{"id":"F2025L01210","name":"CASA EX88/25 — Indoor Operation of RPA Near People and BVLOS (Training and Use) Exemption 2025","slug":"casa-ex88-25-indoor-operation-of-rpa-near-people-and-bvlos-training-and-use-exemption-2025","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":107273,"registerId":"commonwealth-F2025L01210-current","compilationNumber":null,"startDate":"2026-04-03","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"CASA EX88/25 — Indoor Operation of RPA Near People and BVLOS (Training and Use) Exemption 2025","content":"Instrument number CASA EX88/25\n\nI, steven James campbell, Executive Manager, National Operations & Standards, a delegate of CASA, make this instrument under regulations 11.160 and 11.205 of the Civil Aviation Safety Regulations 1998.\n\n\\[Signed S. Campbell\\]\n\nSteven Campbell  \nExecutive Manager, National Operations & Standards\n\n29 September 2025\n\nCASA EX88/25 — Indoor Operation of RPA Near People and BVLOS (Training and Use) Exemption 2025\n\n1 Name of instrument\n\nThis instrument is CASA EX88/25 — Indoor Operation of RPA Near People and BVLOS (Training and Use) Exemption 2025.\n\n2 Duration\n\nThis instrument:\n\n(a) commences on 1 October 2025; and\n\n(b) is repealed at the end of 30 September 2028.\n\n3 Definitions, etc.\n\n(1) In this instrument, unless the contrary intention appears:\n\n> BVLOS: see subsection (2).\n\n> CASR means the Civil Aviation Safety Regulations 1998.\n\n> documented practices and procedures has the meaning given by the Part 101 Manual of Standards.\n\n> Note Documented practices and procedures must be approved by CASA. If a further change is required after such an approval has been given, the documented practices and procedures must be reapproved if they are to comply with the definition.\n\n> emergency service RPA operation, or ESRO, means an operation by an emergency service RPA operator involving an RPA that is for:\n\n(a) law enforcement purposes using the RPA; or\n\n(b) the purpose of saving or protecting persons or property using the RPA.\n\n> emergency service RPA operator means one of the following organisations, that is an RPA operator that may lawfully conduct an ESRO:\n\n(a) a police force or service;\n\n(b) the Australian Defence Force;\n\n(c) the Australian Maritime Safety Authority;\n\n(d) the Australian Border Force;\n\n(e) a State or Territory fire service;\n\n(f) a State or Territory emergency service;\n\n(g) a State or Territory parks, wildlife, or forestry service;\n\n(h) a State, Territory or Commonwealth lifeguard service.\n\n> ESRO: see the definition of emergency service RPA operation.\n\n> internal operation means the operation of an RPA within a building, a structure, a naturally occurring space, or another space created by human effort (the internal place) and within 30 m of a person, whether or not it is physically impossible for the RPA to escape and fly away from the internal place if the RPA is no longer under the control of the remote pilot operating the RPA. An internal operation includes a transit operation.\n\n> internal place has the same meaning as in the definition of internal operation.\n\n> police force or service means a police force or a police service, for the Commonwealth, a State or a Territory, that is:\n\n(a) established by or under an Act of the Commonwealth Parliament, the State Parliament or the Territory Legislative Assembly; and\n\n(b) the holder of remotely piloted aircraft operator certificate under Part 101 of CASR.\n\n> police officer means a sworn member of a police force or service.\n\n> relevant operation means the use of an RPA in an internal operation for the purpose of an ESRO.\n\n> relevant RPA, or RPA, means a micro RPA, or a very small RPA whose gross weight does not exceed 1 050 g.\n\n> remote pilot means a police officer (in the case of a police force or service), or an employee or member of an emergency service RPA operator that is not a police force or service, who:\n\n(a) is:\n\n(i) the holder of a remote pilot licence; or\n\n(ii) a person who is taken to hold a remote pilot licence under subregulation 202.461(3) of CASR; and\n\n(b) is the pilot in control of a relevant RPA; and\n\n(c) is acting at the direction of their RPA operator in a relevant operation; and\n\n(d) has such other qualifications and experience relevant to internal operations as must be specified in the documented practice and procedures of the emergency service RPA operator.\n\n> Note: RPA operator means an emergency service RPA operator that is the holder of a remotely piloted aircraft operator’s certificate issued by CASA.\n\n> shield means a solid physical barrier (other than a moving vehicle) that:\n\n(a) lies between a person and a relevant RPA in flight or in the hover under this instrument; and\n\n(b) is not moving or flexing in any direction; and\n\n(c) is of such dimensions, structure, strength and substance as to prevent:\n\n(i) the RPA from impacting any person; and\n\n(ii) any debris resulting from an impact of the RPA with the barrier from impacting any person; and\n\n(d) is not likely to lose any of the characteristics mentioned in paragraphs (a) to (c) during the course of an RPA operation.