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UAS.OPEN.020 UAS operations in subcategory A1

Annex to Implementing Regulation (EU) 2019/947 — UAS OPERATIONS IN THE ‘OPEN’ AND ‘SPECIFIC’ CATEGORIES · Regulations (EU) 2019/947 and 2019/945 · EAR revision 29 Jun 2026

IRImplementing rule

UAS.OPEN.020UAS operations in subcategory A1

UAS operations in subcategory A1 shall comply with all of the following conditions:

(1)for unmanned aircraft referred to in point (5)(d), be conducted in such a way that a remote pilot of the unmanned aircraft does not overfly assemblies of people and reasonably expects that no uninvolved person will be overflown. In the event of unexpected overflight of uninvolved persons, the remote pilot shall reduce as much as possible the time during which the unmanned aircraft overflies those persons;

(2)in the case of an unmanned aircraft referred to in points (5)(a), (5)(b) and (5)(c), be conducted in such a way that the remote pilot of the unmanned aircraft may overfly uninvolved persons, but shall never overfly assemblies of people;

(3)by way of derogation from point (d) of paragraph 1 of Article 4, be conducted, when the follow-me mode is active, up to a distance of 50 metres from the remote pilot;

(4)be performed by a remote pilot who:

(a)is familiar with manufacturer’s instructions provided by the manufacturer of the UAS;

(b)in the case of an unmanned aircraft class C1, as defined in Part 2 of the Annex to Delegated Regulation (EU) 2019/945, has completed an online training course followed by completing successfully an online theoretical knowledge examination provided by the competent authority or by an entity designated by the competent authority of a Member State achieving at least 75% of the overall marks. The examination shall comprise 40 multiple-choice questions distributed appropriately across the following subjects: air safety; airspace restrictions; aviation regulation; human performance limitations; operational procedures; UAS general knowledge; privacy and data protection; insurance; security.

(5)be performed with an unmanned aircraft that:

(a)has an MTOM, including payload, of less than 250 g and a maximum operating speed of less than 19 m/s, in the case of a privately built UAS; or

(b)meets the requirements defined in point (a) of Article 20;

(c)is marked as class C0 and complies with the requirements of that class, as defined in Part 1 of the Annex to Delegated Regulation (EU) 2019/945; or

(d)is marked as class C1 and complies with the requirements of that class, as defined in Part 2 of the Annex to Delegated Regulation (EU) 2019/945 and is operated with active and updated direct remote identification system and geo-awareness function.

IR · UAS.OPEN.020 — Regulations (EU) 2019/947 and 2019/945 · Regulation (EU) 2020/639 · UAS Easy Access Rules · EAR revision 29 Jun 2026

AMCAcceptable means of compliance

AMC1 UAS.OPEN.020(1)and (2) UAS operations in subcategory A1

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OPERATIONAL LIMITATIONS IN SUBCATEGORY A1 As a principle, the rules prohibit overflying assemblies of people. Overflying isolated people is possible, but there is a distinction between class C1 and class C0 UAS or privately built UAS with MTOMs of less than 250 g.

(a)For UAS in class C1, before starting the UAS operation, the remote pilot should assess the area and should reasonably expect that no uninvolved person will be overflown. This evaluation should be made taking into account the configuration of the site of operation (e.g. the existence of roads, streets, pedestrian or bicycle paths), and the possibility to secure the site and the time of the day. In case of an unexpected overflight, the remote pilot should reduce as much as possible the duration of the overflight, for example, by flying the UAS in such a way that the distance between the UA and the uninvolved people increases, or by positioning the UAS over a place where there are no uninvolved people. [Figure or form omitted from this preview — available in the Avioverse workspace library.]

(b)It is accepted that UAS in class C0 or privately built UAS with MTOMs less than 250 g may fly over uninvolved people; however, this should be avoided whenever possible, and where it is unavoidable, extreme caution should be used.

AMC · AMC1 UAS.OPEN.020(1) — Regulations (EU) 2019/947 and 2019/945 · ED Decision 2019/021/R · UAS Easy Access Rules · EAR revision 29 Jun 2026

AMCAcceptable means of compliance

AMC1 UAS.OPEN.020(4)(b)and UAS.OPEN.040(3) UAS operations in subcategories A1 and A3

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THEORETICAL KNOWLEDGE SUBJECTS FOR BASIC ONLINE THEORETICAL KNOWLEGDE TRAINING COURSES AND THEORETICAL KNOWLEGDE EXAMINATIONS FOR SUBCATEGORIES A1 AND A3 The acquisition of theoretical knowledge by the remote pilot should cover at least the following theoretical knowledge subjects:

(a)Air safety:

(1)non-reckless behaviour, safety precautions for UAS operations and basic requirements regarding dangerous goods;

(2)starting or stopping the operations taking into account environmental factors, UAS conditions and limitations, remote pilot limitations and human factors;

(3)operation in visual line of sight (VLOS) and in very low level (VLL), which entails:

