CASA 20/25 – Operation of Certain Unmanned Aircraft and Rockets – Directions Instrument 2025

This instrument uses a small set of recurring legal concepts to regulate unmanned aircraft and rocket operations. The central concepts, and where they appear in the instrument, are:

• unmanned aircraft: defined broadly in s 3(1) to include tethered and other balloons, kites, unmanned free balloons, RPA and model aircraft. This definition governs the scope of the directions that follow. The instrument also states that, subject to s 3(1), words and phrases take the same meaning as in Part 101 of CASR and the Civil Aviation Act 1988 unless a contrary intention appears (s 3(2)).

• rocket: the instrument adopts the CASR Dictionary meaning and expressly includes a firework projectile for the purposes of the instrument (s 3(1) and note). Where the instrument refers to rockets, the inclusive definition captures fireworks identified as rocket projectiles.

• directions: the instrument is a directions instrument made under reg 11.245 CASR and issues binding directions to persons controlling or operating unmanned aircraft and rockets. The directions appear at ss 5-9 and operate by placing prohibitions or positive obligations on controllers and operators.

• 400 ft AGL ceiling: a bright‑line prohibition on operating RPA or model aircraft higher than 400 ft above ground level, with enumerated exceptions for specified CASA approvals, authorisations/exemptions under CASR, approved areas under reg 101.030, and where the RPA is flown by a remote pilot licence holder in accordance with licence privileges and the operator’s certification (s 5(1)-(2)).

• emergency/public safety exclusion: a prohibition on operating unmanned aircraft or rockets over areas where a fire, police or other public safety or emergency operation is being conducted, except where written CASA approval exists or where oral approval is granted by the person in charge of the operation and a contemporaneous record is retained (s 6(1)-(2)).

• safety zone: a notional cylindrical volume of airspace around a person with a radius of 30 metres from the person’s position and rising from the ground or water surface that the person is on or directly above. Critically, the instrument’s note to s 7(2) states that, for safety purposes, there is no ceiling to this zone (s 7(2) and note; s 7(1) prohibition applies to operating in or over another person’s safety zone).

• single‑aircraft rule: controllers must operate only one RPA or model aircraft at a time, subject to exceptions for micro RPA or where specific CASA authorisation or exemption permits multiple operations (s 8(1)-(2)).

• operator duty of oversight: the operator of an unmanned aircraft or rocket must ensure that the person controlling the aircraft or rocket complies with directions in this instrument and is familiar with and follows the operator’s approved practices and procedures intended to ensure compliance (s 9).

Many of these concepts are operationalised with a combination of absolute prohibitions and express carve‑outs. The carve‑outs are uniformly framed as either approvals given by CASA in writing, authorisations or exemptions under CASR, privileges attached to a remote pilot licence, or written approvals from CASA specific to model aircraft (see s 5(2), s 6(2), s 7(3), s 8(2)). The instrument thus produces a regulatory architecture in which front‑line mandatory constraints coexist with delegated discretion and an authorisation pathway under CASR.

The instrument identifies several distinct categories of persons and entities that must alter behaviour to comply. The parties specifically addressed are:

• persons controlling an unmanned aircraft or a rocket: the operative prohibitions in ss 5, 6, 7 and 8 are expressed as directions to "a person controlling" the relevant aircraft or rocket. That means the individual at the controls, whether an RPA pilot or a person flying a model aircraft, is a primary duty‑bearer for the instrument’s prohibitions (s 5(1); s 6(1); s 7(1); s 8(1)). The instrument repeatedly uses the phrase "a person controlling" to impose obligations.

• operators of an unmanned aircraft or rocket: s 9 places a statutory duty on the operator to ensure controllers comply with applicable directions and that controllers are familiar with and follow the operator’s approved practices and procedures. This creates an operator‑level compliance responsibility beyond the individual controller.

