Have your say: proposed amendments to Drone Part 101 Manual of Standards

Published: 15 September 2020


CASA is seeking feedback on some proposed key changes to be made to the Part 101 (Unmanned Aircraft and Rockets) Manual of Standards 2019, otherwise known as the “MOS”.

The MOS can be accessed in its current state  here. Importantly, the MOS in this link is current at the date of writing but it is subject to change and so this link could be outdated shortly – especially once these changes are made to the MOS. 

However, we are here for the bare bones Need-to-Know, so here goes. At a high-level, there are 8 proposed changes to the MOS, outlined as follows:

1. Any student who commenced a Remote Pilot Licence (RePL) course between 3 April 2020 and 10 October 2020, will have until 31 January 2021, to complete all aspects of the course under the syllabi as is in force before 10 October 2020. Any course commenced on or from 10 October 2020 must be completed against the new relevant syllabi.

2. RePL training instructors are to be given an additional 18 months, to 10 April 2022, to obtain new instructor qualifications.

3. There are a number of new definitions, including ‘classification’, ‘electronic identificaiton’, ‘gross weight on take-off’, ‘modification’, ‘permit version’, and ‘unacceptable modification’, which set the stage for the proposed amendments.

4. Chapter 11 of the MOS currently titled ‘Notification of Change to Operate Excluded RPA’ is to be repealed. The aim is to replace the requirement for excluded category notifications with registration.

5. New Chapter 12: ‘Identification of RPA and Model Aircraft’. This provides that registration holders are to legibly display, in a manner that is easily seen or accessible, the manufacturer’s serial number, or the mark allocated by CASA when the drone was registered.

6. New Chapter 13: ‘Operation of Foreign Registered RPA and Model Aircraft’. Provides that an RPA or a model aircraft that has been registered under a law of a foreign country but not registered in Australia, will be required to obtain permission from CASA, instead of a registration certificate.

7. New Chapter 14: ‘Permisible [sic] Modifications to Registered RPA and Model Aircraft’: This provides for the acceptable modification of registered drones and criteria when any modified drone must be re-registered.

8. New Chapter 15: ‘Conduct of Online Training Course and Examinations for Accreditation’. Provides for how the online pilot accreditation scheme will work, including that an applicant must personally successfully complete the entirety of the online training course. i.e. no cheating!

Finally, as a heads up, the substantive questions asked by CASA in this consultation are as follows:

Question 1: Do you agree that the Part 101 MOS amendments reflect the change in policy as set out in the summary of proposed change and will work as intended?

Question 2: Do you agree that the Part 101 MOS amendments will not result in unintended consequences?

Do you have any additional comments about the proposed policy?


If you want to provide feedback, the consultation closes on 23 September 2020 and a link to the CASA page is available here.

While the CASA page contains all the relevant documents, we have prepared a marked-up version of the MOS to show the changes threaded within the MOS, which helps with context, that can be purchased for a fee.

Fly Free!

The Drone Lawyer

15 September 2020