On March 26, 2025, the Canadian government published SOR/2025-70 in the Canada Gazette, Part II — the most significant set of amendments to the Canadian Aviation Regulations (CARs) Part IX since the original drone rules took effect in June 2019. These amendments fundamentally reshape how remotely piloted aircraft systems (RPAS) are regulated in Canada, particularly for operators who want to fly beyond visual line of sight (BVLOS).

If you hold a Basic or Advanced RPAS pilot certificate, or if you operate drones commercially in Canada, these changes directly affect you. Here is a plain-language breakdown of what SOR/2025-70 introduces, how the two-phase rollout works, and what documentation you need to stay compliant.

What is SOR/2025-70?

SOR/2025-70 is a statutory order amending the Canadian Aviation Regulations, specifically Part IX (Remotely Piloted Aircraft Systems). The amendments were developed by Transport Canada over several years of consultation with industry stakeholders, drone manufacturers, and provincial regulators. The goal is to create a regulatory pathway for lower-risk BVLOS operations that does not require a Special Flight Operations Certificate (SFOC) — which historically has been the only legal route for flying a drone out of your direct line of sight.

Until now, any BVLOS flight in Canada required an SFOC, which involves a lengthy application process, site-specific approval, and no guarantee of approval. SOR/2025-70 replaces that bottleneck for qualifying operations with a new, certificate-based system.

The Two-Phase Rollout

The amendments are being implemented in two phases to give pilots and organizations time to prepare:

Phase 1 — April 1, 2025

• Expanded Advanced certificate privileges: Advanced RPAS pilot certificate holders can now conduct Extended Visual Line of Sight (EVLOS) operations using a trained Visual Observer (VO), up to 2 nautical miles from the pilot. This was previously SFOC-only territory.
• Sheltered operations: Advanced pilots can now fly near or behind structures (buildings, towers, terrain features) within certain parameters — again, without an SFOC.
• Medium-weight RPAS: The weight categories have been adjusted. Drones between 25 kg and 150 kg now have a clearer regulatory framework under Part IX, rather than being treated as edge cases requiring SFOCs.
• Updated Safety Assurance Declarations: Manufacturers must provide updated declarations of compliance with Standard 922 for any RPAS used in Advanced or higher operations.

Phase 2 — November 4, 2025

• Level 1 Complex (L1C) pilot certification: A brand-new pilot certificate tier that authorizes BVLOS operations for lower-risk profiles. This sits above the Advanced certificate and requires additional training, examination, and a flight review.
• RPAS Operator Certificate (RPOC): Organizations conducting Level 1 Complex operations must obtain an RPOC from Transport Canada. The RPOC requires documented safety management policies, standard operating procedures, maintenance programs, and training records.
• BVLOS without SFOC: Pilots with an L1C certificate, operating under an RPOC, can conduct qualifying BVLOS operations without applying for an SFOC. This is the headline change — it removes the single biggest regulatory barrier to commercial BVLOS in Canada.

Key date: If you plan to conduct BVLOS operations in Canada without an SFOC, you must hold a Level 1 Complex certificate and operate under a valid RPOC by November 4, 2025.

What Changed for Advanced Pilots

Even if you have no immediate plans for BVLOS, the April 1 changes give Advanced certificate holders substantially more operational flexibility:

• EVLOS operations: You can now use a Visual Observer to extend your operational range to 2 NM. The VO must be trained and briefed using a standardized procedure (our EVLOS Visual Observer Briefing Sheet template covers this).
• Sheltered ops: Flying behind buildings, tree lines, or terrain features — common in inspection work — is now explicitly permitted for Advanced pilots under defined conditions.
• Medium RPAS (25–150 kg): If you operate larger survey or inspection drones, these are now covered under Part IX rather than requiring bespoke SFOC applications for every flight.

The Safety Assurance Declaration requirement has been strengthened. Before conducting Advanced operations, you must verify that your RPAS manufacturer has provided a current declaration of compliance with Standard 922. This document should be part of your pre-flight documentation pack.

