The UK’s Law Commission has published the conclusion of its review of the law relating to aviation autonomy and issued recommendations for reform of the law which applies in England and Wales.
Some of the key recommendations for law changes (or not) focus on legal requirement for piloting several drones at the same time and eVTOL pilot qualifications,
“Although more consultees than not felt that there should be an upper limit to the number of UAS for which an individual remote pilot can be responsible for at one time, most of those did not advocate for a fixed number to be prescribed,” said the report. “We agree that it would not be sensible to set a fixed upper limit in legislation, especially not at this early stage. A fixed upper limit would risk being arbitrary and could inhibit flexibility and innovation in relation to a relatively nascent, and significant, type of operation.”
The report focus also on passenger services.
“Any requirements about particular levels of experience – for example different competencies for different types of VTOL operation, and for other types of passenger carrying UAS – could be set out in the more specific responsibilities needed to supplement the high-level requirements,” said the Law Commission.
“We think that operators of remotely piloted VTOLs should continue to be required to establish procedures for any reasonably foreseeable emergency situation, rather than expanding the requirement to cover non-foreseeable emergency situations.”
Here is a summary of the key recommendations
- The current definition of remote pilot set out in the UK UAS Delegated Regulation 2019/945 should be retained.
- In a commercial air transport operation a remote pilot as defined in the UK UAS Delegated Regulation 2019/945 should have the responsibilities of the commander of an operation within the meaning of the UK Air Operations Regulation 965/2012.
- Where the Air Navigation Order 2016 applies to UAS operations, references to “pilot” and “pilot-in-command” should include “remote pilot”.
- Where the applicable requirements in UK SERA 923/2012, the UK Air Operations Regulation 965/2012 and the UK Common Airspace Usage Requirements 1332/2011 apply to UAS operations, references to “pilot” and “pilot-in command” should include “remote pilot”.
- If multiple simultaneous operations (MSO) are authorised, UAS regulations should be amended to make clear that a remote pilot can serve as the pilot for multiple aircraft simultaneously.
- If switching between autonomous and remotely piloted phases of flight is permitted, if, UAS regulations should be amended accordingly so as to ensure legal certainty for all parties involved, any such amendment should be accompanied by supplemental frameworks setting out: (1) the conditions for such a transfer; and (2) who is legally responsible for the operation of the aircraft before, during and after a transition.
- Where the Air Navigation Order 2016 applies to UAS operations, the definition of “operator” should also include “UAS operator”.
- Where the applicable requirements of UK SERA 923/2012, the UK Air Operations Regulation 965/2012 and the UK Common Airspace Usage Requirements 1332/2011 apply to UAS operations, the definition of “operator” in these regulations should include “UAS operator”.
- Operators of remotely piloted VTOLs should be certified.
- Operators of remotely piloted VTOLs should continue to be required: (1) to have the means necessary for the scale and scope of operations planned; (2) to use only suitably qualified and trained personnel; (3) to implement a management system to ensure safety; (4) to ensure operations only take place in accordance with the operations manual; (5) to establish procedures to minimise the consequences to safe flight operations of disruptive passenger behaviour; (6) to develop and maintain security programmes suitable for the aircraft and type of operation; (7) to have a management system to prevent fatigue; (8) to ensure the continuing airworthiness of the aircraft; and (9) to establish procedures for any reasonably foreseeable emergency situation.
- Licences should be required for remote VTOL pilots. So far as appropriate, these should follow the classes and ratings adopted for crewed VTOLs
- A remotely piloted VTOL should be capable of detecting and recording information relating to accidents and near accidents.
For more information
https://cdn.websitebuilder.service.justice.gov.uk/uploads/sites/54/2026/05/Aviation-autonomy-final-report.pdf