Australian Airspace Policy Statement (AAPS) 2026

The AAPS codifies a set of core concepts and constructs that will govern administrative decisions about Australian-administered airspace. These are primarily safety, strategic planning through an Australian Future Airspace Framework (AFAF), evidence- and risk-based decision making using ARMS, regulatory certainty for new technology, collaborative arrangements for flight testing and national security, adherence to ICAO standards, and transparency via reporting obligations (paras 9-16, 35-49).

Safety is the first and dominant concept, stated as the priority for airspace administration (para 9 and para 17). The AAPS expects CASA to “identify and monitor airspace risk, and respond appropriately and in a timely manner” and to collaborate with industry and government entities, with particular reference to integration of Automatic Dependent Surveillance Broadcast (ADS-B) (para 9). The priority is expressed procedurally: CASA must use a risk and evidence-based review process aligned with ICAO guidance when assessing airspace (paras 25-27).

Related to safety is the AFAF concept. The AAPS requires CASA to develop the AFAF as a long-term strategic airspace plan, containing design principles for airspace architecture, transitional milestones for technology and regulation, and a commitment to not predetermine airspace classifications (paras 10, 35-44). The AFAF is to be risk-based and informed by CASA’s Airspace Risk Modelling System (ARMS) to support evidence-driven decisions (para 37). The AFAF also has an implementation emphasis: where practicable it should support advanced Air Traffic Management (ATM) and Uncrewed Aircraft Systems Traffic Management (UTM) technologies (paras 38-40).

The statement also embeds the concept of regulatory pathways and certainty for new aviation technologies. CASA is expected to work with the Department, Airservices and industry to integrate RPAS and AAM safely, using “fit-for-purpose regulations and/or regulatory pathways informed through proportionate risk profiles” plus guidance material and digital transformation of regulatory application services (para 11, para 38). In practice this links regulatory design to measured risk profiles and to digital capability to process applications.

Administrative coordination and institutional integration are explicit concepts. Airservices is expected to implement services consistent with CASA’s intent (para 7). Defence integration is institutionalised by the placement of Defence officers within the OAR holding delegated powers under the Airspace Regulations, reflecting the AAPS’ policy of harmonised civil and military ATM (para 8). The AAPS also highlights consultation with Defence where airspace changes affect military responsibilities (para 31).

International alignment and constrained deviation are another central concept. The AAPS reiterates that Australian airspace administration is aligned with ICAO classes and Annex 11, that any differences are notified to ICAO and published in the AIP, and that deviations from ICAO SARPs must be justified and notified (paras 18, 41). This creates a framework in which international standards serve as baseline norms.

Finally, transparency and accountability are embedded through publication and reporting requirements. CASA must publish findings and proposals from airspace reviews, maintain and make AFAF guidance material available to proponents, publish an annual OAR Strategic Workplan, and report to the Minister on priorities, residual risks, and non-delivery against policy objectives (paras 32, 42-49). These procedural transparency requirements are intended to make the decision process visible to industry and other stakeholders.

All the above main concepts are defined or referenced in a glossary that sets specific meanings for terms such as AAM, AFAF, ARMS, OAR, RPAS, UTM and Australian-administered airspace (Glossary). The glossary also points to the external legal instruments and documents,Airspace Act 2007, Airspace Regulations 2007, the Chicago Convention and the Aeronautical Information Publication,that underpin the execution of these concepts (Referenced Documents).

The AAPS explicitly identifies the principal decision makers, service providers, regulated entities and stakeholders that will be affected. CASA is the primary addressee: the AAPS is made pursuant to Part 2 of the Airspace Act 2007 and directs CASA to administer airspace consistent with government priorities and international obligations (para 4). Within CASA, the Office of Airspace Regulation (OAR) is the operational unit charged with exercising airspace regulatory functions (para 5). CASA’s statutory enabling activities are listed and include determining airspace classes, designations of prohibited, restricted and danger areas, and publishing particulars of air traffic services (para 6).

