COVID-19 causes delay in Australian Drone Part 101 Manual of Standards

Published: 12 April 2020

Executive summary

The sections of the Australian Part 101 (Unmanned Aircraft and Rockets) Manual of Standards 2019 (MOS) that were due to come into effect on 10 April 2020 have been pushed out to 10 October 2020.

MOS refresher

The MOS prescribes a range of miscellaneous matters in relation to the safety and regulatory oversight of drones, including training and competency standards for remote pilot licences, and standing approvals for certain kinds of operations near aerodromes and beyond visual line of sight operations.

Staggered implementation

The MOS comprises 11 chapters, most of which came into effect on 10 April 2019. However, parts of chapters 2, 4, 9 and 10 were not to come into force until 10 April 2020, and part of Chapter 2 delayed until 10 October 2020.

The latest amendment

On 2 April 2020, CASA released the Part 101 Manual of Standards (Extensions of Time Due to COVID-19) Amendment Instrument 2020 (No. 1) accessible here which, in short, pushed out the MOS provisions due to come into force on 10 April 2020 a further 6 months to 10 October 2020.

The Explanatory Statement to the amendment states that, “RPA training organisations have been faced with the progressively dire implications of the COVID-19 pandemic, the associated state of emergency across Australia and the need to maximise the remedial effects of travel bans and social distancing rules. Largely because of this, and its impacts, for example, on mobility and staffing, it has proved to be impracticable for a large number of the training organisations to finalise their required training documented practices and procedures for CASA approval by properly incorporating all of the relevant elements from the new training syllabus contained in the MOS.”

What is the actual effect?

[1] All of Chapter 2, titled ‘RePL Training Course’ concerning training courses (and training instructors) will now take effect on 10 October 2020 (this was the original date for the provisions relating to instructors).

[2] Chapter 4 titled ‘Operations in Controlled Airspace – Controlled Aerodromes’ took effect on 10 April 2020 as originally intended.

[3] Chapter 9 titled, ‘Operations of RPA in Prescribed Areas’  took effect on 10 April 2020 as originally intended (except Division 9.2 concerning no-fly zones which took effect on 10 April 2019).

[4] Chapter 10 titled, ‘Record Keeping for Certain RPA’ will now take effect on 10 October 2020 (except Divisions 10.1 and 10.4 concerning Definitions and giving certain information to CASA, which took effect on 10 April 2019).


While we appreciate that industry has mixed feelings about the delay (and its causes), perhaps we simply take it as an opportunity to get our drones lined up impeccably so that when the changes do come into place, all participants are in the best possible position to leverage all opportunities made available by this technology.

Fly free!

The Drone Lawyer

12 April 2020