CAP3105: Understand the CAA's recommendations for the Open Category. UK Class Marking.

The CAA published today CAP3105, which details its recommendations to the Department for Transport following the analysis of the responses to its consultation held back in 2023 on UK UAS Regulation Review (CAP2610).

This package of recommendations is significant because it signals officially what should happen in the Open Category in the UK after the transition period is over on1st of January 2026 .

Introduction of UK Class Marking

In a nutshell, the CAA recommends to move forward with class marking, developing its own label UK0, UK1, UK2 etc. But European Class C0, C1, C2 etc would be accepted as of 1st of January 2026 and until 1st of January 2028, at which point the UK marking should be sufficiently in place. The CAA reserves its right to diverge from EASA Class Marking, but in absence of good reasons to do so, we suspect that EU class marked drones will be reviewed swiftly and essentially receive a UKx label accordingly.

Clarifications and Simplifications

The UAS Regulation Review brings other simplifications and clarifications, such as labelling the operational subcategories ‘Over people (A1)’, ‘Near people (A2)’, and ‘Far from people (A3)’, so that sub-category names are more intuitive and descriptive for UAS users.

See below our understanding of the CAA's key recommendations in CAP3105, in a simplifying table:

Introduction of Remote ID and Geoawareness functionalities

Remote ID, in the form of Direct Remote ID first then Hybrid RID, is introduced. Remote ID is already a requirement in the USA and in Europe, that should not cause any issues to drone manufacturers. Reports suggest that Remote ID does not work very well, and malevolent individuals find a way to circumvent it. But we need to start the journey of the digital ID, to facilitate law enforcement, typically during events, around critical infrastructures and airports.

In summary, our understanding of CAP3105 in a simplifying table

Next Steps - from a legislative point of view

The Department for Transport will consider whether to implement the proposed changes. If the DfT chooses to take forward the proposals, changes to the relevant regulations will be progressed through a statutory instrument. The timetable for this statutory instrument may be unpredictable as it depends on DfT and the government's legislative agenda and priorities.

Impact for the UK drone industry

This proposed expansion of the Open Category will benefit industry growth. The A1 and A2 subcategories as they stand today are not very useful due to their operational constraints. The introduction of class marking, meaning a level of validation of the UAS' robustness and safety, enables to unlock those operational constraints.

If indeed A1 and A2 are implemented as we understand it in the table above, we can assume that many current PDRA01 holders in the specific category will find A1 and A2 a simpler regulatory framework to conduct their routine operations.