Airservices Australia is named as the civilian air navigation service provider expected to manage airspace and provide services consistent with CASA’s administrative intent and government policy objectives, and subject to its own legislative functions and obligations under the Chicago Convention (para 7). Aerodrome operators and air traffic service providers who supply particulars to the AIP will be affected because changes require collaborative implementation between CASA and Airservices (paras 31, 33).

The Department of Defence has a concrete operational role. The AAPS directs the placement of Defence officers within CASA’s OAR who will hold delegated powers under the Airspace Regulations 2007, to facilitate better coordination of military and civil airspace requirements (para 8). Defence will therefore be a direct participant not only in consultation but in delegated decision processes where those delegated powers are exercised.

Industry stakeholders are comprehensively captured. Crewed aviation, uncrewed aircraft operators, RPAS and AAM developers, flight training organisations, aerodrome operators (particularly regional aerodromes), and businesses seeking flight testing opportunities will be materially affected by AAPS priorities. The AAPS explicitly expects CASA to work with the Department, Airservices, Defence and industry to integrate RPAS and AAM and to facilitate flight testing of new civil and military systems, to enable commercialisation and sovereign manufacturing outcomes (paras 11-12). Regional aerodrome operators are singled out for tailored consideration of airspace classification and services to support continued safe operations (para 15).

Regulatory proponents and applicants are affected by procedural expectations: CASA must use risk-based reviews, consult with Airservices and Defence, publish findings and formalise changes via legislative instruments and the AIP (paras 25-33). This imposes identifiable stages for proponents to engage, supply data for CASA’s ARMS, and expect legislative instrument processes for any definitive changes.

Other government agencies are implicated. The Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts (the Department) is named as a coordinating agency for integrating new technologies and developing the AFAF with CASA and Airservices (paras 10, 11, 36-37). The AAPS also expects collaboration with the Department of Home Affairs in the context of national security considerations (para 16).

Finally, the public and other airspace users are affected indirectly. The AAPS requires publication of CASA’s proposals and findings for public comment as part of the review process and the AFAF is to provide transparency to industry regarding how administrative decisions will be determined (paras 30, 42). In short, the AAPS affects regulators, service providers, Defence, industry participants (both crewed and uncrewed), aerodrome operators, other government agencies, and the public that may participate in consultation processes.

The AAPS imposes expectations and procedural duties primarily on CASA, sets duties indirectly on Airservices and Defence to cooperate, and creates rights of participation for industry and other stakeholders. The instrument is an expression of government policy rather than a statutorily enforceable code in itself, but it requires CASA to act in specified ways as a matter of policy and administrative process.

Duties of CASA. The AAPS requires CASA to administer Australian-administered airspace consistent with legislative functions, government policy objectives and international obligations (para 4). CASA must exercise airspace regulatory functions through the Office of Airspace Regulation and as necessary through other parts of CASA (para 5). CASA’s specific duties as set out in the instrument include:

• Conducting risk and evidence-based airspace reviews using quantitative and qualitative data, aligned with ICAO guidance (paras 25-27).
• Using its Airspace Risk Modelling System (ARMS) to inform the AFAF and airspace reviews (para 37).
• Publishing findings and proposals on safety and suitability when considering changes to classifications, designations or service levels, and providing these findings to Airservices, Defence and the public for comment prior to making determinations (para 30).
• Formalising changes as legislative instruments, endorsed by the relevant delegate, and publishing them on the Federal Register of Legislation and the AIP (para 32).
• Developing and maintaining the AFAF in consultation with Airservices, Defence, the Department and industry stakeholders (paras 35-38, 42-44).
• Publishing an OAR Strategic Workplan at least annually and reporting progress in corporate plans and to the Minister, including bi-annual reporting on residual airspace risks (paras 45-49).