• holders of remote pilot licences and certified RPA operators: s 5(2)(b) preserves the operation of an RPA by a holder of a remote pilot licence, provided the flight is consistent with licence privileges and the certification of the RPA operator conducting the operation. Thus licensed pilots and certified operators remain able to operate above the 400 ft AGL ceiling to the extent permitted by their licence and operator certification.

• CASA as approver and documenter: CASA is the authorised decision maker for written approvals and for giving approvals referenced across the instrument. For example, CASA may issue written approvals for operations over emergency areas (s 6(2)(a)), give written approvals for model aircraft operations closer than 30 m (s 7(3)(a)), or issue approvals permitting multiple aircraft (s 8(2)(a)). CASA therefore holds the administrative discretion to authorise departures from the instrument’s prohibitions.

• persons in charge of public safety or emergency operations: in the emergency context a person in charge of the operation may give oral approval for unmanned aircraft or rocket operations over the relevant operational area when "necessary for the purposes of the operation," but the oral approval must be recorded and retained with appropriate details (s 6(2)(b)). That person in charge becomes a delegated decision maker in the field with a contemporaneous recording obligation.

• operators and controllers of rockets: the instrument explicitly applies to rockets as well as unmanned aircraft (s 4). The definition of rocket imports the CASR Dictionary and expressly includes firework projectiles (s 3(1) and note). Persons launching or controlling rockets must therefore observe the prohibition against operations over emergency scenes and other applicable directions.

• persons physically near operations: an indirect but practical effect is that members of the public and other bystanders are beneficiaries of the safety zone protection in s 7. The instrument’s notional 30 m radius safety zone around "another person" creates a constraint on where unmanned aircraft and model aircraft can be operated in the presence of other people.

Excluded categories and limits:

• indoor operations: the instrument expressly excludes operations referred to in paragraphs 101.005(3)(b) and (c) of CASR, which the instrument notes refer to certain indoor operations. Those indoor operations are not affected by the instrument (s 4 and accompanying note).

• micro RPA and other carve‑outs: micro RPA and certain other small‑scale operations are treated differently under the exceptions in ss 7(3)(c) and 8(2)(a), where a CASA approval for the purposes of that paragraph is a potential exception.

In short, the instrument imposes primary obligations on those who control unmanned aircraft and rockets and secondary oversight obligations on operators, while preserving a network of approvals, licences and exemptions that affect CASA, certified operators and licence holders.

The instrument sets out a compact set of duties for controllers and operators and identifies a limited set of rights or exceptions that may be exercised through approvals, licences or certifications. The duties and the corresponding exception pathways are summarised below, with section references.

Duties on controllers and operators

• Height ceiling for RPA and model aircraft: A person controlling an RPA or a model aircraft must not operate the aircraft higher than 400 ft above mean sea level AGL. This is an absolute directional duty except where an exception applies (s 5(1)).

• No operation over emergency or public safety areas: A person controlling an unmanned aircraft or a rocket must not operate over an area where a fire, police or other public safety or emergency operation is being conducted (s 6(1)).

• Respect safety zones around other people: A person controlling an RPA or model aircraft must ensure the aircraft is not operated in, or over, another person’s safety zone, unless the other person has duties essential to control or navigation of the aircraft (s 7(1)). The safety zone is a 30 metre horizontal radius cylinder rising from the ground or water surface the person is on or directly above, with no ceiling for safety purposes (s 7(2) and note).

• Single aircraft at a time: A person controlling an RPA or model aircraft must only operate one aircraft at a time (s 8(1)).

• Operator oversight: The operator must ensure the controller complies with applicable directions in this instrument and is familiar with and follows the operator’s approved practices and procedures designed to ensure such compliance (s 9(a)-(b)).

