3.2 Legacy Aircraft 50 m Separation & MTOM < 2 kg
Key Takeaways
- Legacy (non-UK2/C2 class-marked) unmanned aircraft with MTOM under 2 kg that were placed on the market before 1 January 2026 may be flown in A2 Near People with an A2 CofC, but the safe horizontal distance from uninvolved persons is at least 50 m—not 30 m or 5 m.
- The 30 m normal and 5 m low-speed privileges are class-mark privileges; without a UK2 or transitional C2 mark you cannot claim them even if you fly slowly or the airframe is light.
- From 1 January 2028, EU C-class aircraft that previously flew under transition are treated as legacy by weight—detail expands in the transition chapter; exam stems already use this as a calendar trap.
- Compare three patterns: UK2/C2 at 30 m (or 5 m with low-speed mode); legacy MTOM < 2 kg at 50 m from people; A3 default that also uses large person buffers plus typically 150 m from residential/commercial/industrial/recreational areas.
- A2 CofC on a legacy airframe expands where you may operate relative to pure A3 far-from-people flying, but it does not import UK2 distance numbers.
Legacy Aircraft Still Matter on the Exam
Not every drone used for commercial or serious amateur work carries a UK class mark. Thousands of capable multirotors were placed on the market without UK0–UK6 marking. UK regulation therefore keeps a legacy path so those aircraft are not instantly worthless—but the path is deliberately stricter on ground risk than the UK2 package.
For A2 theory, “legacy” means: not flying under a UK2 (or transitional C2-as-UK2) class mark. The critical mass line for Near People legacy use with an A2 CofC is MTOM less than 2 kg for aircraft placed on the market before 1 January 2026 (UAS.OPEN.030 legacy wording, often referenced as the (1A) / (3)(b) style provisions in training materials). Heavier unmarked aircraft are pushed toward A3 far-from-people operations or the Specific category—not the A2 person-distance regime you are studying here.
The 50 m Horizontal Floor
A legacy / non-UK2 aircraft with MTOM < 2 kg operated under A2 with a valid CofC must maintain a safe horizontal distance of at least 50 metres from uninvolved persons. As with UK2 rules:
- The distance is horizontal, not a slant-range shortcut through the air.
- Intentional overflight of uninvolved persons remains prohibited.
- There is no regulatory 5 m reduction for legacy types just because you fly slowly or install third-party prop guards.
Why 50 m instead of 30 m? Class-marked UK2 aircraft meet design requirements (including a manufacturer low-speed mode and other safety features) that justify closer operations. Legacy airframes have not demonstrated those class standards to the regulator’s product framework, so the Open category keeps a larger person buffer.
Exam trap: “I have A2 CofC so I get 30 m”
Holding the certificate is necessary for A2 privileges on eligible aircraft; it is not sufficient to import UK2 distances onto an unmarked airframe. Certificate + legacy < 2 kg → 50 m. Certificate + UK2/C2 → 30 m (or 5 m with low-speed mode and evaluations). Certificate alone never rewrites the aircraft’s regulatory identity.
Exam trap: “My drone is only 900 g so I can use 5 m”
Mass helps for legacy eligibility under the 2 kg line, but 5 m is not a mass privilege—it is a class-mark + low-speed mode privilege. A 900 g unmarked drone still sits on the 50 m legacy floor in A2.
No 30 m / 5 m Without the Mark
| Claim a pilot might make | Valid for legacy MTOM < 2 kg in A2? | Correct rule |
|---|---|---|
| “I will keep 30 m like UK2 normal mode.” | No | ≥ 50 m horizontal from uninvolved persons |
| “I will engage a custom slow mode and use 5 m.” | No | No 5 m legacy reduction; stay at ≥ 50 m |
| “I will not overfly uninvolved people.” | Yes — mandatory | Same absolute ban as UK2 |
| “I completed A2 CofC so A3 150 m area rules disappear.” | Not automatically | A2 changes the people and subcategory framing; do not ignore other Open rules, airspace, or local restrictions |
| “After 1 Jan 2028 my old EU C2 still flies as UK2 forever.” | No | Transition ends; C-class becomes legacy by weight (see below) |
If the manufacturer later obtains a proper UK2 class mark for that type, or you change to a UK2 airframe, the 30/5 package becomes available. Until then, train your muscle memory: no mark → no 30/5.
Calendar Preview: 1 January 2028 and C-Class as Legacy by Weight
During the UK transition, many pilots lawfully treat EU C2 aircraft as UK2-equivalent for operational privileges (including separation) until 31 December 2027. From 1 January 2028, those C-class aircraft are generally treated as legacy according to weight, not as perpetual UK2 twins. Full operational detail belongs in the transition and Remote ID chapters; what you need now for separation questions is the logic:
- Before end-2027: transitional C2 → may use UK2-style 30 m / 5 m package when other A2 conditions are met.
- From 1 Jan 2028: same physical airframe without a UK mark path → legacy weight rules apply; if it still qualifies by mass for A2 legacy treatment, expect the 50 m person floor rather than 30/5; if it is too heavy for legacy A2, the pilot is looking at A3 or Specific category options.