Duties of Airservices and Defence. Airservices is expected to manage airspace and provide services consistent with CASA’s administrative intent and implement CASA determinations in a reasonable timeframe acceptable to CASA (paras 7, 33). Defence is expected to be a partner in coordination and consultation; Defence officers may be placed within the OAR with delegated powers under the Airspace Regulations to facilitate harmonised civil-military ATM arrangements (para 8). Where relevant, CASA must consult Defence prior to determinations that have military implications (para 31).

Rights of stakeholders. Industry and the public have procedural rights to participate in consultation. CASA must publish findings and proposals and provide them to Airservices, Defence and the public for comment, which creates a right to be heard during the review and determination stages (para 30). The AFAF and associated guidance material must be maintained and available to proponents of airspace change, enabling access to the framework that will inform decisions (para 44).

Limits and discretion. The AAPS does not remove statutory discretions but frames them. CASA retains the safety judgement as the ultimate decision driver,the AFAF will inform but not predetermine classifications (para 40). The instrument also allows for urgent decisions where safety, national security or other imperatives make the full process impracticable, under the Airspace Regulations (para 34). Determinations must be endorsed by the relevant delegate and formalised as legislative instruments, which means normal administrative law and legislative instrument regimes remain relevant to how rights and duties are enforced (para 32).

Interaction with international duties. CASA and Airservices are expected to move closer to ICAO SARPs and to ensure any deviations are well justified and notified to ICAO as differences, which creates an obligation to document and formalise departures from international standards (paras 14, 41).

Reporting obligations as duties. CASA is directed to include OAR priorities in its corporate plan, publish and consult on an annual strategic workplan, provide quarterly reporting to the Minister on AAPS priorities, report bi-annually on residual risks, and advise the Minister if AAPS policy objectives will not be met within three years (paras 45-49). These reporting obligations create administrative transparency duties and impose accountability to the Minister.

In short, the AAPS imposes procedural and planning duties on CASA and obliges Airservices and Defence to cooperate. It confers consultative rights on industry and publics while preserving statutory discretion and safety primacy for the regulator.

The AAPS is a policy statement made under Part 2 of the Airspace Act 2007 and does not itself create statutory offences, monetary fines or criminal penalties. The instrument principally prescribes government expectations about how CASA should exercise its existing statutory and regulatory powers under the Airspace Act 2007, the Civil Aviation Act 1988 and the Airspace Regulations 2007 (para 4; Referenced Documents). Enforcement, sanctions and penalties therefore remain those provided by the underlying legislation and regulations, not by the AAPS text.

Where the AAPS is operationalised, the concrete enforcement mechanisms will flow from determinations and legislative instruments made by CASA under the Airspace Act and Airspace Regulations. The AAPS requires that changes to airspace classification, services or facilities be formalised as legislative instruments, endorsed by the relevant delegate, and published on the Federal Register of Legislation and the AIP (para 32). Those legislative instruments, and the Acts and Regulations they implement, carry the legal force that enables enforcement actions, directions, and penalties. The AAPS itself instructs procedural steps that precede or accompany those legal instruments but does not specify enforcement modalities or penalty levels (paras 25-33).

Administrative enforcement and oversight. The AAPS establishes reporting obligations and oversight lines that can lead to administrative scrutiny of CASA’s actions. CASA must include OAR initiatives in its corporate plan, publish a Strategic Workplan for the OAR annually, provide quarterly reporting to the Minister on priorities and initiatives, and report bi-annually on residual airspace risk (paras 45-49). These reporting requirements create administrative accountability to the Minister, and failure to comply could lead to ministerial queries, revised statements of expectations, or legislative or budgetary responses, but those are political or administrative consequences rather than penalties stated in the AAPS itself.

Urgent decisions and legal authority. The AAPS expressly contemplates urgent decisions made under the Airspace Regulations in circumstances where safety, national security or other imperatives require action and where it may not be practicable to comply fully with the process otherwise described (para 34). That paragraph indicates that urgent regulatory or administrative action and any enforcement that flows from it will be undertaken within the scope of the Airspace Regulations, not by the AAPS alone.