Exception pathways and rights

• CASR authorisations and exemptions: The instrument repeatedly preserves authorisations or exemptions granted under CASR that permit departures from the instrument’s prohibitions. For example, the 400 ft AGL prohibition does not apply where operation is in accordance with an authorisation or exemption under CASR permitting higher flight (s 5(2)(a)(i)). Similarly, the safety zone prohibitions do not apply where the operation is in accordance with an authorisation or exemption under CASR permitting operation within 30 m (s 7(3)(b)). The instrument uses the phrase "authorisation (however called) or exemption granted under CASR," which embraces a range of regulatory instruments issued under CASR (s 5(2)(a)(i); s 7(3)(b); s 8(2)(b)).

• CASA written approvals and approved areas: Some exceptions require a written CASA approval. For example, the 400 ft limit does not apply to operations in an "approved area" under regulation 101.030 of CASR (s 5(2)(a)(ii)). The safety zone exception for a model aircraft may be satisfied by a written CASA approval (s 7(3)(a)). The emergency operation exception may be satisfied by written CASA approval (s 6(2)(a)).

• Remote pilot licence and operator certification: The 400 ft AGL prohibition does not apply to an RPA operated by a holder of a remote pilot licence in accordance with the licence’s privileges and with the certification of the RPA operator conducting the operation (s 5(2)(b)(i)-(ii)). That preserves authorised professional operations consistent with the licence and operator certification.

• Oral approval by person in charge of an emergency operation: For emergency operations where it is "necessary for the purposes of the operation," oral approval by the person in charge of the operation is a permitted exception, provided a record containing appropriate details of the oral approval is made and retained (s 6(2)(b)). This creates a situational field‑level delegation of approval authority in time‑sensitive circumstances.

Operational constraints and interpretive notes

• "Another person" is not further defined in the instrument; the safety zone applies to any such person as described in s 7(2).

• The safety zone has no ceiling for safety purposes, meaning the instrument treats the notional cylinder as extending upward indefinitely for the purpose of the prohibition in s 7(1) (s 7(2) note).

• Where the instrument requires approvals or exemptions, the text often requires an approval "for the purposes of this paragraph," which limits the scope of the approval to the particular instrument paragraph and indicates the approval must be framed to address the specific prohibition being overridden (for example ss 5(2)(a)(ii), 7(3)(a), 8(2)(a)).

Recordkeeping duty linked to approvals

• The instrument requires that, when a person in charge gives an oral approval for operation over an emergency area, "a record is made and retained containing appropriate details of the oral approval" (s 6(2)(b)). The obligation to retain a record is the only explicit recordkeeping duty in the instrument. The instrument does not specify retention periods or a format; it requires merely that an appropriate record be made and retained.

Taken together, the instrument imposes clear operational duties with a well defined set of exceptions exercised through CASA written approvals, CASR authorisations or exemptions, and professional licence privileges. The operator has a non‑delegable duty to ensure controllers both comply and are trained or familiar with approved procedures intended to secure that compliance (s 9).

The instrument itself does not specify penalties, sanctions, or a discrete enforcement regime. It is framed as a directions instrument made under CASR regulation 11.245 and contains mandatory directions that controllers and operators must follow (instrument header; ss 5-9). The absence of express penalty provisions in the instrument means that any enforcement, infringement notices, or prosecution would rely on the enforcement powers and penalty provisions available under the Civil Aviation Act 1988 and CASR, or other applicable legislative instruments; those external mechanisms are not set out in this instrument.

Practical enforcement and evidentiary consequences that follow from the instrument’s text include:

• prima facie breach evidence: The instrument establishes bright‑line prohibitions (for example s 5(1) regarding the 400 ft AGL ceiling and s 8(1) regarding single‑aircraft operation). Where factual circumstances show a controller exceeded those boundaries, the instrument provides a clear legal standard on which an enforcement agency or court could rely even though this instrument does not itself list penalties.

• approvals as compliance defences: Compliance will often be demonstrated by producing the relevant authorisation, exemption, CASA approval, remote pilot licence privileges, or operator certification that qualifies as an exception under the instrument. Where an operator or controller acts under an authorisation/exemption or written CASA approval, possession of that instrument is central to establishing compliance with the directions.

