Skip to main content
Please wait...
Discover Our Blog

Controller: UAV Navigation S.L. Main Purpose:  Facilitate offers of News and Events, our services and/or products of your interest and of our Blog. Rights: Access, Rectification, Erasure, Object, Restriction of processing, Data portability, not to be subject to a decision based solely on automated processing. Additional Information: Additional and detailed information about our Privacy Policy can be found here. 

1 + 9 =
Solve this simple math problem and enter the result. E.g. for 1+3, enter 4.
This question is for testing you are a human visitor

Operational Authorization Processes Applicable to the UAS Specific Category operations


Obtaining operational authorization to operate unmanned aerial vehicles (UAS) in the specific category is a crucial process to ensure safety and regulatory compliance. According to Commission Regulation (EU) 2019/947 [1], there are several ways to obtain such authorization.

First, the operator can perform a risk assessment and submit it together with the application to the competent authority, following the Specific Operations Risk Assessment (SORA) methodology. For those cases associated with a higher level of operational risk, European Union Aviation Safety Agency (EASA) approval is required through a Design Verification Process (DVP). Another option is to submit an operational statement if the conditions defined for a Standard Scenario (STS) are met. It is also possible to obtain authorization by fulfilling the requirements of a Predefined Risk Assessment (PDRA) or by obtaining a Light UAS Certificate (LUC). 

As of today, while it can be considered that there is still a certain level of uncertainty in the authorization process, especially for those operations associated with higher risk levels for which specific requirements and means of compliance have yet to be defined, as the industry evolves, bodies such as EASA and European Organization for Civil Aviation Equipment (EUROCAE) are working to make the regulations more accessible and efficient for operators and manufacturers.   



According to Article 5 of Commission Regulation (EU) 2019/947 [1], operational authorization is required to operate in a specific category. There are several ways to obtain this authorization:

  • The operator may conduct a risk assessment in accordance with Article 11 of [1] and submit it to the competent authority together with the application, including appropriate mitigation measures. A risk assessment can be performed using the SORA methodology, identified as Acceptable Means of Compliance (AMC) by EASA in its Easy Access Rules for Unmanned Aircraft Systems [2]. The result of this path would be the authorization of a specific operation to be performed, taking into account the following aspects:
    • Operational conditions and procedures.
    • Design and technical characteristics of the aircraft.
    • Remote pilot competence.

If the Specific Assurance and Integrity Level (SAIL) obtained from the SORA is equal to IV, the considerations derived from the design and technical characteristics must be approved by EASA through the Design Verification Process (DVP).

  • If the operation complies with the conditions defined for an STS according to the Implementing Regulation (EU) 2020/639 [3], the operator may submit an operational statement to the competent authority of the Member State.
  • In addition, the operator can also obtain operational authorization if they demonstrate compliance with the requirements defined for a PDRA. In particular, EASA has published five PDRAs as AMCs [2].
  • Finally, the operator can obtain an LUC if they demonstrate compliance with the requirements defined in its Implementing Regulation (EU) 2019/947 [1] in Part C of the Annex. This certificate allows the operator to self-assess the risk of their operation and to authorize it, provided that it complies with the specification provided by the competent authority (operator name, UAS model, type of UAS operations, special limitations).

Figure 1. Operational authorization pathways. Source: Own elaboration



In March 2021, EASA issued the first guidance by which UAS manufacturers or operators can request design verification of a system to be used for a given operation. This guidance was last updated in September 2023 [4]. This process can be performed in two different cases:

  • By a UAS operator applying for operational authorization: in this case, the competent authority refers to EASA the considerations associated with the design and technical characteristics of the UAS. Once the design verification process has been approved, the competent authority can issue the authorization, provided that the operation complies with the considerations associated with the operational procedures and the remote pilot's competencies.
  • By a UAS manufacturer voluntarily requesting a design verification process: in this case, the manufacturer applies directly to EASA for design verification approval. In this way, when an operation is to be performed with the approved UAS, only the operational issues need to be assessed, as those associated with the design and technical characteristics of the UAS will be approved directly. This facilitates the authorization process, since the competent authority will be able to directly approve the operation without requiring any additional verification by EASA.


