CASA 66/24 — Operation of RPA Within 3 Nautical Miles of a Controlled Aerodrome (CASA-Verified Drone Safety App) Instrument 2024

Definitions and delegated infrastructure are central. The instrument defines and relies on the following main concepts: “relevant approved area”, “operating area”, CASA RPAS digital platform, CASA‑verified drone safety app, remote pilot, RPA operator, measurement point and approved area as drawn from the Part 101 Manual of Standards and CASR (Definitions; s 3). Those definitions create an architecture in which CASA supplies aeronautical data via a digital platform, third‑party apps connect to that platform, CASA verifies apps and lists them on its website, and those apps describe operating areas within which the instrument’s directions apply.

Key definitional links in the instrument:

• “Operating area” is the segment of airspace described on a CASA‑verified app, defined by horizontal and vertical limits within a relevant approved area, in which an RPA may be operated under subsection 4.03(7) of the Part 101 Manual of Standards (Definitions).
• “Relevant approved area” is an area approved under section 4; section 4 approves areas below 400 ft AGL and within 3 NM of a runway measurement point of a relevant controlled aerodrome (s 4).
• “CASA RPAS digital platform” and “CASA‑verified drone safety app” link operational control to digital services: the platform is the CASA digital platform accessible by third‑party app developers; verified apps are those connected to that platform and listed on CASA’s website (Definitions).

Operational rules are a second main concept. Section 5 imposes specific directions on remote pilots operating in an operating area. Those include registration via the verified app (s 5(1)), compliance with app‑notified operating limitations (s 5(2)), limitation of the operation to aerial work operations (s 5(3)), exclusivity of the RPA being flown (no other RPA to be operated concurrently, s 5(4)(a)), communications and monitoring duties (s 5(4)(b)-(c)), immediate notification to ATC if the RPA leaves the operating area (s 5(6)), limited transmission on ATC frequencies (s 5(7)), equipment fail‑safe requirements (s 5(8)), and restrictions on activating transponders or ADS‑B transmissions absent ATC direction (s 5(9)). An exception to maintaining a listening watch is provided when operating within 100 metres laterally from, and below, an obstacle other than an aircraft (s 5(5)).

Authority and temporal scope are a third concept. The instrument is made under specified CASR provisions and a Manual of Standards subsection, and it is time‑limited (ss 1-2). The instrument’s note references regulation 11.250 concerning the cessation of the directions at the repeal date (s 2 note).

Finally, precedence is a concept: where the directions in this instrument conflict with an RPA operator’s documented practices and procedures, the pilot must comply with the instrument (s 5(10)). That creates an explicit rule that these directions override operator documentation in conflict situations.

The instrument expressly affects a defined set of parties. Primary duties fall on remote pilots (see Definitions and s 5). Remote pilot is defined as the holder of a remote pilot licence or a person taken to hold one under subregulation 202.461(3) of CASR (Definitions). RPA operators are also directly implicated: an RPA operator must be “certified as an RPA operator under regulation 101.335 of CASR” for the term “RPA operator” to apply (Definitions), and operators must register via a CASA‑verified drone safety app to authorise operation in an operating area (s 5(1)(a)). Pilots who are members of personnel of a registered RPA operator are covered by the alternative registration pathway in s 5(1)(b).

Airservices Australia is a named actor insofar as it applied (ARN 202210) for the approvals that CASA grants in s 4(1). CASA and its digital services are central: the CASA RPAS digital platform, CASA‑verified drone safety apps, and the CASA website are expressly referenced in the Definitions; verified apps must be listed on CASA’s website (Definitions).

Other aviation actors are affected indirectly. Air traffic control (ATC) becomes an active participant during the operation: pilots must take reasonable steps to ensure reliable VHF coverage and maintain a listening watch on the relevant ATC frequency from 15 minutes before flight until landing (s 5(4)(b)(i)-(ii)), notify ATC immediately if the RPA leaves the operating area (s 5(6)), and comply with ATC directions (s 5(4)(d)). ATC also has the power to direct pilots to transmit on ATC frequencies; otherwise pilots must not transmit (s 5(7)). The instrument limits the use of transponders and ADS‑B by pilots during RPA operations unless ATC directs activation (s 5(9)).

Third‑party app developers who connect to the CASA RPAS digital platform are implicated by the instrument’s architecture. The instrument ties authorisation and publishing of operating areas to CASA‑verified apps (Definitions), and it refers users to the CASA website for the list of verified apps.

Finally, the instrument affects any person intending to operate an RPA within the described airspace. Section 4(2) defines the geographic and vertical limits , below 400 ft AGL, within 3 nautical miles of a runway measurement point of a relevant controlled aerodrome , thereby identifying the physical domain and the population of flights covered.