• oral approvals and evidential risk: The instrument permits oral approval by the person in charge of a public safety or emergency operation in limited circumstances, but requires that an appropriate record of that oral approval be made and retained (s 6(2)(b)). That creates an evidentiary mechanism. In enforcement or dispute contexts, the existence, content and quality of the retained record will be material to assessing whether a controller was lawfully operating under an oral approval.

• oversight duty of operators: Section 9 imposes a duty on operators to ensure controllers comply and are familiar with approved practices and procedures. That creates a potential compliance and vicarious liability pathway in which enforcement or administrative action could be directed at operators for allowing non‑compliant operations, though the instrument does not itself state how liability would be allocated.

• administrative discretion and monitoring: CASA retains a central role in granting written approvals and in interpreting authorisations or exemptions under CASR that qualify as exceptions to the directions. Enforcement will, therefore, require CASA to exercise administrative discretion in authorisations and approvals as well as in any compliance monitoring or enforcement activities.

What the instrument does not do

• It does not set out penalty amounts, infringement notice schemes, or specific criminal or civil offences linked directly to breach of the instrument’s directions.

• It does not define the procedural steps of enforcement, such as notice periods, rectification plans, infringement notice processes or appeal routes within the instrument text.

Consequently, compliance and enforcement practitioners should view CASA 20/25 as a layer of binding operational directions whose breach creates regulatory risk, but they must consult the Civil Aviation Act 1988, CASR and CASA enforcement policies to identify the specific penalties and enforcement processes that would be applied in practice. The instrument embeds processes,written approvals, authorisations/exemptions, licence privileges and records of oral approvals,that will be relied upon in enforcement and evidentiary contexts.

The instrument explicitly situates itself within the existing CASR and Civil Aviation Act 1988 framework. The interactions the instrument creates or preserves are set out in its own text. Key cross‑references and interaction points are:

• authority under CASR: The instrument is made by a CASA delegate under regulation 11.245 of CASR (instrument header). That locates the instrument’s legal source in the CASR architecture, meaning its directions rely on the delegated rule‑making and direction powers conferred by CASR.

• alignment with Part 101: Section 3(2) states that, subject to s 3(1), words and phrases used in the instrument have the same meaning as in Part 101 of CASR and the Civil Aviation Act 1988 unless a contrary intention appears. That expressly aligns the instrument’s terminology and interpretive baseline with Part 101. The instrument therefore operates as an overlay while preserving Part 101 terminology and concepts.

• preservation of CASR authorisations, exemptions and approvals: Multiple provisions preserve authorisations, exemptions or approvals under CASR as exceptions to the instrument’s directions. For example, the 400 ft AGL ceiling is subject to authorisations or exemptions issued under CASR, approved areas under reg 101.030 of CASR, and remote pilot licence privileges and operator certification (s 5(2)). The safety zone and single‑aircraft rules are also subject to authorisations, exemptions or CASA approvals under CASR (s 7(3)(b); s 8(2)(b)).

• specific cross‑reference to reg 101.030 and paragraphs 101.005(3)(b) and (c): The instrument invokes an "approval of an approved area under regulation 101.030 of CASR" as one pathway for permission to operate above the 400 ft limit (s 5(2)(a)(ii)). It also excludes operations mentioned in paragraphs 101.005(3)(b) and (c) of CASR, which are noted as certain indoor operations and are not affected by this instrument (s 4 and accompanying note). This shows the instrument is designed to operate in conjunction with specific CASR provisions rather than displacing them.

• reliance on CASR Dictionary: The instrument takes the definition of "rocket" from the CASR Dictionary and explicitly includes firework projectiles for the instrument’s purposes (s 3(1) and note). Definitions in CASR therefore feed directly into the instrument’s scope.

