1.1 EASA Regulatory Framework & A2 Overview

EASA Regulatory Framework & A2 Overview

The European UAS Regulatory Hierarchy

The European Union Aviation Safety Agency (EASA) regulatory framework for drones is structured across three core legislative instruments enacted by the European Parliament and the European Commission:

1. Basic Regulation (EU) 2018/1139: Serves as the overarching primary aviation law of the European Union. It establishes common rules in civil aviation and creates EASA's legal mandate. Crucially, Regulation (EU) 2018/1139 removed the historical 150 kg operating boundary that previously left lightweight civil drones under disparate national civil aviation authorities (NAAs). It brings all civil unmanned aircraft, regardless of maximum take-off mass (MTOM), under uniform European jurisdiction.
2. Commission Implementing Regulation (EU) 2019/947: Defines the operational rules governing UAS flights, remote pilot competencies, operational categories, and UAS operator registration. It establishes the operational constraints for the Open, Specific, and Certified categories and outlines the rules of the air for unmanned aviation.
3. Commission Delegated Regulation (EU) 2019/945: Defines the technical manufacturing and product standards for UAS sold within the European single market. It defines the class identification labels (Class C0 through Class C6), CE marking requirements, noise emissions, structural impact mitigation, and Direct Remote Identification (DRI) specifications.

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The Three Operational Categories

Regulation (EU) 2019/947 divides all unmanned flight operations into three distinct risk tiers:

1. The Open Category (Low Risk)

• Operational Profile: Visual Line of Sight (VLOS) operations conducted up to a maximum flight altitude of 120 m (400 ft) above the nearest point of the surface of the earth.
• Weight Threshold: Unmanned aircraft with an MTOM of strictly less than 25 kg.
• Authorizations: No prior operational authorization or declaration is required from the National Aviation Authority (NAA) before flight.
• Subcategories: Subdivided into A1, A2, and A3 based on proximity to uninvolved people and operational environment.
• Commercial vs. Leisure: The regulation makes no distinction between commercial and recreational operations; regulatory requirements are based purely on operational risk and aircraft class.

2. The Specific Category (Medium Risk)

• Operational Profile: Operations that exceed the boundaries of the Open category, such as Beyond Visual Line of Sight (BVLOS), operations with drones exceeding 25 kg MTOM, flights over 120 m above ground level, or flights involving higher ground or air risk.
• Authorizations: Requires one of three formal compliance pathways:
  • Submission of an operational declaration under a European Standard Scenario (STS-01 for urban VLOS or STS-02 for rural BVLOS);
  • Obtaining an Operational Authorization from the NAA following a Specific Operations Risk Assessment (SORA) or Pre-Defined Risk Assessment (PDRA); or
  • Holding a Light UAS Operator Certificate (LUC) with privileges to self-authorize operations.

3. The Certified Category (High Risk)

• Operational Profile: Operations with risk levels comparable to traditional manned aviation, including the carriage of passengers (e.g., urban air mobility and autonomous air taxis), transportation of dangerous goods that present severe environmental or public hazards upon an accident, or flights over assemblies of people with a UAS certified for that purpose.
• Authorizations: Requires a UAS certified under Article 40 of Delegated Regulation (EU) 2019/945, a certified UAS operator and, where applicable, a licensed remote pilot (Article 6 of Regulation (EU) 2019/947).

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The Open Category Subcategories: A1, A2, and A3

To manage ground risk proportionally, the Open category is partitioned into three operational subcategories:

Subcategory A1 ("Fly Over People")

• Objective: Permitting operations in urban and populated settings using very light drones where ground kinetic impact risk is minimal.
• Permitted Aircraft:
  • Class C0 drones (MTOM < 250 g, max speed $\le 19\text{ m/s}$);
  • Privately built drones with MTOM < 250 g;
  • Class C1 drones (MTOM < 900 g, or designed so that less than 80 J is transmitted to a human head on impact; maximum level-flight speed 19 m/s).
• Operational Rules:
  • Overflight of individual uninvolved persons is permitted with C0 drones, though remote pilots should minimize such overflights where possible.
  • With Class C1 drones, the remote pilot must not intentionally overfly uninvolved persons. If unexpected overflight occurs, the pilot must curtail the overflight duration immediately.
  • Overflight of assemblies of people is strictly prohibited for all drones.

Subcategory A2 ("Fly Close to People")

• Objective: Permitting operations with heavier, professional-grade unmanned aircraft close to populated areas and uninvolved individuals under strict speed and distance buffers.
• Permitted Aircraft: Class C2 drones (MTOM < 4 kg bearing the official C2 class identification label).
• Operational Rules:
  • Standard minimum horizontal separation of 30 m from any uninvolved person.
  • Separation may be reduced to a minimum of 5 m if the remote pilot activates the drone's low-speed mode (limiting ground speed to $\le 3\text{ m/s}$).
  • Before using the 5 m minimum, the remote pilot must evaluate the weather conditions, the performance of the aircraft and the segregation of the overflown area (UAS.OPEN.030(1)). AMC1 UAS.OPEN.030(1) adds the 1:1 rule as a reference: keep a lateral distance from uninvolved persons at least equal to the flying height.
  • Overflight of uninvolved persons and assemblies of people is strictly prohibited at all times.