Who pays and who decides. The instrument places the immediate compliance obligations on remote pilots and RPA operators (s 5). Costs of registration, app access, communications capability, and ensuring equipment features (fail‑safe modes, ability to comply with VHF and mobile coverage expectations) will fall on those pilots and operators. CASA decides which apps are verified and lists them on its website; Airservices Australia initiated the approval application that led to the approved areas (s 4(1)).

The instrument sets out mandatory duties for remote pilots operating in an operating area and defines limited permissions and prohibitions. Duties are concentrated in section 5; the principal duties follow.

Registration and authorisation: If the pilot is an RPA operator, the operator must be registered using a CASA‑verified drone safety app to be authorised to operate in the operating area during the period notified on the app (s 5(1)(a)). Alternatively, a pilot may be covered if they are personnel of an RPA operator that has registered using a CASA‑verified app (s 5(1)(b)). The app is the mechanism by which authorisation, timing, and operating limitations are communicated (s 5(2)).

Compliance with operating limitations: The pilot must comply during the operation with any operating limitations notified on the CASA‑verified app relevant to the operation and the registration (s 5(2)). That places operational constraints in the hands of the app‑displayed limitations; the instrument makes compliance with those notified limitations mandatory.

Scope of permitted operations: The pilot must conduct the RPA operation only as an aerial work operation (s 5(3)). The instrument therefore limits operations in the approved areas to aerial work operations, excluding other types of RPA activity for the duration of the instrument’s operation.

Single RPA and personnel conditions: The pilot must not operate any other RPA during the operation (s 5(4)(a)). Personnel who are not the registered operator’s personnel are captured only if they are a member of personnel of a registered RPA operator (s 5(1)(b)).

Communications and monitoring duties: The pilot must take reasonable steps to ensure reliable VHF coverage exists in the operating area enabling communication with ATC, and must maintain a listening watch on the relevant ATC frequency from 15 minutes before flight until landing (s 5(4)(b)(i)-(ii)). There is a narrow exception where paragraph (4)(b) does not apply if the pilot is operating within 100 metres laterally from, and below, an obstacle other than an aircraft (s 5(5)). The pilot must also take reasonable steps to ensure reliable mobile phone coverage and must comply with any ATC direction in relation to the operation (s 5(4)(c)-(d)).

Notification duties: If the RPA leaves the operating area during the RPA operation, whether or not under pilot control, the pilot must notify ATC of the event immediately after it happens (s 5(6)). This creates an immediate reporting obligation on the pilot for any exit from the operating area.

Transmission restrictions: The pilot must not transmit on the relevant ATC frequency during the RPA operation unless directed by ATC to do so or when making the notification to ATC under s 5(6) (s 5(7)). This confines pilot‑initiated transmissions to discrete circumstances, leaving routine radio transmissions controlled by ATC direction.

Equipment and fail‑safe requirements: The pilot must ensure the RPA is equipped and operated with an active fail‑safe mode that, on data link loss, will: adjust altitude to a minimum safe level for obstacle clearance and minimum potential collision risk; transit to a pre‑defined safe landing or flight termination area; and land or otherwise end the flight (s 5(8)(a)-(c)).

ADS‑B and transponder restriction: Unless directed by ATC, the pilot must not activate any transponder fitted to the RPA or activate transmission of ADS‑B position information by the RPA during the operation (s 5(9)(a)-(b)).

Precedence over operator documentation: If there is an inconsistency between the RPA operator’s documented practices and procedures and a direction in section 5, the pilot must comply with the direction in section 5 (s 5(10)). That explicitly prioritises the instrument’s directions over operator documentation in conflict scenarios.

Rights are limited and procedural. The instrument does not confer expansive rights beyond the authorisation to operate in approved areas where the directions are met. It provides a mechanism (registration through a CASA‑verified app) to be authorised for operations in the defined airspace (s 5(1)). It also provides that ATC may direct operation changes, and pilots must comply (s 5(4)(d)). The instrument does not itself set out appeal, review or exemption procedures; it does not state penalties or enforcement mechanisms within its text. Any enforcement or penalties would therefore fall under the broader statutory and regulatory framework under which the instrument was made (see preamble and ss 1-2), but no penalty provisions are inserted in the instrument itself.

The instrument itself contains no express penalty schedules or enforcement wording within its text. It is made under regulations 11.245 and 101.030 of CASR and subsection 4.03(7) of the Part 101 Manual of Standards (instrument preamble). Those source authorities are the legal basis for the directions, but the instrument does not reproduce enforcement mechanisms or civil/criminal sanctioning within its four corners.