• interaction with licences and operator certification: The instrument preserves the privileges associated with a remote pilot licence and the certification of the RPA operator in determining whether an operation is permitted to exceed the 400 ft AGL limit (s 5(2)(b)). That means CASA licensing and operator certification regimes under CASR and the Act continue to be determinative in many cases.

• no separate statutory carve‑out for other Commonwealth or State laws: The instrument does not expressly override or deal with other Commonwealth, State or local laws that might regulate activities on land, maritime foreshore, public safety operations, or civil liability. It regulates aviation‑related conduct via directions under CASR and assumes interaction with CASR and the Act for enforcement and authorisation.

Net effect

The instrument is an instrument of CASA that modifies conduct by imposing directions while deferring in multiple places to the substantive CASR framework for authorisations, exemptions, licences and certifications. It is therefore best read as a regulatory overlay that tightens operational constraints in certain respects while preserving the existing CASR pathways for exceptions and approvals. Practitioners should treat CASA 20/25 as operationally interdependent with Part 101 of CASR, reg 101.030 and the CASR Dictionary because those instruments supply definitions, authorisation pathways and approved area mechanisms referenced throughout CASA 20/25.

This instrument contains its own limited temporal and formal history within its introductory provisions. The text records the following immutable items:

• instrument identity and maker: The instrument is titled CASA 20/25 - Operation of Certain Unmanned Aircraft and Rockets - Directions Instrument 2025 and is numbered CASA 20/25. It is made by the Executive Manager, National Operations & Standards, a CASA delegate, under regulation 11.245 of CASR. The instrument is signed "S. Campbell" and dated 27 March 2025 (instrument header and signature block).

• commencement and expiry: The instrument commences on 1 April 2025 and is repealed at the end of 31 March 2028, ceasing to be in force from 1 April 2028 (s 2). The instrument explicitly states that the repeal clause is "for the purposes of paragraph 11.250(a) of CASR" (s 2(c) and note). That frames the instrument as time‑limited, operating over a three‑year window.

• absence of further amendment entries: The instrument text does not record any amendments, variations, or prior forms. It contains no schedule of amendments, transitional provisions other than its duration, or reissue notes. There are no provisions in the instrument that set out how it may be amended, nor any interim amendment history recorded in the instrument itself.

What practitioners should note

• The instrument is a discrete, time‑limited measure with a clear start and end date. Any change to its terms or effective dates would necessitate a subsequent instrument or amendment under CASR; there is no internal mechanism in CASA 20/25 that autonomously extends or alters its duration.

• Because the instrument contains no recorded amendments, users should verify whether subsequent instruments or amendments have been made under CASR that replace, extend or repeal CASA 20/25 after the instrument’s date. The instrument itself contains the dates relevant to its operational life and does not contain transition clauses beyond its own expiry.

• The instrument’s repeal at the end of 31 March 2028 will remove the directions unless a new instrument is made; during its three‑year life the directions are effective and binding as expressed.

In short, the instrument’s own amendment history is effectively nil: it was made 27 March 2025, commences 1 April 2025 and is expressly repealed on 31 March 2028. Any change outside that timeline would be effected by later administrative action not recorded within this instrument.

The instrument contains no record of litigation, judicial interpretation, or administrative review decisions. It does not reference any court judgments, tribunal decisions or past enforcement actions. The text is a stand‑alone directions instrument and provides no annexed litigation history or precedent.

Practical implications for litigation risk and likely dispute areas

• matters of factual interpretation: Because the instrument relies on physical thresholds and spatial concepts, litigation or administrative disputes would likely centre on facts. Examples include determining whether an RPA exceeded 400 ft AGL (s 5(1)), whether an aircraft operated within the notional 30 m safety zone around "another person" (s 7(2)), and whether more than one aircraft was under control by a person at a time (s 8(1)). The instrument’s bright‑line measures create clear factual questions susceptible to evidential disputes.