The DVP must be performed when the operation is associated with a SAIL level IV when the technical mitigations (i.e., "M2" mitigations of the SORA) are declared with high robustness, as well as for the verification of the requirements associated with enhanced containment defined in step 9 of the SORA. Thus, the scope of the DVP may cover one or more of the following items:

  • Complete UAS design.
  • Mitigation means linked to the design.
  • Enhanced containment function.


The DVP is based on the airworthiness specifications for specific category UAS defined in the EASA document "Special Condition for Light Unmanned Aircraft Systems - Medium Risk" (SC Light-UAS) [5]. The following table shows the relationship between the specifications defined in [5] and the DVP application areas mentioned above:


Table 2. SC Light-UAS specifications for DVP Source: [6]


The first successful DVP was with Volocopter's "VC-200-2" system, which was performed for its enhanced containment function in June 2021 [7]. Another example of an application is the "ebee X" system, which was used for the verification of "M2" type mitigations in May 2022 [6]. However, the DVP process is still considered to be an evolving process, which will mature and adapt to real cases as experience increases both on the part of operators and manufacturers (as applicants for the process), as well as regulatory bodies.

For their part, EASA and other organizations, such as EUROCAE, are working to provide the necessary guidance material to meet the specifications associated with the verification process. As an example of this, the following documents have been developed for this purpose:

Table 3. Guidance material for compliance with SC Light-UAS specifications.
Sources: [8-15]



In conclusion, as we have been able to see throughout this document and the previous table highlights, different guides have been made available for compliance with the requirements applicable to the verification process and in obtaining certificates and operating authorizations for unmanned aerial vehicles (UAS) in the specific category. However, the consolidation of the regulations is yet to be finalized, which implies greater uncertainty in the regulatory process for medium-risk UAS operations in the specific category, especially for SAIL levels IV and above. This is why work will continue along these lines, with the aim of making the regulations applicable to UAS operations in Europe increasingly accessible and able to be adopted by operators and manufacturers efficiently.

Download report


[1] Commission Implementing Regulation (EU) 2019/947 of 24 May 2019 on the rules and procedures for the operation of unmanned aircraft.
[2] EASA. 2022. Easy Access Rules for Unmanned Aircraft Systems.
[3] Commission Implementing Regulation (EU) 2020/639 of 12 May 2020 amending Implementing Regulation (EU) 2019/947 as regards standard scenarios for operations executed in or beyond the visual line of sight.
[4] EASA. 2023. Guidelines on Design verification for UAS operated in the ‘specific’ category.
[5] EASA. 2020. Special Condition for Light Unmanned Aircraft Systems - Medium Risk
[6] EASA Certification and Design Verification Report - UAM Becoming a Reality - Technical Workshop 2b
[8] EASA. 2023. Means of Compliance with Light-UAS.2405
[9] EASA. 2023. Means of Compliance with Light-UAS.2410
[10] EASA. 2023. Means of Compliance with Light-UAS.2510
[11] EASA. 2022. Means of Compliance with Light-UAS.2511
[12] EASA. 2023. Means of Compliance with Light-UAS.2512
[13] EASA. 2023. Means of Compliance with Light-UAS.2615
[14] EASA. 2022. Functional Test Based Means of Compliance with SC Light-UAS
[15] EUROCAE. 2023. ED-325 Vol.1 Guidance Document for Special Condition Light-UAS - Medium Risk - Volume 1

Subscribe to our
Click here to subscribe
Are you looking for a control solution?

Contact us

Contact Us


UAV Navigation is a privately-owned company that has specialized in the design of flight control solutions for Unmanned Aerial Vehicles (UAVs) since 2004. It is used by a variety of Tier 1 aerospace manufacturers in a wide range of UAV - also known as Remotely Piloted Aircraft Systems (RPAS) or 'drones'. These include high-performance tactical unmanned planes, aerial targets, mini-UAVs and helicopters.