Practical implications follow from the instrument’s making under CASR provisions: the directions in section 5 are issued under regulatory power (see instrument heading and preamble). The instrument includes a note that, for regulation 11.250 of CASR, the directions stated in section 5 cease to be in force at the instrument’s repeal date (end of 30 November 2026) (s 2 note). That ties the temporal operation of the directions to CASR’s regulatory regime. However, the instrument does not itself provide for inspections, notices, infringement notices, pecuniary penalties, or administrative sanctions.

Because the instrument imposes mandatory duties on remote pilots and RPA operators (for example, registration via a CASA‑verified app (s 5(1)), immediate notification to ATC if the RPA leaves the operating area (s 5(6)), and other operational duties in s 5), non‑compliance will be non‑compliance with the instrument’s directions. The instrument does not state what consequence attaches to non‑compliance within its text; enforcement and penalties, if any, will therefore need to be sought in the Civil Aviation Safety Regulations 1998 and other relevant statutory instruments under which CASA and its delegates exercise enforcement powers. The instrument’s silence on specific enforcement measures means practitioners must consult the CASR and the Civil Aviation Act 1988 for the enforcement regime that would apply to breaches of directions issued under the referenced regulations.

Operational compliance enforcement may also be practical and administrative. The instrument ties authorisation to registration via a CASA‑verified drone safety app (s 5(1)-(2)). That creates an administrative control point: lack of valid registration or failure to follow app‑notified operating limitations is a clear, verifiable breach of the instrument’s conditions. ATC plays an operational compliance role during flights; the instrument requires pilots to comply with ATC directions (s 5(4)(d)) and constrains when pilots can transmit on the ATC frequency (s 5(7)), which may be monitored in real time by ATC.

In sum, the instrument imposes mandatory operational duties but does not itself specify enforcement tools or penalties; the legal and administrative consequences of non‑compliance must be located in the broader CASR and Civil Aviation Act framework referenced in the instrument’s preamble and notes.

The instrument expressly operates within and references the wider Civil Aviation regulatory architecture. It is made under regulations 11.245 and 101.030 of the Civil Aviation Safety Regulations 1998 and subsection 4.03(7) of the Part 101 Manual of Standards (instrument preamble). It also imports defined terms and meanings from the Civil Aviation Act 1988, the regulations, and the Part 101 Manual of Standards (s 3 Note). Several defined terms refer to or are qualified by specific CASR provisions and MOS subsections, for example: “approved area” has the meaning given by regulation 101.236 of CASR; “documented practices and procedures” and “measurement point” have the meaning given by subsection 1.04(2) of the Part 101 Manual of Standards; “RPA operator” references regulation 101.335 of CASR; “remote pilot” cross‑references subregulation 202.461(3) of CASR (s 3).

The instrument also cross‑references internal Parts of the Part 101 Manual of Standards: it notes that the areas approved in s 4 accord with the areas described in paragraph (a) of the definition of no‑fly zone of a controlled aerodrome in section 4.02 of the Part 101 Manual of Standards (s 4(2) note). The operating area is expressly defined as an area that may be used “under subsection 4.03(7) of the Part 101 Manual of Standards” (Definitions). These cross‑references mean that the instrument’s practical application depends on the content of the cited CASR provisions and Manual of Standards, which locate the instrument within the established regulatory scheme for RPA operations.

Precedence and conflict: The instrument specifies that if there is an inconsistency between a requirement of an RPA operator’s documented practices and procedures and a direction in section 5, the pilot must comply with the direction (s 5(10)). That creates a clear prioritisation of the instrument’s directions over operator documentation where they conflict. The instrument does not expressly state how it interacts with other potentially applicable CASR provisions in cases where the operator’s documented practices align with but the CASR contains separate prescriptions; practitioners must look to the broader CASR framework for resolving such conflicts.

Temporal interaction: The instrument is time‑limited , it commences on 16 November 2024 and is repealed at the end of 30 November 2026 (s 2). The instrument contains a note referencing regulation 11.250 of CASR for the cessation of the directions in s 5 at the repeal date. That means the instrument is a temporary overlay on existing CASR and MOS obligations; how it interacts with longer‑term statutory provisions depends on whether subsequent instruments or amendments are made.

Operational interfaces: The instrument sets up an administrative and technical interface between CASA’s digital services, third‑party apps, RPA operators, and ATC. It requires registration on a CASA‑verified app to be authorised to operate in the operating area (s 5(1)), and it makes compliance with app‑notified operating limitations mandatory (s 5(2)). This effectively integrates app‑based authorisation and notification into the regulatory compliance chain; the legal effect of a failure to follow app‑notified limitations is produced by the instrument’s directions, but accountability for that failure would be resolved under the CASR enforcement provisions.