• authorisations and exemptions as focal points: Many of the instrument’s carve‑outs turn on the existence and scope of authorisations, exemptions or approvals under CASR or CASA written approvals (s 5(2), s 6(2)(a), s 7(3)). Disputes are likely to involve whether a particular authorisation or approval lawfully covered the operation in question. Litigation could centre on whether the document relied on was validly issued, properly framed "for the purposes of this paragraph," or valid at the time of the operation.

• oral approvals and record sufficiency: The instrument allows oral approvals by the person in charge of a public safety operation when necessary for the operation’s purposes, but requires that "a record is made and retained containing appropriate details" (s 6(2)(b)). Where an operator or controller claims to have relied on an oral approval, litigation could turn on whether an adequate record was made and retained, what "appropriate details" are, and the timing and content of that record.

• operator oversight duties: Section 9 imposes an operator duty to ensure controllers comply and follow the operator’s approved practices and procedures. Litigation may engage whether an operator’s practices and procedures were adequate and whether the operator took reasonable steps to ensure controller familiarity and compliance. Such proceedings could involve review of an operator’s internal documentation and training records.

• interpretive disputes tied to definitions: The instrument relies on CASR definitions through s 3(2) and imports the CASR Dictionary definition of "rocket" (s 3(1)). Litigation could arise over the precise reach of those definitions, for example whether a particular airborne device is a "model aircraft," "RPA" or "rocket" for instrument purposes. The instrument itself does not clarify those definitional boundaries; it defers to CASR and the Act for meaning.

Limitations on what the instrument shows

• The instrument does not evidence any past litigation, appellate decision or administrative adjudication that would guide interpretation. For that reason, courts and tribunals would have to apply general statutory and administrative law interpretive principles when construing the instrument in any contested case.

• Because penalties and enforcement procedures are located outside the instrument, litigation about sanctions will involve the Civil Aviation Act 1988 and CASR, rather than being resolvable from CASA 20/25 alone.

In sum, CASA 20/25 contains no litigation history; however, its content points to predictable factual and administrative law dispute areas, notably regarding factual compliance with spatial limits, the scope and validity of authorisations and approvals, sufficiency of records for oral approvals, and the adequacy of operator oversight arrangements.

The instrument is concise, but its text contains several features that can produce compliance traps or operational ambiguity for controllers, operators, emergency services and approvers. The following "gotchas" are grounded in the instrument’s wording and structure.

1. Safety zone has no ceiling: The note to s 7(2) states that "for the safety purposes of this instrument, there is no ceiling to the safety zone." Practically, that means the notional 30 metre horizontal radius cylinder is treated as extending upward indefinitely for the purpose of the prohibition in s 7(1). Controllers cannot rely on altitude to escape the safety zone prohibition.

2. "Another person" is broad and undefined: Section 7(1) prohibits operation in or over "another person’s safety zone" unless the other person is performing duties essential to controlling the aircraft. The instrument does not define "another person." That could include bystanders, passengers on vessels, people in buildings or workers on the ground. Controllers must be conservative in identifying who constitutes "another person" in crowded locations.

3. Oral approval requires an "appropriate" retained record but gives no retention standard: Section 6(2)(b) permits oral approvals by the person in charge of an emergency operation where necessary, but it requires that "a record is made and retained containing appropriate details of the oral approval." The instrument does not specify what constitutes appropriate details or how long the record must be kept. This creates evidential risk if an oral approval is claimed without a contemporaneous record meeting enforcement expectations.

4. Multiple exception routes, varying thresholds: The instrument repeatedly permits operations contrary to its prohibitions if done "in accordance with" an authorisation/exemption under CASR or with CASA approval. Those exception pathways are not uniform. For example, the 400 ft limit may be overridden by an "approved area" (reg 101.030) or by remote pilot licence privileges, whereas safety zone exceptions may require CASA written approval or authorisations under CASR. Operators and controllers must navigate multiple administrative routes rather than relying on a single, consistent approval framework.