The New Level 1 Complex Certification

Level 1 Complex (L1C) is an entirely new certification tier. To obtain it, you must:

1. Already hold a valid Advanced RPAS pilot certificate.
2. Complete a minimum of 20 hours of Level 1 Complex ground school training from a Transport Canada-approved provider (TP 15530 training providers).
3. Pass the Level 1 Complex written examination administered by TC or an authorized designate.
4. Successfully complete a flight review with a qualified flight reviewer, demonstrating competence in BVLOS-specific procedures including lost-link protocols, contingency management, and airspace deconfliction.
5. Maintain currency: the L1C certificate requires ongoing recency — you must log a minimum number of BVLOS hours within each 24-month period to maintain privileges.

The L1C certification is specifically designed for "lower-risk" BVLOS — meaning operations in uncontrolled airspace, away from aerodromes, over sparsely populated areas. Higher-risk BVLOS scenarios (urban, near airports, over crowds) will continue to require an SFOC or future regulatory tiers that Transport Canada has indicated are in development.

RPOC Requirements

The RPAS Operator Certificate (RPOC) is mandatory for any organization (corporation, partnership, or sole proprietorship operating commercially) conducting Level 1 Complex operations. Individual recreational pilots do not need an RPOC, but effectively all commercial BVLOS operators will.

To obtain an RPOC, you must submit an application through Transport Canada's Drone Management Portal with the following:

• A complete set of standard operating procedures (SOPs) for each type of BVLOS operation you intend to conduct.
• A safety management system (SMS) that includes hazard identification, risk assessment, and mitigation procedures — aligned with Standard 922 Safety Assurance requirements.
• A maintenance control system for all RPAS in your fleet.
• A pilot training and records management program documenting initial and recurrent training for all pilots operating under the RPOC.
• An emergency response plan covering lost-link scenarios, fly-away procedures, and incident reporting obligations.
• Designation of a responsible person (Operations Manager) who serves as the primary point of contact for TC oversight.

As of the publication date of these amendments, Transport Canada has issued 318 RPOCs to organizations across Canada — largely to those who participated in the pilot program and early-access consultation phases.

Documentation You Need

Whether you are preparing for Phase 1 (April) or Phase 2 (November), here is a practical checklist of the documentation you should have in order:

• Valid pilot certificate (Basic, Advanced, or L1C depending on your operations).
• Current Safety Assurance Declaration (Standard 922) from your RPAS manufacturer.
• Updated pre-flight checklists reflecting the new Advanced privileges (EVLOS, sheltered ops).
• EVLOS Visual Observer briefing sheet and training records (if conducting EVLOS).
• Site survey templates for each operational location.
• Aircraft maintenance logs — TC auditors specifically look for these.
• Flight logs with hours tracked per certificate type.
• RPOC application documentation (if pursuing BVLOS): SOPs, SMS, maintenance program, training records, emergency procedures.

Pro tip: Start assembling your RPOC documentation now, even if you don't plan to apply until November. The application process through the Drone Management Portal can take 60–90 days for review.

What Happens Next

Transport Canada has signalled that SOR/2025-70 is the first phase of a broader BVLOS regulatory framework. Future amendments are expected to address higher-risk BVLOS profiles (urban operations, operations near aerodromes, flights over populated areas), drone delivery frameworks, and integration with manned air traffic. But for now, the Level 1 Complex pathway gives Canadian operators a viable, certificate-based route to BVLOS — something the industry has been requesting since 2019.

The bottom line: if you fly drones commercially in Canada, you need to understand these changes. The operational privileges are significant, but so are the documentation requirements. Getting organized now — not in October — is the smart move.

A Transport Canada RPAS inspection is not a random event for most commercial drone operators — it is an inevitability. Whether it is a scheduled audit triggered by your RPOC application, a field inspection at an active job site, or a complaint-driven investigation, TC inspectors have a clear playbook for what they check and in what order. Understanding that playbook is half the battle.

This guide walks through the typical audit process based on publicly available TC guidance, enforcement data, and the real-world experiences of Canadian operators who have been through inspections. If you are operating commercially under an Advanced certificate or an RPOC, this is what to expect.

