1.2 The Three Operational Categories: Open, Specific, and Certified

1.2 The Three Operational Categories: Open, Specific, and Certified

[!NOTE] The Paradigm Shift to Risk-Based Aviation: Under Regulation (EU) 2019/947, the legal purpose of a flight is completely irrelevant. Whether you are flying for fun, shooting a Hollywood blockbuster, or surveying critical infrastructure for a multinational utility, the regulatory category is determined strictly by the risk profile of the operation—specifically its kinetic energy, operating environment, and proximity to uninvolved people and manned aircraft.

Historically, aviation authorities regulated drones based on commercial intent: recreational hobbyists operated under lenient guidelines, while commercial operators faced burdensome licensing and airworthiness certifications regardless of how small the drone was. Regulation (EU) 2019/947 eliminated this dual standard. Today, risk is evaluated through an operation-centric, proportionate methodology.

All drone operations in Europe are categorized into three distinct operational tiers:

1. Open Category (Low Risk)
2. Specific Category (Medium Risk)
3. Certified Category (High Risk)

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The Open Category (Low Risk)

The Open Category is designed for straightforward, low-risk civil drone operations. Its defining legal feature is that no prior operational authorization or declaration is required from the National Aviation Authority before commencing flight.

+-----------------------------------------------------------------------------------+
|                         THE OPEN CATEGORY GOLDEN BOUNDARIES                       |
+-----------------------------------------------------------------------------------+
|  1. Maximum Height Above Ground:  120 metres (400 ft)                             |
|  2. Visual Line of Sight (VLOS):  Continuous direct unassisted visual contact     |
|  3. Maximum Take-Off Mass (MTOM): Strictly less than 25 kg                        |
|  4. Crowd Overflight Prohibition: Never fly over open-air assemblies of people    |
|  5. Payload Restrictions:         No dangerous goods, no dropping of any items    |
|  6. Prior Authorization:          NONE required from the NAA                      |
+-----------------------------------------------------------------------------------+

The Three Open Subcategories (A1, A2, A3)

To mitigate ground risk proportionally, the Open Category is subdivided into three operating subcategories based on proximity to uninvolved people and aircraft mass:

• Subcategory A1 ("Fly Over People"): Permits operations close to people, and transient overflight of uninvolved people with lightweight drones (C0 < 250 g or C1 < 900 g). Overflight of open-air assemblies of people is strictly prohibited.
• Subcategory A2 ("Fly Close to People"): Permits operations with medium drones (C2 class up to 4 kg) near uninvolved people, maintaining a minimum safe horizontal distance of 30 metres (or 5 metres if low-speed mode is actively engaged).
• Subcategory A3 ("Fly Far from People"): The default operating environment for heavy drones (C3 and C4 up to 25 kg, and legacy unclassed drones up to 25 kg). Requires maintaining a minimum horizontal buffer of 150 metres from residential, commercial, industrial, and recreational areas, with zero uninvolved persons present in the operating zone.

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The Specific Category (Medium Risk)

When a planned flight exceeds even a single limitation of the Open Category, it cannot legally take place in the Open Category. It immediately transitions into the Specific Category.

Operational Triggers for the Specific Category

An operation belongs in the Specific Category if it involves any of the following:

• Flying Beyond Visual Line of Sight (BVLOS).
• Exceeding the standard 120-metre flight ceiling above ground level.
• Operating a drone with an MTOM exceeding 25 kg (up to certified thresholds).
• Dropping articles, materials, or agricultural sprays from the aircraft.
• Operating in urban or populated environments closer to people than permitted in Open subcategories A1 or A2.

Pathways to Operational Authorization in the Specific Category

Because the Specific Category carries medium risk, the operator must obtain formal authorization or submit an official declaration before flying. There are four established administrative pathways:

                         SPECIFIC CATEGORY AUTHORIZATION PATHS
                                           │
    ┌──────────────────────┬───────────────┴───────────────┬──────────────────────┐
    ▼                      ▼                               ▼                      ▼
+───────────────+  +───────────────+               +───────────────+      +───────────────+
| Standard      |  | Pre-Defined   |               | SORA Risk     |      | Light UAS     |
| Scenarios     |  | Risk Assess.  |               | Assessment    |      | Operator Cert.|
| (STS-01/02)   |  | (PDRA)        |               | (JARUS/EASA)  |      | (LUC)         |
| Declaration   |  | Fast-track    |               | Custom safety |      | Organizational|
| only (C5/C6)  |  | authorization |               | case (SAIL)   |      | self-authoriz.|
+───────────────+  +───────────────+               +───────────────+      +───────────────+

1. Standard Scenarios (STS): Highly standardized European flight envelopes published by EASA. The operator merely submits a declaration to the NAA confirming compliance with the STS rules without waiting for an individual assessment:
   • STS-01: Covers VLOS operations over a controlled ground area in a populated environment using a C5-class drone.
   • STS-02: Covers BVLOS operations over a controlled ground area in a sparsely populated environment with visual observers using a C6-class drone.
2. Pre-Defined Risk Assessments (PDRA): Standardized risk scenarios published by EASA (such as PDRA-S01 or PDRA-G01). Operators submit an authorization application using pre-packaged mitigations, significantly expediting NAA review.
3. Specific Operations Risk Assessment (SORA): The full comprehensive safety risk methodology developed by JARUS and adopted by EASA. The operator evaluates the Ground Risk Class (GRC) and Air Risk Class (ARC) to determine the Specific Assurance and Integrity Level (SAIL I through VI), implementing corresponding Operational Safety Objectives (OSOs).
4. Light UAS Operator Certificate (LUC): An organizational certification granted to mature drone companies with an approved Safety Management System (SMS). An LUC holder has the legal privilege to self-authorize Specific Category missions without submitting individual applications to the NAA.