(i)keeping a safe distance from people, animals, property, vehicles, and other airspace users;

(ii)the identification of assemblies of people;

(iii)a code of conduct in case the UA encounters other traffic;

(iv)respecting the height limitation; and

(v)when using a UA observer, the responsibilities and communication between the UA observer and the remote pilot; and

(4)familiarisation with the operating environment, in particular:

(i)how to perform the evaluations of the presence of uninvolved person in the overflown area as required in UAS.OPEN.020(1) and UAS.OPEN.040(1); and

(ii)informing the people involved;

(b)Airspace restrictions:

(1)obtain and observe updated information about any flight restrictions or conditions published by the MS according to Article 15 of the UAS Regulation;

(2)describe the types of geographical zones and the procedures for receiving a flight authorisation; and

(3)upload the geographical zones onto the geo-awareness system;

(c)Aviation regulations:

(1)Introduction to EASA and the aviation system;

(2)Regulation (EU) 2019/945 and Regulation (EU) 2019/947:

(i)their applicability to EU MSs;

(ii)subcategories in the ‘open’ category and the associated classes of UAS;

(iii)registration of UAS operators;

(iv)the responsibilities of the UAS operator;

(v)the responsibilities of the remote pilot; and

(vi)incident – accident reporting;

(d)Human performance limitations:

(1)the influence of psychoactive substances or alcohol or when the remote pilot is unfit to perform their tasks due to injury, fatigue, medication, sickness or other causes;

(2)human perception:

(i)factors influencing VLOS;

(ii)the distance of obstacles and the distance between the UA and obstacles;

(iii)evaluation of the speed of the UA;

(iv)evaluation of the height of the UA;

(v)situational awareness; and

(vi)night operations.

(e)Operational procedures:

(1)pre-flight:

(i)assessment of the area of operation and the surrounding area, including the terrain and potential obstacles and obstructions for keeping VLOS of the UA, potential overflight above uninvolved persons, and the potential overflight above critical infrastructure;

(ii)identification of a safe area where the remote pilot can perform a practice flight;

(iii)environmental and weather conditions (e.g. factors that can affect the performance of the UAS such as electromagnetic interference, wind, temperature, etc.); methods of obtaining weather forecasts; and

(iv)checking the condition of the UAS;

(2)in-flight:

(i)normal procedures;

(ii)determine the UA’s attitude, altitude, and direction of flight;

(iii)observe the airspace for other air traffic or hazards;

(iv)determine that the UA does not pose a danger for the life or property of other people; and

(v)contingency and emergency procedures for abnormal situations:

(a)managing the UAS flight path in abnormal situations;

(b)managing the situation when the UAS positioning equipment is impaired;

(c)managing the situation of incursion of a person into the area of operation, and taking appropriate measures to maintain safety;

(d)managing the exit from the area of operation as defined during the flight preparation;

(e)managing the situation when a manned aircraft flies near the area of operation;

(f)managing the incursion of another UAS into the area of operation;

(g)dealing with a situation of a loss of attitude or position control caused by external phenomena; and

(h)following the C2 loss-of-link procedure;

(3)post-flight:

(i)maintenance; and

(ii)logging of flight details;

(f)UAS general knowledge:

(1)basic principles of flight;

(2)the effect of environmental conditions on the performance of the UAS;

(3)principles of command and control:

(i)overview;

(ii)data link frequencies and spectrums; and

(iii)automatic flight modes, override and manual intervention;

(4)familiarisation with the instructions provided by the user’s manual of a UAS, and in particular with regard to:

(i)overview of the main elements of the UAS;

(ii)limitations (e.g. mass, speed, environmental, duration of battery, etc.);

(iii)controlling the UAS in all phases of flights (e.g. the take-off, hovering in mid-air, when applicable, flying basic patterns and landing);

(iv)features that affect the safety of flight;

(v)setting the parameters of the lost link procedures;

(vi)setting the maximum height;

(vii)procedures to load geographical zone data into the geo-awareness system;

(viii)procedures to load the UAS operator registration number into the direct remote identification system;

(ix)safety considerations:

(A)instructions to secure the payload;

(B)precautions to avoid injuries from rotors and sharp edges; and

(C)the safe handling of batteries;

(x)Maintenance instructions:

(g)Privacy and data protection:

(1)understanding the risk posed to privacy and data protection; and

(2)the guiding principles for data protection under the GDPR;

(h)Insurance:

(1)liability in case of an accident or incident;

(2)general knowledge of the EU regulations; and

(3)awareness of the possible different national requirements for insurance in the MSs.

(i)Security:

(1)an understanding of the security risk;

(2)an overview of the EU regulations;

(3)awareness of the possible different national requirements for security in the MSs.

