Canadian RPAS Regulations

The regulatory landscape for RPAS in Canada is evolving rapidly. Here's the current status and what's coming.

Current Framework: CARs Part IX (June 2019)

The Canadian Aviation Regulations Part IX established the current VLOS framework. These regulations cover:

• Basic operations (micro RPAS under 250g, and small RPAS 250g–25kg in uncontrolled airspace)
• Advanced operations (small RPAS in controlled airspace or near people)
• Pilot certification requirements (Basic or Advanced RPAS Pilot Certificate)
• RPAS registration with Transport Canada
• Visual line-of-sight requirement for all standard operations

Proposed: BVLOS Regulations (CG1, June 2023)

Transport Canada published Canada Gazette Part I (CG1) proposed amendments for BVLOS operations in June 2023. Key elements:

• Low-risk BVLOS in uncontrolled airspace (aligns with RTM-BL designation)
• Risk-based approach using SORA methodology
• RTM Service Provider concept introduced in regulation
• Enhanced pilot certification requirements for BVLOS
• Aircraft capability requirements (DAA, C2 link management)
• Operational constraints based on population density and airspace classification

SFOC Process

A Special Flight Operations Certificate (SFOC) allows operations outside standard CARs Part IX permissions — including BVLOS flights. The current SFOC process:

1. Operator prepares a detailed safety case
2. Submission to Transport Canada regional office
3. Review process (can take weeks to months)
4. Certificate issued with specific conditions and limitations

The ConOps envisions rFIMS streamlining this process by providing standardized risk assessment tools and automated validation, reducing approval times significantly.

RPAS Operating Certificate (ROC)

The proposed regulations introduce the concept of an RPAS Operating Certificate (ROC) — a standing authorization for organizations to conduct specific types of operations, similar to an Air Operator Certificate for crewed aviation.

An ROC would cover:

• Approved operation types and risk levels
• Organizational safety management system requirements
• Personnel qualifications and training
• Aircraft maintenance and airworthiness standards
• Insurance and liability requirements

SORA Risk Assessment (AC 903-001)

The Specific Operations Risk Assessment (SORA) is the risk methodology adopted by Transport Canada for BVLOS operations. Advisory Circular AC 903-001 provides Canadian guidance on:

• Ground Risk Class (GRC) — risk to people on the ground
• Air Risk Class (ARC) — risk of collision with other aircraft
• SAIL (Specific Assurance and Integrity Level) — combined risk level
• OSOs (Operational Safety Objectives) — mitigations required for each SAIL level

SORA is central to the RTM framework because each airspace designation (RTM-VU through RTM-R) maps to specific risk levels and required mitigations.

Future Rulemaking Priorities

Based on the ConOps and regulatory signals, anticipated future rulemaking includes:

• RTM airspace volume establishment and management procedures
• RSP certification standards and requirements
• rFIMS operational standards (performance, availability, security)
• Medium and high-risk BVLOS regulations (RTM-S, RTM-C, RTM-N)
• Non-cooperative surveillance requirements (RTM-N)
• Urban air mobility integration pathways

Key Regulatory Bodies

Check Transport Canada and NAV CANADA for the latest regulatory updates.