International obligations and compliance. The AAPS requires alignment with ICAO SARPs and documentation and notification of any differences to ICAO (paras 14, 41). Non-compliance with ICAO SARPs does not itself result in domestic penalties via the AAPS, but the requirement to notify differences is a reporting obligation; persistent divergence from SARPs without justification could have reputational or international regulatory consequences.

Practical enforcement actors. CASA, exercising its statutory powers through the OAR and other parts of the organisation, will be the principal enforcement actor in the domestic regime (paras 5-6). Airservices will be responsible for implementing service-level changes required by CASA determinations (paras 7, 33). Defence officers placed within the OAR will hold delegated powers under the Airspace Regulations where those delegations exist (para 8), and could therefore be exercising legal authorities delegated under the Regulations.

Summary. The AAPS itself prescribes process, priorities and reporting; it does not create new offences or penalties. Enforcement and penalties are exercised under the Airspace Act 2007, Airspace Regulations 2007 and related legislation, and the AAPS shapes the policy and procedural context in which those legal instruments are applied (paras 4, 6, 32, 34).

The AAPS is explicitly framed as policy to be applied in the context of existing statute and international law. It is made pursuant to Part 2 of the Airspace Act 2007 (para 4) and repeatedly references statutory instruments that govern legal authority and implementation: the Airspace Regulations 2007, the Civil Aviation Act 1988, and the Aeronautical Information Publication (AIP), as well as Australia’s international obligations under the Chicago Convention (paras 5-7, Referenced Documents). The AAPS therefore interacts as subordinate policy guidance that directs the exercise of statutory powers rather than supplanting or changing those laws.

Airspace Act 2007 and Airspace Regulations 2007. The AAPS is made under the Airspace Act 2007 (para 4) and anticipates CASA exercising statutory powers pursuant to the Act and the Airspace Regulations 2007 (paras 5-6, 34). It requires that changes made following CASA decisions be formalised as legislative instruments, endorsed by the relevant delegate, and published on the Federal Register of Legislation and the AIP (para 32). Urgent decisions are to be taken in accordance with the Airspace Regulations where full process is impracticable (para 34). The AAPS therefore functions as a policy overlay that guides regulatory decision-making mandated by those statutes.

Civil Aviation Act 1988. CASA’s activities are to be consistent with its functions under the Civil Aviation Act 1988 (para 5). The Glossary also references section 9A of the Civil Aviation Act 1988 in relation to the concept of environment protection in airspace administration, indicating that environmental considerations articulated in the AAPS are to be applied in the context of that statutory provision (Glossary).

Chicago Convention and ICAO SARPs. The AAPS emphasises alignment with international standards. It requires CASA and Airservices to move closer to alignment with ICAO Standards and Recommended Practices (SARPs) and to remain consistent with the ICAO Global Aviation Safety Plan and Global Air Navigation Plan (para 14). The AAPS specifies that airspace classification in Australia is generally aligned with ICAO Annex 11, that differences are notified to ICAO and listed in the AIP, and that any deviations from ICAO SARPs must be well justified, documented and formally notified to ICAO as a difference (paras 18, 41). The AAPS therefore situates national policy within international legal obligations and imposes domestic reporting and justification duties when departing from SARPs.

AIP and legislative instruments. The AAPS requires CASA to publish determinations on the Federal Register of Legislation and then through the Australian AIP (para 32). That integration links administrative policy to legally operative publications that airlines, pilots and aeronautical service providers rely upon. The AIP is maintained by Airservices and is referred to as the repository for lasting aeronautical information (Referenced Documents and Glossary).