\n\n> Note The shield must be appropriate to withstand the particular impact of the RPA that is being operated in the relevant operation.\n\n> shielded operation means a relevant operation in which no unshielded persons are involved.\n\n> transit operation means the operation of a relevant RPA, in the open air, solely for the purpose of the RPA:\n\n(a) approaching and entering an internal place from a predetermined point; or\n\n(b) departing from the internal place to a predetermined point.\n\n> unshielded person means a person who is not protected by a shield from impact by an RPA in a relevant operation.\n\n(2) In this instrument, an RPA is operated beyond visual line of sight (BVLOS) of the person operating the RPA if it is not operated within the visual line of sight of the person.\n\n(3) In this instrument, unless the contrary intention appears, terms and expressions that are not otherwise defined in this section, have the same meaning as they have in or under the Civil Aviation Act 1988 and its regulations.\n\n4 Application and non-application\n\n(1) This instrument applies, according to its terms, to each of the following for a relevant operation:\n\n(a) an RPA operator;\n\n(b) the RPA operator’s remote pilot.\n\n(2) This instrument applies to training for an emergency service RPA operation as if the training were an emergency service RPA operation.\n\n5 Exemptions\n\n(1) When conducting a relevant operation, an RPA operator and the remote pilot are each exempted from compliance with the following provisions of Part 101 of CASR, as applicable:\n\n(a) regulation 101.073 (for BVLOS);\n\n(b) regulation 101.095 (for weather, and day only, limitations);\n\n(c) regulation 101.245 (for operations near people);\n\n(d) regulation 101.280 (for operations over a populous area);\n\n(e) paragraph 101.300(4)(b) (for certain remote pilot licence conditions);\n\n(f) subregulation 101.300(6), but only in respect of paragraph 101.300(4)(b) (concerning offences).\n\n(2) Each exemption of an RPA operator and their remote pilot under subsection (1) is subject to each condition mentioned in Schedule 1.\n\nSchedule 1 Conditions\n\n1 General\n\nTo have the benefit of an exemption under this instrument, it is a condition that each requirement mentioned in this Schedule must be complied with for the relevant operation.\n\n2 Risk assessment\n\n2.1 Before a relevant operation is conducted, a risk assessment must be carried out in accordance with the RPA operator’s documented practices and procedures.\n\n2.2 The risk assessment must take into account all factors that may cause the relevant RPA to impact on a person or property, including:\n\n(a) the causes and consequences of possible RPA mode interruption, malfunction or failure; and\n\n(b) the possibility that an RPA speed increase may be required in accordance with paragraph 4.5(b).\n\n2.3 A relevant operation must not commence unless:\n\n(a) the risk of serious injury to a person is assessed as being so low that there is minimal probability of it occurring; and\n\n(b) the risk of damage to any property is assessed as being as low as reasonably practicable in the circumstances.\n\n3 RPA not for use of force\n\nThe RPA must not be used by a remote pilot as a use of force.\n\n4 RPA flight near a person\n\n4.1 The RPA may be operated within 30 m of a person provided that the RPA:\n\n(a) comes no closer than 1 m from the person; and\n\n(b) is operated at the slowest practicable speed, including use of the hover, that is consistent with achieving a successful outcome to the operation; and\n\n(c) only moves in a direction where the remote pilot has visibility of the area in the direction of travel, whether that visibility is obtained through the remote pilot’s own eyes, the use of an observer, or the use of live electronic images available to the remote pilot; and\n\n> Note Natural visibility may require, for example, adequate artificial illumination or suitable atmospheric conditions. Visibility in the form of live electronic images may include, for example, CCTV in the internal place or clear thermal or infrared images from the RPA.\n\n(d) does not exceed the speed limitations or height restrictions specified in this clause; and\n\n(e) for an operation involving an unshielded person — has no exposed rotating parts that could lacerate human skin upon impact.\n\n> Note For an ESRO that is a shielded operation, there are no requirements that the RPA have no exposed rotating parts that could lacerate human skin upon impact. However, CASA strongly recommends that, as far as practicable, for all ERSOs, the RPA have no exposed rotating parts that could lacerate human skin upon impact.\n\n4.2 Without affecting the requirements of subclause 4.4, before a relevant operation commences, the RPA flight controller must be set:\n\n(a) to limit the maximum speed of the RPA to 5 m/sec; and\n\n(b) in such a manner that only an intentional and deliberate overriding action by the remote pilot could cause that maximum speed to be exceeded.