5. Micro RPA and model aircraft carve‑outs: The single‑aircraft rule in s 8(1) is subject to an approval for micro RPA or model aircraft where CASA gives an approval under s 8(2)(a) or an authorisation/exemption under CASR permitted by s 8(2)(b). The absence of a default national exemption for common multi‑aircraft recreational activities means operators should not assume multi‑aircraft operations are permitted without explicit CASA approval or CASR authorisation.

6. Operator responsibility goes beyond the controller’s conduct: Section 9 requires the operator to ensure controllers comply and are familiar with the operator’s approved practices and procedures. This creates a compliance obligation for operators to maintain and communicate procedures, and to demonstrate that controllers have been trained or briefed. Operators who lack formal practices or who fail to document controller familiarity may face regulatory scrutiny.

7. Indoor operations excluded but narrow: The instrument explicitly excludes operations mentioned in paragraphs 101.005(3)(b) and (c) of CASR, which the instrument notes are certain indoor operations (s 4 note). However, the instrument does not broaden that exclusion. Controllers operating in semi‑enclosed or partially indoor environments should verify whether their operation falls within the excluded paragraphs rather than assume it is exempt.

8. Rocket definition includes fireworks: The instrument imports the CASR Dictionary definition of "rocket" and explicitly states it includes a firework projectile for the instrument’s purposes (s 3(1) and note). Operators of fireworks could be subject to the prohibitions, particularly the emergency area and safety zone rules.

9. Lack of on‑instrument penalties and appeal language: The instrument does not specify penalties, nor does it state appeal or review processes. Parties must therefore map enforcement and dispute mechanisms to the Civil Aviation Act 1988 and CASR. Failure to appreciate this can lead to misplaced expectations about remedies or timelines following enforcement action.

10. "However called" and "for the purposes of this paragraph" language: The instrument uses broad phrasing such as "an authorisation (however called) or exemption granted under CASR" and limits CASA approvals to those given "for the purposes of this paragraph" (see s 5(2)(a)(i); s 7(3)(a); s 8(2)(a)). That language signals a flexible administrative approach but also introduces interpretive uncertainty about the required content and form of executive approvals. Approvers and applicants should ensure approvals are expressly framed to address the specific paragraph and prohibition they are intended to override.

These features mean compliance requires attention to definitional detail, recordkeeping practice for oral approvals, and management of operator procedures and documentation. Controllers and operators should not rely on informal understandings or assumptions about exceptions without specific CASA written approvals or authoritative CASR authorisations.

The instrument sets out mandatory directions and exception pathways. The practical compliance measures that logically follow from the instrument’s text are described below. These are operational steps grounded in the instrument’s prescriptions.

1. Know which category your device falls into (s 3(1)-(2))

• Determine whether the aircraft or projectile you operate is an RPA, model aircraft, micro RPA, tethered balloon, unmanned free balloon, rocket, or other unmanned aircraft as defined in s 3(1). Where the instrument defers to Part 101 terminology, confirm the applicable Part 101 definition applies. Rockets include firework projectiles per the instrument.

2. Respect the 400 ft AGL limit unless authorised (s 5(1)-(2))

• Plan operations so RPA and model aircraft do not exceed 400 ft AGL except where you have an express, applicable exception. Exceptions include a CASR authorisation or exemption permitting higher operation, operation within an "approved area" under reg 101.030 of CASR, or operation by a holder of a remote pilot licence in accordance with licence privileges and operator certification (s 5(2)). If you intend to fly above 400 ft, secure the relevant authorisation, an approved area designation, or ensure your remote pilot licence and RPA operator certification authorise the flight.

3. Do not operate over emergency or public safety operations unless approved (s 6(1)-(2))

• Avoid flying over areas where fire, police or other public safety or emergency operations are being conducted. If the operation is necessary for the public safety operation, obtain a written CASA approval (s 6(2)(a)) or oral approval from the person in charge of the operation (s 6(2)(b)). If relying on oral approval, ensure that a detailed contemporaneous record of the oral approval is made and retained as required by s 6(2)(b).

