
2. Citizenship and Residency Status: The registered owner must be:
   • A Canadian citizen;
   • A permanent resident of Canada under subsection 2(1) of the Immigration and Refugee Protection Act; or
   • A corporation incorporated under Canadian federal, provincial, or territorial laws.
3. Foreign Operators: Non-Canadian citizens and foreign businesses without permanent resident status cannot register an RPA in Canada. Foreign tourists and commercial pilots must obtain a Special Flight Operations Certificate (SFOC-RPAS) under CAR 903.01 before operating any RPA weighing 250 g or more.

Aircraft Marking Standards (CAR 900.14)

Under CAR 900.14, no person shall operate an RPA unless the registration number issued by Transport Canada is marked on the aircraft.

Statutory marking standards require:

• Format: Prefix C- followed by ten digits (Transport Canada's own worked example is C-1827459426).
• Visibility: CAR 900.14 states the test in one line — the registration number must be clearly visible on the remotely piloted aircraft. Use high-contrast lettering on a flat, uncluttered surface.
• Accepted Methods: Transport Canada's registration guidance accepts a permanent marker, a permanent label, or engraving. Anything that rubs off in flight or in the field fails the "clearly visible" test.
• Practical Placement: Put the number on an exterior surface that stays readable with the battery installed and the arms unfolded. If the number wears away, Transport Canada expects you to restore it (rewrite it or make a new label) before the next flight.

Certificate of Registration & Ownership Transfer (CAR 900.16 - 900.20)

Upon registration, Transport Canada issues a digital Certificate of Registration (CAR 900.16).

• Carriage Requirement (CAR 900.20): The pilot must ensure the Certificate of Registration (electronic or printed) is readily accessible during all flight operations.
• Transfer of Ownership (CAR 900.18(1)(e) and (2)): When the registered owner transfers legal custody and control of the aircraft, the owner must notify the Minister within seven days of becoming aware of the transfer, and the certificate of registration is cancelled. The buyer cannot fly under the seller's registration; they must register the RPA in their own name and receive a new certificate before take-off.
• Other Cancellation Triggers (CAR 900.18(1) and (3)): The certificate is also cancelled when the aircraft is destroyed, permanently withdrawn from use, missing with the search terminated, or missing for 60 days or more — and when the registered owner dies, is wound up or amalgamated, or ceases to be qualified under CAR 900.15.

Mandatory Record Keeping: Flight and Maintenance Logs (CAR 901.48)

Under CAR 901.48, every owner of an RPAS must maintain two continuous logs:

1. The Flight Operational Log

This log tracks operational activity and must include:

• Flight date, take-off and landing times, and total flight duration
• Names of flight crew members (Pilot-in-Command, Visual Observers)
• Specific flight locations or coordinates
• Any operational anomalies, airspace incursions, or malfunctions

2. The Maintenance and Technical Log

This log tracks system airworthiness and must record:

• Total time in service for the aircraft, motors, and assemblies
• Dates and descriptions of pre-flight and post-flight inspections
• Scheduled and unscheduled maintenance performed
• Component replacements (e.g., motor swaps, propeller changes)
• Structural or electronic modifications (e.g., payload mounts, lights)
• Firmware, software, and sensor calibration updates
• Compliance with manufacturer mandatory safety service bulletins
• Battery lifecycle tracking (serial numbers, cycle counts, retirement dates)

Retention Period and Production Standards

CAR 901.48(2) sets two different retention periods, and the exam tests the difference:

Both sets of records must be made available to the Minister on request. Transport Canada inspectors — not police officers generally — are the authority named in the regulation. Under CAR 901.48(3), an owner who transfers ownership of the system must hand the maintenance records to the new owner at the time of transfer.

Regulatory Compliance Matrix: Registration, Marking & Records

Practical Exam Scenarios

Scenario 1: The Worn-Off Marking

A pilot wrote the C-number on the belly of the airframe with a felt-tip pen; after a season of landings on wet grass the number is no longer legible. Analysis: CAR 900.14 requires the registration number to be clearly visible on the aircraft every time it is operated. A number you cannot read is a number that is not clearly visible. Transport Canada's guidance is explicit that the pilot is responsible for making the number visible again — rewrite it or create a new permanent label before the next flight.

Scenario 2: Buying a Used Drone

A buyer purchases a 3 kg drone carrying the previous owner's C-number. The seller claims the registration remains valid for another 18 months. Analysis: This violates CAR 900.18. The certificate of registration is cancelled when legal custody and control is transferred, and the seller must notify the Minister within seven days. The buyer must register the RPA in their own name and apply their own number before flying. The seller must also hand over the CAR 901.48(1)(b) maintenance records at the time of transfer.

Scenario 3: Unrecorded Propeller Replacement

After a rough landing, an operator replaces damaged propellers with new OEM blades but does not log the change. Analysis: Under CAR 901.48(1)(b), replacing aerodynamic components is a maintenance action. The owner must record the particulars — who performed the work, the date, and (for a modification) the manufacturer, model and description of the part — and retain that record for 24 months. The separate crew-and-flight-time record under paragraph (1)(a) is retained for only 12 months.