How a TC RPAS Audit Typically Begins

Transport Canada inspections generally fall into three categories:

• Scheduled audits: These are planned inspections, typically associated with RPOC holders or organizations that have been flagged for routine oversight. You usually receive advance notice — anywhere from two weeks to 30 days.
• Field inspections: An inspector may visit your operational site unannounced. This is common in areas near aerodromes, controlled airspace, or popular flying locations where complaints have been filed. Field inspectors carry identification and have the authority to request documentation on the spot.
• Complaint-driven investigations: If a member of the public, another pilot, or a Nav Canada controller files a complaint, TC may initiate an investigation. These tend to be more adversarial in nature and may involve formal interviews.

Regardless of the type, the first thing every TC inspector asks for is the same set of core documents. If you cannot produce them promptly, the inspection immediately escalates in severity.

The Documents They Ask For First

TC inspectors follow a structured checklist. Here are the documents they request in order of priority:

1. Pilot certificate: Your Basic, Advanced, or Level 1 Complex certificate. They will verify it against TC's database. Expired or suspended certificates are an immediate violation.
2. RPAS registration: Your drone must be registered with Transport Canada and the registration number must be physically displayed on the aircraft. Missing or illegible markings are one of the most commonly cited violations.
3. Safety Assurance Declaration: For Advanced and L1C operations, you must have a current declaration from the manufacturer confirming compliance with Standard 922. Inspectors ask for this document by name — if you do not know what it is, that is a red flag.
4. Flight logs: TC expects to see a record of your flights including date, location, aircraft used, flight time, and type of operation. There is no prescribed format, but the log must be systematic and retrievable.
5. Maintenance records: For each RPAS in your fleet, inspectors want to see a record of maintenance actions — firmware updates, propeller replacements, battery cycles, and any repairs. "I don't do maintenance" is not an acceptable answer.
6. RPOC documentation (if applicable): If you operate under an RPOC, inspectors will review your standard operating procedures, safety management system, training records, and maintenance control system. They compare what is written in your RPOC application to what you actually do in the field.
7. Pre-flight records: Evidence that you conducted a pre-flight safety check before your flight — weather assessment, NOTAM review, site survey, airspace authorization (if applicable).

The golden rule: if it is not documented, it did not happen. TC inspectors operate on this principle. Verbal assurances carry zero weight in an audit.

Most Common Violations Found

Based on TC enforcement data and industry reports, the most frequently cited violations during RPAS inspections are:

• Missing or expired pilot certificate: Pilots fail to renew their certificate or fly with a suspended certificate unknowingly.
• No registration markings on the aircraft: The registration number must be legible and visible. Stickers that have peeled off or serial numbers written in pen do not pass inspection.
• No flight logs: Surprisingly common. Many commercial operators simply do not keep flight records, or keep them in an informal format that does not include required information.
• No Safety Assurance Declaration: Pilots operating in Advanced category without the manufacturer's Standard 922 declaration. Many pilots do not even know this document exists.
• Operating without proper airspace authorization: Flying in controlled airspace without Nav Canada authorization, or flying near a helipad without proper NOTAMs checked.
• No pre-flight records: No evidence of weather check, NOTAM review, or site survey before the flight.
• RPOC non-conformance: The SOPs in the RPOC application describe one set of procedures, but the operator is doing something different in practice. This is one of the most serious findings because it suggests systemic non-compliance.

Penalties: What's at Stake

Under the updated 2025 enforcement framework, penalties for RPAS violations have increased significantly:

Violation	Individual Fine	Corporate Fine
Flying without valid certificate	Up to $1,000	Up to $5,000
Operating unregistered RPAS	Up to $1,000	Up to $5,000
No Safety Assurance Declaration	Up to $1,000	Up to $5,000
Unauthorized airspace entry	Up to $3,000	Up to $15,000
RPOC non-conformance	Up to $3,000	Up to $25,000
Endangering aviation safety	Up to $5,000	Up to $25,000

For the most serious violations — endangering aviation safety or operating BVLOS without authorization — penalties can reach $5,000 for individuals and $25,000 for corporations. TC can also suspend or revoke your pilot certificate and your RPOC.