Environmental and national security law. The AAPS instructs that airspace administration should “as far as is practicable, ensure the environment is protected from the effects of the operation and use of aircraft,” referring to section 3A of the Airspace Act 2007 and section 9A of the Civil Aviation Act 1988 in the Glossary (para 17 and Glossary). National security considerations are to be integrated with civil aviation requirements; the AAPS expects CASA, the Department, Airservices, Department of Home Affairs and Defence to work together to ensure national security is considered without compromising aviation safety, and to recognise links and differences between national security and safety (para 16). These references indicate interaction with environmental policy settings and national security frameworks, though the AAPS does not displace or restate those separate legal regimes.

Administrative law and consultative obligations. The AAPS mandates consultation with Airservices, Defence and the public for comment on CASA findings and proposals and requires publication of relevant materials (para 30). That procedural direction interacts with administrative law norms such as procedural fairness and reviewability even though the AAPS itself does not create rights enforceable at law. CASA’s determinations being legislative instruments (para 32) means they are subject to statutory requirements for instruments, potential disallowance and administrative review mechanisms available under general administrative law.

Referenced legislation. The AAPS cross-references and links to the Air Navigation Act 1920 and the Chicago Convention (Referenced Documents), and through the glossary and references to ICAO Annexes ties the AAPS to the international framework that is incorporated at various points into domestic law.

Summary. The AAPS functions within a legal matrix: it is policy guidance made under the Airspace Act 2007 that instructs CASA how to exercise statutory powers, it requires that outcomes be formalised as legislative instruments and published in the AIP, and it requires alignment with ICAO obligations and domestic environmental and national security considerations. The principal legal interactions are with the Airspace Act 2007, Airspace Regulations 2007, Civil Aviation Act 1988, the Chicago Convention and the AIP (paras 4, 6, 32, 34, 41; Referenced Documents; Glossary).

The AAPS 2026 document contains a limited but explicit amendment record within the instrument itself. The instrument opens by stating its name and that “this instrument is the Australian Airspace Policy Statement (AAPS) 2026” (para 1). It then provides a commencement provision that the AAPS 2026 “commences the day after it is registered on the Federal Register of Legislation and repeals the Australian Airspace Policy Statement 2021, which commenced on 24 November 2021” (para 2). That is the only direct substantive repeal noted in the instrument.

An administrative amendment is recorded in the Referenced Documents section. A note at the end of the text records that “The name of this instrument was amended on registration to include the year of its making (see section 12, Legislation Rules 2026)” (final line). This is an editorial rule compliance change to the instrument name, citing the Legislation Rules 2026 s 12 as authorising the naming convention. No further historical versions, redlines or comparative text between the 2021 and 2026 statements are provided within the instrument itself.

There are no incremental amendment clauses within the AAPS text setting out staged revisions or sunset provisions beyond the requirement that CASA review Instruments containing declarations, designations, determinations and directions at least every five years (para 6). That five year review obligation applies to the Instruments that formalise airspace changes in the legal sense and is a duty under the enabling legislation; the AAPS restates it as part of CASA’s statutory functions (para 6).

The instrument requires CASA to ensure the AFAF and associated guidance materials are “maintained and available” to proponents and that the long-term strategic airspace plan will require “ongoing review” based on identification of aviation safety risks (paras 42-44). These provisions imply a continuing maintenance and revision regime for the AFAF once it is developed, but the AAPS does not specify particular amendment mechanisms for the AAPS itself beyond its status as a legislative instrument subject to the usual processes for variation or repeal, which in practice would be effected through a replacement or amending instrument registered on the Federal Register of Legislation.

Summary of concrete amendment items recorded in the instrument:

• Commencement and repeal of the prior 2021 AAPS upon registration of the 2026 instrument (para 2).
• Administrative amendment to the instrument’s name on registration to include the year pursuant to Legislation Rules 2026 s 12 (Referenced Documents, final note).
• Restatement of statutory periodic review requirements for Instruments containing declarations, designations, and determinations at least every five years (para 6).