\n\n> Note For example, such an action may be activation of a mode change switch. To avoid doubt, subclause 4.2 applies even in the event of a failure of the RPA’s GNSS positioning system.\n\n4.3 For an ESRO that is a shielded operation, the speed limitation of the RPA is 5 m/sec, with a height restriction of 3 m.\n\n> Note But paragraphs 4.1(a), (b) and (c) still apply to a shielded operation.\n\n4.4 For an ESRO involving any unshielded person, the speed limitations and the height restrictions for this clause are set out in Table 4.4.\n\nTable 4.4 — For unshielded persons\n\n| Item |                 | Less than 30 m but not less than 5 m | Less than 5 m but not less than 1 m |\n| ---- | --------------- | ------------------------------------ | ----------------------------------- |\n| 1    | Speed           | Up to 3 m/sec                        | Up to 1.5 m/sec                     |\n| 2    | Increased speed | Up to 5 m/sec                        | The speed may not be increased      |\n| 3    | Height          | Up to 5 m                            | Up to 3 m                           |\n\n4.5 For subclause 4.4, when operating an RPA within the distance from a person mentioned in a column of Table 4.4:\n\n(a) the speed of the RPA must not exceed the speed mentioned in item 1 of the column; and\n\n(b) the speed of the RPA may be increased up to the applicable increased speed mentioned in item 2 of the column — but only if the risk assessment has covered the safety implications of the increased speed; and\n\n(c) the height of the RPA above the ground or floor of the internal place must not exceed the applicable height mentioned in item 3 of the column.\n\n4.6 There must be no continuous overflight of any person or moving vehicle.\n\n5 Transit operations\n\nFor a transit operation, the RPA must not be flown at a height greater than the height of the tallest structure within 150 m horizontally of the RPA.\n\n6 Practices and procedures\n\n6.1 The RPA operator’s documented practices and procedures must include the following:\n\n(a) a schedule of the RPA to be used for relevant operations, which includes details of the following:\n\n(i) the make and model of each RPA;\n\n(ii) the configuration of each RPA;\n\n(iii) confirmation of the gross weight of each RPA;\n\n(iv) the failsafe method by which, when required, no exposed rotating parts of the RPA could lacerate human skin upon impact;\n\n(b) if RPA speed and height restrictions are used to meet the requirements under clause 4 — instructions for the remote pilot and any other operating crew to ensure compliance with the requirements;\n\n(c) details of how a shield is assessed as fit for purpose in a proposed relevant operation;\n\n(d) both:\n\n(i) details of how the remote pilot will monitor the control link integrity for the RPA; and\n\n(ii) the procedures for loss of link;\n\n(e) procedures for the training and testing of relevant individuals in relation to conducting a relevant operation;\n\n(f) procedures for making and retaining records of the matters mentioned in paragraph (e);\n\n(g) how, for all for relevant operations, risk assessments are to be conducted, documented, made available to relevant individuals, and retained;\n\n(h) abnormal operating procedures related to internal operations;\n\n(i) a copy of this exemption instrument.\n\n6.2 A relevant operation must be conducted in accordance with the RPA operator’s documented practices and procedures.\n\n6.3 The RPA operator must not conduct an ESRO unless CASA has approved the RPA operator’s documented practices and procedures in respect of the ESRO.\n\n6.4 In the event of conflict or inconsistency between anything in this instrument and the documented practices and procedures, this instrument prevails.\n\n7 Data collection and reporting to CASA\n\nIf an RPA impacts a person or damages any property during a relevant operation, the RPA operator must give details of the operation to CASA within 72 hours of completion of the operation.\n\n8 CASA observers\n\nAn RPA operator that has used, or that intends to use, this instrument must make arrangements, on written request by an Executive Manager of CASA, for a CASA officer to observe a relevant operation at CASA’s expense.","sortOrder":0}],"analysis":{"kimi_summary":{"content_quality":"ok","complexity_score":6,"scope_assessment":{"changed":false,"description":"This is a new instrument (2025) with a tightly focused scope: indoor emergency service drone operations. It does not appear to have expanded beyond its original intent — it targets a specific operational need (emergency services flying small drones indoors) with precisely tailored exemptions and conditions. The scope is actually narrower than general drone regulations, being restricted to emergency service operators, specific RPA weight classes (micro/very small under 1.05kg), and internal operations."