4. Observe the 30 m safety zone (s 7(1)-(3))

• Do not operate in or over the notional cylindrical safety zone of another person with a horizontal radius of 30 m from the person’s position, rising from the ground or water surface the person is on or directly above (s 7(2)). Because there is no ceiling to the safety zone for safety purposes, plan horizontal separation accordingly. Exceptions require a CASA approval or a CASR authorisation/exemption that specifically permits operation less than 30 m from another person; ensure the relevant paperwork is on hand for inspection.

5. Operate only one aircraft at a time unless authorised (s 8(1)-(2))

• Ensure persons controlling RPAs or model aircraft operate only a single aircraft at a time. For multi‑aircraft operations, obtain a CASA approval for micro RPA/model aircraft where applicable, or a CASR authorisation/exemption permitting multiple aircraft. Do not assume informal arrangements will suffice.

6. Maintain operator oversight and procedures (s 9)

• Operators must ensure controllers comply with applicable directions and are familiar with and follow the operator’s approved practices and procedures. Develop, document and implement operator approved practices and procedures that specifically address the instrument’s prohibitions and exceptions. Ensure controllers are trained, briefed and can demonstrate familiarity with those procedures.

7. Recordkeeping for oral approvals and approvals documentation (s 6(2)(b); s 5(2); s 7(3); s 8(2))

• Maintain written copies of all CASA approvals, CASR authorisations and exemptions relied upon to operate in contravention of the instrument’s prohibitions. For oral approvals given by the person in charge of emergency operations, create and retain a contemporaneous record containing the appropriate details of the oral approval. The instrument does not define "appropriate", so include date, time, identity of person giving approval, scope of approval, operational location, and names of controllers and operators to reduce evidential friction.

8. Coordinate with emergency services and persons in charge (s 6(2)(b))

• Where your operations may intersect with emergency services, coordinate with the relevant person in charge to obtain necessary approvals. Ensure any oral approvals are promptly documented in accordance with s 6(2)(b).

9. Verify remote pilot licence and operator certification privileges (s 5(2)(b))

• If you intend to rely on remote pilot licence privileges to operate above 400 ft, verify that the licence privileges and the certification of the RPA operator for the operation align with the intended flight and that relevant documentation is accessible.

10. Confirm indoor operation exclusions (s 4)

• If operations are being conducted indoors or within the scope of paragraphs 101.005(3)(b) and (c) of CASR, check whether the particular operation falls within those excluded categories, because the instrument expressly does not affect those indoor operations (s 4). If in doubt, obtain written clarification or a CASA approval.

11. Treat approvals "for the purposes of this paragraph" carefully

• When seeking CASA approvals or CASR authorisations that are to relieve a specific prohibition in the instrument, ensure applications and approvals expressly reference the paragraph of CASA 20/25 they are intended to address. The instrument’s language often limits exceptions to approvals or authorisations "for the purposes of this paragraph" (for example s 5(2)(a)(ii); s 7(3)(a); s 8(2)(a)). Explicit cross‑referencing reduces interpretive disputes.

12. Operational compliance documentation

• Keep a compliance pack that contains: relevant CASA approvals and letters, copies of CASR authorisations or exemptions relied upon, pilot licences and operator certifications, operator approved procedures, training records or briefings showing controller familiarity, and records of any oral approvals with appropriate details. The instrument emphasises retained records for oral approvals and operator procedures but does not set retention durations. Retain records prudently to support compliance for the duration of the instrument and for a reasonable period thereafter to address any post‑operation inquiries.

By following these steps that are directly derived from the instrument’s text, operators and controllers can align their procedures to the directions in CASA 20/25. Where the instrument defers to CASR authorisations, exemptions or CASA written approvals, secure those instruments in advance of the operation and retain them as evidence of compliance.