Streamlining Specific Category UAS operations: The CAA trials LUC pathway

The CAA is preparing to run a year-long trial of an alternative regulatory framework for Unmanned Aircraft Systems (“UAS”). The framework to be trialled is a Light UAS Operator Certificate (“LUC”) for UAS operators undertaking Specific Category activities and is therefore relevant to many commercial organisations using UAS as part of their operations. The LUC concept would provide an alternative pathway for certain operators by ‘granting privileges based on organisational competence rather than requiring case-by-case approvals by the CAA’, and has the potential to dramatically reduce the administrative burden faced by commercial UAS operators. 

The LUC trial will be limited to a select number of organisations who respond to the CAA’s current call for applications. The application window closes on 26 March 2026. 

Current categories – UAS operations

The UK’s current drone regime relies on a structured classification of operations set out in UK Regulation (EU) 2019/947 and a requirement for individual authorisations in higher-risk scenarios. UAS activities currently fall into one of three categories:

1. Open Category – basic, low risk flying (e.g. casual flying of most consumer drones). 

   This requires only operator competency and basic registration (e.g. Flyer ID and Operator ID). 

2. Specific Category – moderate risk flying (e.g. construction mapping within 50 metres of buildings / people). 

   This requires a detailed safety assessment and Operational Authorisation by the CAA. 

3. Certified Category – complex, high-risk flying (e.g. carrying dangerous goods).

   Stringent requirements apply, including licensing of pilots and operator certification. 

The LUC concept will apply to the Specific Category only.

Specific Category Authorisations

For activities falling into this category, operators must currently submit a UK Specific Operations Risk Assessment (“SORA”) for approval by the CAA. These applications are assessed on a case-by-case basis. Operators are required to apply individually for each UAS activity. 

Examples of operations requiring this authorisation include: (i) dropping items from a drone; (ii) flying close to people with aircraft that weigh 500g or more; and (iii) flying close to crowds.[1]

The SORA application process can be resource intensive and time-consuming, for operators and the CAA alike. 

The LUC trial

The LUC framework would allow qualifying organisations to operate certain drones in the Specific Category without needing to obtain a separate authorisation for each flight or specific operation. Instead, an organisation’s internal safety, competence and systems would form the basis for privileges granted under the LUC, meaning that an approved operator would only need to satisfy a single assessment rather than make repetitive applications.

The ultimate objective of the trial is to assess whether safety outcomes and compliance can be maintained under this model, and whether the approach is scalable for broader regulatory adoption. This will include consideration of whether the LUC pathway is viable as an alternative to case-by-case approvals for UAS operations, as well as of any lessons learned in terms of how the LUC pathway could be integrated alongside the existing risk assessment methodology for Specific Category operations.

Who are the CAA looking for?

The CAA intends to run the trial with a maximum of five organisations. It has set out its criteria for potential applicants in CAP3221. In general, the CAA is interested in applications from UAS operators that can clearly demonstrate their ability to manage UAS operational risk, including within the context of blended operations involving crewed and uncrewed aircraft. More specifically, the CAA is seeking applications from operators that fulfill the following conditions:

1. Possess a current Air Operator Certificate.
2. Possess a current Operational Authorisation for UAS operations, or have held one within the preceding 12 months.
3. Demonstrate the ability to identify and mitigate UAS-specific risk through deployment of a Safety Management System.
4. Demonstrate organisational competence to manage UAS operations (including training, maintenance, compliance and crew competence).

To participate in the pathway, applicants also need to be able to comply with specific sections of UK Regulation (EU) 2019/947: specifically, Article 11 and the operational requirements relating to LUC holders located in Part C of the Regulation (i.e., UAS.LUC.020, UAS.LUC.030 and UAS.LUC.040).

Impact

The LUC trial has the potential to supercharge commercial UAS operations in the UK by substantially reducing the bureaucratic burden and regulatory friction experienced by UAS operators, while simultaneously increasing the opportunity for operational flexibility.

Meanwhile, if successful, the LUC trial could also free up the CAA to deploy additional resources in other important areas, including the oversight of organisational systems rather than individual flight approvals. 

Conclusion

The scope of the ‘commercial drone opportunity’ was noted as potentially contributing £45 billion to the UK economy by 2030 in the UK Government’s 2022 ambition statement.[2] The LUC trial is emblematic of the UK Government’s desire to capitalise on this opportunity and harness the potential for growth without compromising on the high safety standards achieved through effective regulation. 

For operators considering participation, the trial offers an early opportunity to have critical input on the future UK drone regulation. However, the selective nature of the trial means that any operator hoping to participate will need to be capable of demonstrating high standards of organisational competence and internal governance, and will need to do so quickly.

If you would like further information about the LUC trial, including how to participate, or on the regulation of UAS operations more generally, please contact Chloe Challinor, Patrick Bettle, or your usual contact in the Burges Salmon aviation team.

This article was written by Patrick Bettle and William Bainbridge.