How to Be Audit-Ready in Under 30 Minutes

The good news is that audit readiness is a solvable problem. Most violations stem from disorganization, not malice. Here is a practical 30-minute checklist to get yourself inspection-ready:

1. Verify your certificate status (5 min): Log into the TC Drone Management Portal and confirm your certificate is current and not suspended. Print or save a digital copy.
2. Check your registration markings (3 min): Physically inspect every drone you plan to fly. Confirm the registration number is displayed, legible, and securely attached.
3. Locate your Safety Assurance Declaration (5 min): Find the manufacturer's Standard 922 declaration for each aircraft in your fleet. If you do not have one, contact the manufacturer immediately — most major manufacturers (DJI, Autel, senseFly) provide these on request.
4. Update your flight log (10 min): Bring your flight log current. If you have been logging informally, transfer your records into a structured format. Our Flight Log Tracker template handles this automatically.
5. Review maintenance records (5 min): Confirm you have a record for each aircraft covering recent firmware updates, prop changes, battery cycles, and any repairs.
6. Stage your pre-flight kit (2 min): Ensure your pre-flight checklist, site survey template, and emergency procedures card are accessible — either printed in your field kit or available on your phone/tablet.

If you can produce all six categories of documents within 10 minutes of being asked, you are in better shape than 80% of operators TC inspects.

The operators who struggle in audits are not bad pilots — they are disorganized ones. Transport Canada inspectors are professionals who understand that small operations run lean. They are not looking for perfection. They are looking for evidence that you take compliance seriously, that you have a system, and that you follow it. Having organized, up-to-date documentation demonstrates all three.

The RPAS Operator Certificate (RPOC) is Transport Canada's authorization for organizations to conduct Level 1 Complex and BVLOS drone operations. Starting November 4, 2025, any business, government agency, or organization conducting BVLOS flights under the new SOR/2025-70 framework must hold a valid RPOC. There is no exemption for small operators — if you are flying BVLOS commercially, you need one.

As of January 2025, Transport Canada has issued 318 RPOCs to organizations across Canada, primarily through the early-access program that ran during the consultation phase. With the November deadline approaching, a surge of new applications is expected. Here is a complete walkthrough of what you need to apply.

What Exactly Is an RPOC?

An RPOC is an operator-level certificate — it is issued to the organization, not to individual pilots. Think of it as the RPAS equivalent of an Air Operator Certificate (AOC) that manned aviation companies require. The RPOC authorizes the organization to conduct specific types of complex RPAS operations and holds the organization accountable for safety management, pilot training, aircraft maintenance, and operational procedures.

An RPOC does not replace individual pilot certificates. Your pilots still need to hold the appropriate certificate (Advanced or Level 1 Complex) for the operations they conduct. The RPOC is the organizational wrapper that ensures your company has the systems, policies, and oversight in place to support those operations safely.

Who Needs an RPOC?

You need an RPOC if your organization plans to conduct any of the following after November 4, 2025:

• Level 1 Complex (BVLOS) operations under Part IX without an SFOC.
• Operations with medium-weight RPAS (25–150 kg) in certain categories.
• Any complex operation designated by Transport Canada as requiring operator-level oversight.

You do not need an RPOC if you are an individual pilot flying under Basic or Advanced privileges only (VLOS, EVLOS, sheltered ops). Those operations are covered by your individual pilot certificate alone.

Important: Even if you are a sole proprietor, you need an RPOC if you conduct BVLOS commercially. The RPOC is tied to the operating entity, not the number of employees.

The RPOC Application: What TC Requires

The RPOC application is submitted through Transport Canada's Drone Management Portal. The application package must include:

1. Organizational Information

• Legal name, business number, and contact details.
• Designated Operations Manager (the individual responsible for day-to-day compliance — this person must be named and reachable by TC).
• List of all pilots who will operate under the RPOC, with their certificate numbers and types.
• List of all RPAS in the fleet, with registration numbers, make/model, and Standard 922 compliance status.