The instrument does not provide a running legislative history or list of previous amendments beyond the repeal of the 2021 instrument and the naming amendment. Users seeking comparative text or detailed changes between versions must obtain the prior instrument text and perform a line-by-line comparison, as the AAPS 2026 does not itself catalogue what language was altered from the 2021 edition.

The AAPS 2026 contains no litigation history and does not reference any judicial decisions. It is a policy instrument made under the Airspace Act 2007 and the text does not identify any prior legal challenges, cases, or court findings. The Referenced Documents section lists the key statutory and international instruments that frame the regime, including the Airspace Act 2007, Airspace Regulations 2007, the Civil Aviation Act 1988 and the Chicago Convention, but it does not reference any administrative or judicial determinations interpreting those instruments.

Because the AAPS is a statement of government policy rather than a statutory prohibition or penalty provision, the instrument itself is unlikely to be the subject of direct litigation. However, CASA’s determinations that implement the AAPS in the form of legislative instruments (as required by para 32) would be subject to the usual avenues of administrative review and judicial review at the time those instruments are made. The AAPS anticipates that CASA will publish findings and proposals and consult with Airservices, Defence and the public prior to determinations (para 30). Those administrative actions, once formalised as legislative instruments, would be reviewable or challengeable by affected parties under the Administrative Decisions (Judicial Review) Act 1977 or by merits or injunction applications where applicable, but the AAPS itself does not address those remedies nor does it list historical litigation.

No cases are named within the instrument, and the AAPS does not record any legal disputes or precedents that influenced its drafting. To assess litigation risk or history relevant to airspace administration, practitioners would need to search decisions concerning CASA, Airservices, and Airspace Act instruments outside the AAPS text. The AAPS does not provide a record of such authorities.

In short, the AAPS 2026 includes no litigation history or cited cases. It operates as a policy direction to be applied in the statutory framework; any litigation relating to airspace administration would arise in the context of statutory instruments made under the Airspace Act, the Airspace Regulations or other relevant statutes, not from the policy statement itself.

Several practical and legal pitfalls emerge from the text of the AAPS 2026. These are operational features and procedural constraints that stakeholders should note because they may catch proponents, operators or advisers unaware.

Policy versus law. The AAPS is a policy statement, not a replacement for statutory authority. Although the AAPS directs CASA to act in certain ways, legal force in operational terms arises from subsequent determinations and legislative instruments under the Airspace Act and Airspace Regulations (para 32). Relying on the AAPS alone to assert a legal right is a mistake; stakeholders must track the legislative instruments and AIP entries that formalise changes.

Scope of consultation and timing. The AAPS mandates publication of findings and proposals and providing them to Airservices, Defence and the public for comment (para 30). But the instrument also allows for urgent decisions where safety or national security imperatives make the full process impracticable (para 34). A proponent who expects the full consultation process could be surprised by an expedited determinations pathway in urgent or security-related contexts. Similarly, CASA must publish an annual Strategic Workplan (para 46), but stakeholders that do not monitor that workplan may miss opportunities to input early.

Defence integration and delegated powers. The AAPS expressly permits the placement of Defence officers within the OAR who will hold delegated powers under the Airspace Regulations 2007 (para 8). This institutional integration can change decision pathways and the locus of delegated authority for certain determinations. Stakeholders should not assume civil-only decision processes where Defence interests are engaged, and proponents may need to manage access and negotiation with Defence stakeholders as part of the consultation.

AFAF is guiding not determinative. The AFAF will contain design principles and be used to inform reviews and classification decisions, but it “will not pre-determine the adoption of a particular classification of airspace” (para 40). Industry actors should therefore treat the AFAF as informative for planning and engagement, but not as a contractual or guaranteed outcome on airspace category. Investment or operational planning premised on specific classifications should incorporate this uncertainty.