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The Certified Category (High Risk)

The Certified Category represents the pinnacle of operational risk in unmanned aviation. Operations in this category present risks comparable to manned commercial air transport and are governed by traditional aviation safety mechanisms: certified aircraft, licensed pilots, and certified operators.

The Three Statutory Triggers for the Certified Category

Under Article 6 of Implementing Regulation (EU) 2019/947 and Article 40 of Delegated Regulation (EU) 2019/945, an operation is strictly mandated to be conducted in the Certified Category if it meets ANY of the following three criteria:

1. Passenger Transport: The operation is conducted with an unmanned aircraft carrying human passengers (e.g., autonomous air taxis, urban air mobility eVTOL passenger vehicles).
2. Carriage of Dangerous Goods: The operation involves the transport of dangerous goods that may pose high risk to third parties in the event of an accident (e.g., bulk toxic chemicals, radiological substances, or high-explosive compounds).
3. Large Aircraft Over Crowds: The operation is conducted over open-air assemblies of people using an aircraft with a characteristic dimension of 3 metres or more.

In the Certified Category, the drone must hold a formal Type Certificate (TC) and Certificate of Airworthiness (CofA) issued under Part-21. The remote pilot must hold a commercial remote pilot license issued under Part-FCL standards, and the operator must hold a certificate equivalent to a commercial Air Operator Certificate (AOC).

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Comparative Matrix of the Three Categories

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Boundary Lines: When Does an Operation Shift Categories?

Understanding exactly when a flight crosses from one category to another is a critical exam competency:

                                   IS FLIGHT WITHIN OPEN LIMITS?
                    - Direct Visual Line of Sight (VLOS) maintained?
                    - Height <= 120 m above ground?
                    - MTOM < 25 kg?
                    - No crowds, no dangerous goods, no dropping items?
                                     /                     \
                                   YES                      NO
                                   /                         \
                          +---------------+                   v
                          | OPEN CATEGORY |        DOES OPERATION INVOLVE:
                          +---------------+        - Carrying human passengers?
                                                   - Transporting dangerous goods?
                                                   - UAS >= 3m over assemblies?
                                                          /                \
                                                        YES                 NO
                                                        /                    \
                                              +--------------------+   +-------------------+
                                              | CERTIFIED CATEGORY |   | SPECIFIC CATEGORY |
                                              +--------------------+   +-------------------+

Case Analysis: The 120-Metre Artificial Obstacle Exemption

Under Article 4(1)(e) of Regulation (EU) 2019/947, read together with point UAS.OPEN.010(3) of Part A of the Annex, a narrow exception exists in the Open Category regarding the 120-metre ceiling: when flying within 50 metres horizontally of an artificial obstacle taller than 105 metres (such as a 150-metre wind turbine or telecommunications tower), the drone may fly up to 15 metres above the height of the obstacle, provided:

1. The flight is conducted at the explicit request of the structure's owner.
2. The drone remains within a horizontal radius of 50 metres from the obstacle at all times.
3. The flight remains strictly in direct VLOS.

If the drone strays more than 50 metres horizontally from the structure while flying above 120 metres, it instantly violates Open Category rules and becomes an unauthorized Specific Category flight.

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Practical Flight Scenarios: Categorization in Action

+-----------------------------------------------------------------------------------+
| SCENARIO 1: Inspecting Solar Panels on a Commercial Warehouse                     |
| Equipment: DJI Mavic 3 Enterprise (C2 class, MTOM ~1,050 g).                      |
| Profile: Flown in direct VLOS at 45 metres altitude, keeping 30 m from workers.    |
| Classification: OPEN Category (Subcategory A2). No authorization needed.          |
+-----------------------------------------------------------------------------------+
| SCENARIO 2: Linear Railway Inspection Across a 15-Kilometre Mountain Pass        |
| Equipment: Fixed-wing mapping drone (MTOM 8 kg).                                  |
| Profile: Flown Beyond Visual Line of Sight (BVLOS) at 100 metres altitude.        |
| Classification: SPECIFIC Category. Flown under European Standard Scenario STS-02  |
| (or an NAA operational authorization via SORA).                                   |
+-----------------------------------------------------------------------------------+
| SCENARIO 3: Autonomous Airport Shuttle Transporting Airline Passengers            |
| Equipment: Multi-rotor passenger eVTOL (MTOM 1,800 kg).                           |
| Profile: Autonomous transport of two passengers between terminal and city center. |
| Classification: CERTIFIED Category. Aircraft requires Type Certification; operator|
| requires full commercial certification equivalent to an Air Operator Certificate. |
+-----------------------------------------------------------------------------------+

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Common Exam Traps & Pitfalls

• Trap: "Commercial" Equals "Specific": Never select an answer claiming that being paid for a drone flight places it in the Specific Category. A commercial roof inspector operating within 120 m in VLOS flies 100% legally in the Open Category.
• Trap: FPV Flying is Automatically BVLOS: First-Person View (FPV) goggles block the pilot's direct line of sight, but under Open Category rules, FPV is explicitly permitted provided an unmanned aircraft observer stands directly beside the pilot, maintaining continuous direct visual contact with the drone and verbally communicating traffic hazards.
• Trap: Consumer LiPo Batteries as "Dangerous Goods": Drones carry lithium batteries as their integral propulsion power source. This does NOT classify the operation as "transporting dangerous goods" under the Certified Category. The dangerous goods restriction applies to hazardous commercial cargo carried as payload.