2. Standard Operating Procedures (SOPs)

• Pre-flight procedures for each operation type.
• In-flight procedures including communication protocols, airspace management, and contingency actions.
• Post-flight procedures including documentation and reporting.
• BVLOS-specific procedures: lost-link protocol, return-to-home procedures, geofence configuration, and mission abort criteria.
• Emergency procedures: fly-away response, controlled crash procedures, and emergency landing site selection.

3. Safety Management System (SMS)

The SMS is the backbone of your RPOC application. Transport Canada evaluates your SMS against Standard 922 Safety Assurance requirements. At minimum, your SMS must include:

• Safety policy statement: Signed by the accountable executive, committing to safety as an organizational priority.
• Hazard identification and risk assessment: A documented process for identifying hazards in your operations and assessing their risk levels.
• Risk mitigation procedures: Specific controls for each identified hazard — not generic statements, but actionable procedures.
• Incident reporting system: A mechanism for pilots and staff to report safety occurrences (incidents, near-misses, hazards) without fear of reprisal.
• Safety assurance: How you monitor and audit your own compliance — internal audits, trend analysis, corrective actions.
• Safety promotion: Training and communication activities that promote safety awareness among your team.

4. Maintenance Control System

• Scheduled maintenance intervals for each RPAS type.
• Record-keeping procedures for all maintenance actions.
• Battery management program (cycle tracking, storage protocols, disposal).
• Firmware update management — how you track and validate firmware updates before operational use.

5. Training and Records Management

• Initial training program for new pilots joining your organization.
• Recurrent training schedule and requirements.
• Currency requirements — minimum flight hours per period for each operation type.
• Records retention policy (TC recommends a minimum of 3 years for all operational records).

Building Your RPOC Policy Manual

The most time-consuming part of the RPOC application is assembling the policy manual — the single document (or set of documents) that contains your SOPs, SMS, maintenance system, and training program. TC reviewers evaluate this manual against a detailed rubric, and incomplete or vague submissions are routinely sent back for revision.

Here are practical tips for building a strong RPOC manual:

• Be specific, not generic. Do not write "we will conduct a risk assessment before each flight." Write "the pilot-in-command will complete Form OPS-03 (Pre-Mission Risk Assessment) identifying at least five hazard categories per Standard 922, Section 4.2, and document mitigation measures before commencing operations."
• Reference the regulations. Tie every procedure back to a specific CAR section, Standard 922 requirement, or SOR/2025-70 provision. TC reviewers expect to see regulatory references throughout your manual.
• Include templates and forms. Attach the actual forms your pilots will use — checklists, log sheets, risk assessment matrices, incident report forms. Reviewers want to see that your system is operationalized, not theoretical.
• Plan for 60–90 days of review. The TC review process takes time. Submit early, expect at least one round of revision requests, and do not schedule BVLOS operations based on an optimistic approval timeline.

If you are starting from scratch, our BVLOS / RPOC Operator Pack includes a complete RPOC policy manual template with all required sections pre-structured and regulatory references embedded. It is the fastest way to get from zero to submission-ready.

After Submission: What to Expect

Once you submit your RPOC application through the Drone Management Portal, Transport Canada assigns a reviewer. The typical process:

1. Initial review (2–4 weeks): TC checks completeness — are all required sections present? Are regulatory references correct?
2. Detailed review (4–6 weeks): A subject matter expert evaluates the substance of your SMS, SOPs, and maintenance system.
3. Revision requests: Most first-time applicants receive at least one request for additional information or clarification. Respond promptly and thoroughly.
4. Approval and issuance: Once satisfied, TC issues the RPOC with specific conditions and limitations. Your RPOC will specify which types of operations you are authorized to conduct.

The RPOC is not a "get it and forget it" document. TC conducts periodic audits of RPOC holders, and you are expected to maintain all systems described in your application as long as the certificate is active. Changes to your operations, fleet, or personnel must be reported to TC and reflected in updated documentation.