Data and modelling expectations. CASA will use ARMS and expects evidence- and risk-based analyses to inform decisions (paras 25-27, 37). Proponents may be required to provide detailed quantitative and qualitative data to support applications or to participate in modelling. Organisations that lack the data collection capacity may be disadvantaged or slower in responding to proposals.

Digital transformation and resourcing. The AAPS expects CASA to leverage digital transformation of regulatory application and assessment processes to improve data collection and provide cost-effective services in the face of growing application volumes (para 38). While this should produce efficiency in the long run, transitional frictions are possible. Applicants reliant on legacy systems or with limited digital capability may face short-term access or processing issues as new systems are implemented.

Interaction with ICAO and AIP publication. Any deviation from ICAO SARPs must be justified, documented and notified to ICAO as a difference (para 41), and differences are to be listed in the AIP (para 18). Proponents should anticipate that departures from international norms will attract scrutiny, require documentation and potentially affect international operators who use Australian airspace.

Class E exclusion for control zones. The AAPS notes that Class E “shall not be used for control zones” (para 19). Where stakeholders assume a flexibility to create lower-control zones using Class E, that assumption would be a misreading. The AAPS sets a specific limit on where Class E may be applied.

Reporting lines and ministerial oversight. CASA must report OAR priorities in its corporate plan, publish Strategic Workplans, provide quarterly and bi-annual reports to the Minister, and advise if policy objectives will not be met within three years (paras 45-49). These reporting obligations mean that CASA’s priorities and resource allocations are likely to be influenced by political and ministerial expectations. Industry should factor political cycles and ministerial-level scrutiny into expectations for timing and deliverables.

Regional aerodrome expectations. The Government commits to ensuring appropriate levels of classification and services for regional aerodromes (para 15). However, the AAPS qualifies this with the need to be informed by outcomes of airspace reviews. Therefore regional operators should expect that service level changes will be evidence- and risk-driven rather than guaranteed by the statement alone.

No explicit penalties in the AAPS. Some stakeholders may look to the AAPS for enforcement details. The instrument does not set out penalties. Enforcement arises under the Airspace Act and related regulations, so parties must consult those instruments to understand sanction regimes (paras 4, 32).

In short, the principal “gotchas” are: treating the AAPS as self-executing law rather than policy; underestimating the role of Defence-delegated powers and urgent decision provisions; over-relying on the AFAF to lock in classifications; not preparing to supply robust data for ARMS modelling; transitional frictions during digital transformation; obligations to document deviations from ICAO rules; and the absence in the AAPS of any new penalties. Awareness of these elements will shape realistic expectations and engagement strategies.

Compliance under the AAPS is primarily about engaging with the procedural and evidentiary expectations the statement imposes on CASA and on proponents of airspace change. Because the AAPS directs how CASA will exercise existing statutory powers, effective compliance for industry and other stakeholders involves preparing to operate within CASA’s review, consultation and implementation processes described in the instrument.

Key compliance steps for proponents (operators, aerodrome owners, RPAS/AAM developers):

1. Identify applicable classifications and publications. Check the Australian AIP and relevant legislative instruments to ascertain the current classification or designations of any airspace volume of interest. The AAPS requires CASA to publish determinations through legislative instruments and in the AIP (para 32). Subscribe to AIP updates via Airservices so you receive formal amendments promptly.

2. Prepare risk- and evidence-based submissions. CASA’s review process must be risk and evidence-based and use quantitative and qualitative data sources aligned with ICAO guidance (paras 25-27). Assemble traffic, operational, safety occurrence and other empirical data , for example, movement statistics, ADS-B data where available, ATS occurrences, and modelling inputs relevant to collision risk , to support proposals. Where possible, prepare the data in formats compatible with CASA’s ARMS to facilitate analysis (para 37).

3. Engage early with CASA, Airservices and Defence. The AAPS requires consultation with Airservices and Defence where relevant and the AFAF is to be developed collaboratively (paras 31, 36). For proposals that may affect military operations, expect Defence consultation and possible involvement of Defence officers within the OAR who hold delegated powers (para 8). Early engagement can reduce the risk of late objections or urgent security-based interventions (para 34).