Exam stems often plant a date (2026 vs 2027 vs 2028) next to an EU C2 label. Always ask: are we still inside the transition window, or has C-class flipped to legacy-by-weight?
Comparison Table: UK2 vs Legacy A2 vs A3 Default Thinking
| Feature | UK2 / transitional C2 in A2 | Legacy MTOM < 2 kg in A2 | Typical A3 “far from people” pattern |
|---|---|---|---|
| Class mark required | Yes (UK2 or transitional C2) | No (legacy path) | Often used for unmarked or heavier Open types |
| A2 CofC | Required for these Near People privileges | Required for this legacy A2 path | Flyer ID level training; A2 CofC not the A3 ticket |
| Min horizontal from uninvolved persons | 30 m normal; 5 m with low-speed mode + evaluations | 50 m (no 5 m reduction) | Commonly 50 m from uninvolved persons in training materials, with stricter area rules |
| Area / built-up buffers | Near People allowed within Open A2 constraints | Near People allowed but with larger person buffer | Often ≈150 m from residential, commercial, industrial, recreational areas |
| Low-speed mode privilege | Yes — enables 5 m floor | No regulatory 5 m package | Not the A2 5 m privilege |
| Intentional overflight of uninvolved persons | Prohibited | Prohibited | Prohibited |
| MTOM context | UK2 typically < 4 kg with class features | Legacy A2 line < 2 kg (and market-date conditions) | Varies; heavier legacy types often stuck in A3 |
Read this table as a hierarchy of strictness about people and places. UK2 is the most precise Near People tool: closer person floors because product standards exist. Legacy A2 is a middle path: you may work nearer to people environments than pure A3, but you still give people a 50 m berth. A3 is the far-from-people Open default: large person buffers plus distance from settled or recreational areas.
Worked Comparisons
Example 1 — Two pilots, same park edge. Pilot A flies a UK2 2.5 kg aircraft in normal mode: minimum 30 m from walkers. Pilot B flies a 1.5 kg unmarked legacy aircraft with A2 CofC: minimum 50 m from the same walkers. If both wrongly use 20 m, both are non-compliant, but for different floors—the exam may ask which pilot is closer to compliance; Pilot A is nearer the legal floor but still short; Pilot B is further out of limits.
Example 2 — Slow flying without a mark. Pilot B reduces speed manually to a crawl and argues for 5 m. Invalid. Without UK2/C2 and active class low-speed mode, the floor stays 50 m.
Example 3 — Transition date. In June 2027, an EU C2 with A2 CofC uses 30/5 like UK2. In February 2028, unless a UK marking path applies, treat it under legacy weight logic—expect 50 m if still A2-eligible by mass, not 5 m nostalgia.
Example 4 — Confusing A3 150 m with person distance. A question asks the minimum from an uninvolved person for legacy A2 < 2 kg. The answer is 50 m, not 150 m. The 150 m figure belongs to A3 distance from certain types of areas, a different control. Mixing “people” and “areas” is one of the highest-yield A2 mistakes.
Operational Implications for Planning
Because legacy A2 needs 50 m all around uninvolved persons, site selection is harsher than for UK2. A narrow urban courtyard that barely supports 30 m UK2 operations will often fail legacy planning. Before you promise a client a facade inspection with an unmarked 1.8 kg aircraft, measure whether a 50 m person bubble is realistic for the entire task, including transit and contingency paths. If not, change aircraft (UK2), change time (when the public is absent), change subcategory expectations, or move toward an operational authorisation in the Specific category.
Also remember that involved persons (those who have been briefed and accepted the operational risk) are treated differently from uninvolved persons in Open-category doctrine. Do not invent involvement: a random pedestrian is uninvolved; a client standing in the take-off zone after a briefing may be involved. The 50 m floor is about uninvolved people. Exam questions sometimes flip the definition to see whether you enlarge the bubble around everyone including the camera assistant you just briefed.
Memory Hooks for Section 3.2
- Legacy A2 < 2 kg → 50 m from uninvolved persons; no 5 m shortcut.
- UK2/C2 → 30 m / 5 m; mark required.
- A3 → think people + areas (often 50 m people thinking plus ~150 m from built-up/recreational areas).
- 1 Jan 2028 → C-class transition ends; weight-based legacy logic returns for those airframes.
- A2 CofC ≠ automatic UK2 distances.
Master the comparison, and most “which distance applies?” items become mechanical: identify mark → identify mode → identify subcategory → pick the floor.
An A2 CofC holder operates a legacy (non-class-marked) drone with a take-off mass of 1.8 kg placed on the market before 1 January 2026. What is the minimum horizontal distance from uninvolved persons?
Why can a remote pilot not apply the UK2 30 m / 5 m separation package to an unmarked 1.2 kg multirotor even though they hold an A2 CofC and fly very slowly?
Which statement best compares UK2 A2 separation with legacy MTOM < 2 kg A2 separation and typical A3 thinking?
From 1 January 2028, how should a remote pilot conceptually treat an EU C-class drone that previously flew in the UK under the class-mark transition?