AMC · AMC1 UAS.OPEN.020(4)(b) — Regulations (EU) 2019/947 and 2019/945 · ED Decision 2022/002/R · UAS Easy Access Rules · EAR revision 29 Jun 2026

AMCAcceptable means of compliance

AMC2 UAS.OPEN.020(4)(b)and UAS.OPEN.040(3) UAS operations in subcategories A1 and A3

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PROOF OF COMPLETION OF THE ONLINE THEORETICAL KNOWLEGDE TRAINING COURSE AND SUCCESSFUL COMPLETION OF THE ONLINE THEORETICAL KNOWLEGDE EXAMINATION Upon receipt of the proof that a remote pilot has successfully completed the online theoretical knowledge training course and the online theoretical knowledge examination, the competent authority should provide a proof of completion to the remote pilot in the format that is depicted in the figure below. An entity that is designated by the competent authority may issue the certificate on behalf of the competent authority. The proof may be provided in electronic form.

[Figure or form omitted from this preview — available in the Avioverse workspace library.]

The remote pilot identification number that is provided by the competent authority or the entity that is designated by the competent authority that issues the proof of completion should have the following format: NNN-RP-xxxxxxxxxxxx Where: ‘NNN’ is the ISO 3166 Alpha-3 code of the MS that issues the proof of completion; ‘RP’ is a fixed field meaning ‘remote pilot’; and ‘xxxxxxxxxxxx’ are 12 alphanumeric characters (lower-case only) defined by the competent authority or the entity that is designated by the competent authority that issues the proof of completion. Example: (FIN-RP-123456789abc) The QR code provided a link to the national database where the information related to the remote pilot is stored. Through the ‘remote pilot identification number’, all information related to the training of the remote pilot can be retrieved by authorised bodies (e.g. competent authorities, law enforcement authorities, etc.) and authorised personnel.

AMC · AMC2 UAS.OPEN.020(4)(b) — Regulations (EU) 2019/947 and 2019/945 · ED Decision 2022/002/R · UAS Easy Access Rules · EAR revision 29 Jun 2026

AMCAcceptable means of compliance

AMC1 UAS.OPEN.020(5)(c)and (d), UAS.OPEN.030(3) and UAS.OPEN.040(4)(c),(d) and (e) UAS operations in subcategories A1, A2 and A3

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MODIFICATION OF A UAS WITH A CLASS IDENTIFICATION LABEL When placing UASs with a class identification label on the market, manufacturers should ensure the compliance of those UASs with the applicable regulatory requirements. It is the responsibility of UAS operators to ensure that those UASs remain compliant throughout their lifetime. UAS operators should, therefore, not make any modifications to a UAS in class C0, C1, C2, C3 or C4 that breach compliance with the product requirements, unless the modification is foreseen by the manufacturer and documented in the manufacturer’s instructions. The replacement of a part by a similar one for maintenance purposes is not considered a modification, provided the operator uses an original part or a part that complies with the characteristics defined by the manufacturer in the list of replaceable parts provided in the manufacturer’s instructions. The affixation of payload is not considered a modification provided that affixing a payload is not forbidden by the manufacturer and the payload complies with the characteristics provided in the manufacturer’s instructions. Affixing a payload when it is forbidden by the manufacturer or affixing a payload that does not comply with the characteristics provided in the manufacturer’s instructions is strictly forbidden. If the payload does not comply with the characteristics of the allowed payloads or if maintenance is not performed according to the manufacturer’s instructions, it is then considered a modification that invalidates the class conformity. The class identification label must be removed from the UAS identification label and the modified UAS may only be operated in the ‘specific’ category in accordance with Subpart B of Annex to the UAS Regulation. Changes to UASs with a class identification label C4 are allowed, and such UASs can be considered ‘privately built’ UASs and continue to be operated in subcategory A3 of the ‘open’ category.

AMC · AMC1 UAS.OPEN.020(5)(c) — Regulations (EU) 2019/947 and 2019/945 · ED Decision 2022/002/R · UAS Easy Access Rules · EAR revision 29 Jun 2026

GMGuidance material

GM1 UAS.OPEN.020(5)(c)and (d), UAS.OPEN.030(3) and UAS.OPEN.040(4)(c), (d) and (e) UAS operations in subcategories A1, A2 and A3

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MODIFICATION OF A UAS WITH A CE CLASS MARK Modifications to UAS that breach compliance with the requirements for the CE marking are those that affect the weight or performance so that they are outside the specifications or the instructions provided by the manufacturer in the user manual. A replacement of a part with another that has the same physical and functional characteristics is not considered to be a breach of the requirements for the CE marking (e.g. a replacement of a propeller with another of the same design). The UA user manual should define instructions for performing maintenance and applying changes that do not breach compliance with the CE marking requirements.

GM · GM1 UAS.OPEN.020(5)(c) — Regulations (EU) 2019/947 and 2019/945 · ED Decision 2019/021/R · UAS Easy Access Rules · EAR revision 29 Jun 2026

All rules in PART A — UAS OPERATIONS IN THE ‘OPEN’ CATEGORY

Consolidated from the EASA Easy Access Rules (revision 29 Jun 2026, extracted 17 Aug 2026) for convenience. Not the official publication — verify against the Official Journal of the European Union and the EASA publications before operational use.

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