4. Use published materials and the AFAF. The AAPS requires CASA to make the AFAF and associated guidance material available to proponents (para 44). Before lodging applications, review the AFAF, CASA’s published findings, and the OAR Strategic Workplan to ensure proposals align with stated design principles and planned priorities (paras 42-46).

5. Plan for formal legislative instrument processes. Any determination that effects change must be formalised as a legislative instrument endorsed by the relevant delegate and published on the Federal Register and in the AIP (para 32). Factor time for instrument drafting, endorsement and publication into project timelines.

6. Anticipate consultation cycles and public comment. CASA will publish findings and proposals and provide them for public comment (para 30). Prepare to respond to public submissions and to provide supplementary data or mitigations as requested during consultation.

7. Prepare for urgent decision scenarios. Where safety, national security or other imperatives apply, CASA may take urgent action that truncates consultation timelines in accordance with the Airspace Regulations (para 34). Maintain contingency plans for operational continuity should urgent temporary restrictions be introduced.

8. Understand international obligations where relevant. If your proposal would involve departures from ICAO SARPs, be ready to justify and document differences, since deviations must be notified to ICAO and recorded in the AIP (para 41). International operators using Australian airspace may be affected by such differences.

9. Consider environmental and regional aerodrome factors. The AAPS instructs administrators to consider environmental protection in line with s 3A of the Airspace Act and s 9A of the Civil Aviation Act and requires sensitive treatment of regional aerodromes (para 17; Glossary; para 15). Include environmental impact information where relevant and plan proposals for regional aerodromes with an evidence base demonstrating acceptable safety and community outcomes.

10. Monitor CASA reporting products and timelines. CASA will publish an OAR Strategic Workplan at least annually and include OAR priorities in its corporate plan; it will report quarterly and bi-annually to the Minister (paras 45-49). Monitoring these products will help proponents align project timing with regulator priorities and identify windows for engagement.

Actions for service providers, aerodrome operators and Airservices:

• Coordinate implementation planning with CASA following any determination, recognising Airservices has an obligation to bring CASA decisions into effect in a reasonable time acceptable to CASA (para 33).
• Maintain accurate aeronautical information for AIP submission processes and ensure timely updates to operational publications when changes are formalised (para 32).
• Engage in collaborative flight testing arrangements with CASA, Defence and the Department if seeking flight testing authorisations, and ensure safety mitigations are presented and acceptable (para 12).

Actions for regulators and government agencies:

• CASA should publish and maintain the AFAF and supporting guidance, leverage ARMS and digital application processes, and meet its reporting obligations (paras 35-39, 44-49).
• Defence and Home Affairs should coordinate with CASA on national security needs that may constrain airspace use, while ensuring safety remains the priority in administrative decision-making (para 16).

Documentation and record-keeping:

• Maintain records of all data submitted to CASA and any interactions with the OAR, Airservices and Defence. Given that determinations will be formal legislative instruments and that deviations from ICAO SARPs require documentation, robust record-keeping supports both compliance and any administrative review.

Practical compliance checklist summary:

• Verify current AIP and legislative instruments for the airspace volume.
• Prepare quantitative and qualitative risk evidence compatible with ARMS.
• Engage early with CASA, Airservices and Defence.
• Review and align with the AFAF and CASA OAR Strategic Workplan.
• Plan for legislative instrument timelines and public consultation.
• Ensure environmental and regional aerodrome impacts are addressed.
• Keep records to demonstrate compliance with procedural expectations and to facilitate any future administrative scrutiny.

Following these steps will align proponents and service providers with the procedural and evidentiary expectations that the AAPS 2026 places on airspace administration and on the decision-making processes of CASA, Airservices and Defence (paras 25-38, 42-49).