Subcategory A3 ("Fly Far from People")

• Objective: Accommodating heavy drones, legacy aircraft without class labels, and model aircraft in remote environments.
• Permitted Aircraft: Class C2 drones, Class C3 and C4 drones (< 25 kg), privately built aircraft below 25 kg, and legacy drones without a class label that were placed on the market before 1 January 2024 (MTOM < 25 kg, Article 20).
• Operational Rules:
  • Must maintain a minimum horizontal distance of 150 m from residential, commercial, industrial, or recreational areas.
  • The operation must take place in an area where the remote pilot reasonably expects that no uninvolved persons will be present or endangered within the operational buffer.

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Privileges and Scope of the A2 Certificate of Competency

The A2 Certificate of Competency (A2 CofC) provides advanced operational privileges in European airspace. Holding this qualification unlocks the legal right to pilot Class C2 unmanned aircraft systems (up to 4 kg MTOM) within urban, suburban, and commercial settings near uninvolved individuals.

Without an A2 Certificate of Competency, a C2-labelled drone may be flown in the open category only under the restrictive conditions of Subcategory A3 (no uninvolved people endangered and at least 150 m from residential, commercial, industrial or recreational areas). The A2 certificate transforms a remote pilot's operational envelope, making commercial aerial surveys, roof and infrastructure inspections, real estate media production, and emergency response filming legally feasible in cities and populated towns.

Mutual Recognition Across Europe

Under Article 67 of Basic Regulation (EU) 2018/1139, certificates issued under the EU framework are valid and recognised in all Member States without further evaluation. An A2 Certificate of Competency issued by the competent authority of any EU Member State is therefore recognised across all 27 EU Member States, as well as in European Free Trade Association (EFTA) nations adopting the EASA regulatory framework: Iceland, Liechtenstein, Norway, and Switzerland. A pilot certified in Germany or Ireland can legally conduct A2 operations in France, Italy, or Spain without re-examination or foreign conversion fees.

Validity and Revalidation

Under UAS.OPEN.070, the A2 Certificate of Competency is valid for 5 years. While it is still valid, it can be revalidated by either:

• Demonstrating the competencies again in accordance with UAS.OPEN.030(2); or
• Completing refresher training on the theoretical knowledge subjects, provided by the competent authority or an entity it has designated.

If the certificate has already expired, only the first route applies: the pilot must demonstrate the competencies again.

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UAS Operator Registration vs. Remote Pilot Competency

A critical legal distinction that frequently appears on the A2 examination is the difference between the UAS Operator and the Remote Pilot:

• The UAS Operator (Article 14): The natural or legal person (individual, company, public agency, or educational institution) who owns, leases, or is legally responsible for operating the unmanned aircraft. The operator is responsible for maintaining the aircraft, managing insurance, establishing operational procedures, and ensuring pilots are properly certified.
• The Remote Pilot (Article 8): The physical individual who manipulates the flight controls of the unmanned aircraft system during flight.

Full registration string issued at registration:  FIN87astrdge12k8-xyz

FIN           ISO 3166 alpha-3 code of the registering Member State
87astrdge12k  12 random lower-case alphanumerics
8             checksum character (Luhn mod 36)
-xyz          3 "secret digits": entered into the Remote ID system, never displayed or shared

Public UAS operator registration number = first 16 characters: FIN87astrdge12k8

Mandatory Operator Registration Criteria (Article 14)

An individual or organization must register as a UAS Operator in their Member State of residence or establishment before operating an unmanned aircraft in the Open category if the aircraft:

1. Has an MTOM of 250 g or more, or could transfer more than 80 J of kinetic energy to a person on impact; or
2. In the case of an aircraft with an MTOM of less than 250 g, is equipped with a sensor able to capture personal data (such as an optical camera or audio microphone), unless the aircraft conforms to Directive 2009/48/EC (the European Toy Safety Directive).

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Official A2 Theoretical Examination Specifications

To earn the A2 Certificate of Competency, candidates must pass an additional theoretical knowledge examination provided by the competent authority or by an entity it has designated or recognised (UAS.OPEN.030(2)(c)):

• Prerequisites: The candidate must hold the A1/A3 proof of completion of the online training and exam. They must also have completed the practical self-training under A3 conditions and declared that they completed it. The general minimum age for remote pilots is 16 (Article 9).
• Question Count: At least 30 multiple-choice questions (MCQs).
• Subject Breakdown: The regulation requires the questions to be "distributed appropriately" across three subjects. AMC1 UAS.OPEN.030(2)(c) lists what each subject covers. No official percentage weighting is published.
  1. Meteorology: the effect of weather on the UA (wind, including urban effects and turbulence; temperature; visibility; air density) and obtaining weather forecasts;
  2. UAS Flight Performance: the typical operational envelope of rotorcraft, fixed-wing and hybrid configurations; mass, balance and centre of gravity; securing the payload; and batteries (types, terminology such as memory effect, capacity and C-rate, charging, use, dangers and storage);
  3. Technical and Operational Mitigations for Ground Risk: low-speed mode functions, evaluating the distance from people, and the 1:1 rule.
• Passing Score: At least 75% of the overall marks (on a 30-question paper, at least 23 correct answers).
• Examination Time: Not set by the EU rules. Each competent authority (or its designated entity) sets the time limit and exam procedure, so check your national authority's instructions.
• Examination Conditions: Under AMC2 UAS.OPEN.030(2)(c), the exam is held either face-to-face at the facilities of the competent authority or a designated/recognised entity, or as an online-proctored exam. The proctoring system must verify the candidate's identity and check that no support is used beyond what the exam procedure allows.