},"complexity_factors":["14 defined terms in section 3, including nested definitions (e.g., 'internal operation' includes 'transit operation', which is separately defined)","Multiple conditional speed and height restrictions in Table 4.4 with three variables (distance from person, base speed, increased speed, height)","Dual regime system: different rules for 'shielded operations' vs operations involving 'unshielded persons'","Cross-references to external documents: Part 101 Manual of Standards, Civil Aviation Safety Regulations 1998 (CASR), Civil Aviation Act 1988","Conditional exemptions: 6 specific regulations exempted, but only for specific circumstances and subject to Schedule 1 conditions","Hierarchy clause (6.4) establishing precedence between instrument and operator's documented procedures","Training and documentation requirements that require CASA pre-approval (6.3)","Transitional provisions for transit operations (approaching/leaving buildings) with separate height restrictions"],"plain_english_summary":"This CASA exemption lets accredited emergency services (police, fire, ambulance, defence, border force, etc.) operate small drones (<1.05 kg) indoors near people and beyond visual line of sight, where normal rules would bar such use. It provides a controlled legal pathway for lifesaving, rescue, and safety operations subject to strict risk assessments, physical safeguards (no exposed blades, speed/height limits, shielding), procedural approvals, and mandatory accident reporting."},"flash_summary_failed":{"failed":true,"reason":"Unauthenticated. Configure AI_GATEWAY_API_KEY or use a provider module. Learn more: https://ai-sdk.dev/unauthenticated-ai-gateway","source":"analysis-cron"},"flash_summary":{"complexity_score":6,"scope_assessment":{"changed":true,"description":"This instrument temporarily broadens the operational scope for specified emergency-service RPA operators by exempting them from particular Part 101 restrictions (BVLOS — reg 101.073; weather/day limits — reg 101.095; operations near people — reg 101.245; operations over a populous area — reg 101.280; certain remote pilot licence conditions — para 101.300(4)(b)) when conducting relevant operations (clause 5(1)). The expansion is limited to micro/very-small RPAs (≤1,050 g) and to persons/operators meeting the definitions (clause 3). The exemptions are conditional on CASA-approved documented practices, prescribed risk assessments, speed/height limits and reporting (Schedule 1, clauses 2, 4, 6; clause 7), and apply also to training treated as an ESRO (clause 4(2)). The instrument is time-limited (1 Oct 2025–30 Sep 2028) (clause 2)."},"complexity_factors":["Extensive defined terms and scope limits (clause 3) that narrow eligibility to specific emergency-service organisations and RPAs ≤ 1,050 g.","Exemption is conditional rather than absolute: multiple Part 101 provisions are disapplied only when Schedule 1 conditions are met (clause 5(1)–(2); Schedule 1).","Detailed operational limits and contingencies (speed caps, height limits, deliberate override requirement, shielded vs unshielded distinctions — Schedule 1, clause 4 and Table 4.4).","Mandatory documented practices and procedures with CASA approval for ESROs (Schedule 1, clause 6.1 and 6.3) creating administrative and compliance burden.","Risk assessment obligations with specific required content and thresholds for acceptable risk (Schedule 1, clause 2).","Training, recordkeeping and abnormal procedures mandated and integrated into approval/compliance system (Schedule 1, clauses 6.1(e)–(f), 6.2).","Reporting and oversight provisions: incident reporting within 72 hours (clause 7) and CASA observer access at CASA expense (clause 8), increasing monitoring and potential operational interruption.","Cross-references to multiple CASR/Part 101 provisions and offence provisions (clauses 1, 3(3), 5), increasing legal interpretive complexity.","Temporal limitation (commences and repeals on specific dates — clause 2), requiring time-bound implementation and renewal planning."],"plain_english_summary":"Allows specified emergency-service RPA operators (police, ADF, AMSA, Border Force, state/territory fire, emergency, parks/forestry and lifeguard services) and their remote pilots to operate micro and very-small RPAs indoors, within 30 m of people and beyond visual line of sight by exempting them from certain Part 101 limits, subject to CASA-approved documented practices, risk assessments, speed/height limits, and incident reporting. Operators pay compliance costs (procedures, training, records); CASA approves procedures and may observe operations at CASA’s expense. Exemption runs 1 Oct 2025–30 Sep 2028."}},"importantCases":[],"_links":{"self":"/api/acts/casa-ex88-25-indoor-operation-of-rpa-near-people-and-bvlos-training-and-use-exemption-2025","history":"/api/acts/casa-ex88-25-indoor-operation-of-rpa-near-people-and-bvlos-training-and-use-exemption-2025/history","analysis":"/api/acts/casa-ex88-25-indoor-operation-of-rpa-near-people-and-bvlos-training-and-use-exemption-2025/analysis","conflicts":"/api/acts/casa-ex88-25-indoor-operation-of-rpa-near-people-and-bvlos-training-and-use-exemption-2025/conflicts","importantCases":"/api/acts/casa-ex88-25-indoor-operation-of-rpa-near-people-and-bvlos-training-and-use-exemption-2025/important-cases","documents":"/api/acts/casa-ex88-25-indoor-operation-of-rpa-near-people-and-bvlos-training-and-use-exemption-2025/documents"}}