What the instrument does not do: It does not amend CASR or the Part 101 Manual of Standards text within the instrument; it relies on the authority of CASR provisions to issue these directions. It does not itself provide enforcement mechanisms, penalties or appeal processes. It does not define the full content of the “documented practices and procedures” or other externally referenced terms beyond stating where those meanings are sourced (s 3).

Practitioners must therefore read this instrument alongside the cited CASR provisions and the Part 101 Manual of Standards to understand fully the legal regime governing RPA operations in the approved areas.

The instrument itself records a limited administrative history within its text. It bears instrument number CASA 66/24 and is signed by Paul Hibberd, a CASA delegate (preamble). Section 1 records the instrument’s name. Section 2 sets commencement on 16 November 2024 and an automatic repeal at the end of 30 November 2026. There are no amendments recorded within the instrument; the instrument is presented as a single instrument with a defined life span.

There is an internal administrative detail that the approval in section 4 follows an application made by Airservices Australia with application reference ARN 202210 under subregulation 101.030(1) of CASR (s 4(1)). That documents the provenance of the approved areas: Airservices Australia applied and CASA, via this instrument, approved the areas for RPA operation.

Beyond that, the instrument contains no entries indicating prior instruments amended, superseded, revoked, or otherwise modified. It does not include transitional provisions or express amendment clauses. The instrument’s temporal limitation (s 2) functionally means that any amendment to prolong or alter these directions would need to be effected before the repeal date, or a new instrument made to replace it. The instrument also includes notes that connect it to regulation 11.250 of CASR for the cessation of the directions at the repeal date (s 2 note), which implies that CASR contains the mechanism for timing and cessation , however, the instrument does not record any historic amendments to CASR itself.

Practitioners should therefore treat this instrument as a discrete, time‑limited grant of approval and set of directions, made on Airservices Australia’s application, with no amendment history recorded in the instrument. Any changes to these directions before the repeal date would require a new instrument or an amendment instrument; the text provided contains none.

The instrument contains no litigation history, and it does not reference any judicial or tribunal decisions. There are no cases, proceedings, or disputes recorded in the instrument’s text. The instrument is a standalone administrative instrument issued by CASA under specified regulatory powers and does not purport to summarise or report on any litigation.

Implications of the absence of litigation history in the instrument:

• There is no statutory or judicial interpretation of the instrument’s provisions included in the document. Practitioners cannot rely on precedent or reported decisions for interpretive guidance from the instrument itself.
• Any legal controversies concerning interpretation, enforcement, or the validity of the instrument would have to be established through proceedings after the instrument’s commencement; none exist in the instrument’s text.
• Because the instrument relies on and references other regulatory instruments and the Part 101 Manual of Standards, litigation that interprets those source documents could be relevant in practice. However, the instrument does not record such litigation or its impact.

For practitioners advising clients or preparing compliance programmes, the lack of litigation history in the instrument means that legal risk assessments must rely on the instrument’s plain text and on the broader CASR and Manual of Standards framework. If disputes arise about the scope of duties (for example, whether a particular app‑notified limitation is enforceable or how the fail‑safe requirement in s 5(8) is to be applied to specific RPA equipment), those questions would be resolved in the applicable forums absent any existing precedent recorded in this instrument.

In short, there is no litigation history in the source text; any future litigation relating to these directions will need to be tracked in external case law and cannot be informed by content within this instrument.

The instrument creates several practical traps for pilots, operators and app developers because it ties authorisation and regulatory compliance to a specific digital and procedural pathway, and because certain requirements are phrased as “reasonable steps” or as absolute prohibitions. The following items are concrete operational “gotchas” drawn directly from the instrument’s wording.

1. App‑only authorisation pathway (s 5(1)-(2)). Authorisation to operate in an operating area is conditional on registration using a CASA‑verified drone safety app. If the app is not available, not verified, or the pilot/operator cannot register within the app, the instrument’s authorisation mechanism is not satisfied and the pilot cannot rely on the instrument’s permission to operate. The instrument does not provide an alternative authorisation method.

2. Authorisation tied to notified periods and limitations (s 5(1)(a), s 5(2)). Registration authorises operation only during the period notified on the app and requires compliance with any operating limitations notified on the app. Operators must ensure the app displays the correct periods and limitations; pilots must ensure they comply with whatever the app notifies. A mismatch between the intended operation and the app notification may produce immediate non‑compliance.

3. Operations limited to “aerial work operation” (s 5(3)). The instrument mandates that the operation must be conducted only as an aerial work operation. Pilots seeking to conduct recreational flights, training flights not classified as aerial work, or other non‑aerial‑work activities in the approved airspace will not be authorised under this instrument.

4. Communications and “reasonable steps” language (s 5(4)(b)-(c)). The pilot must “take reasonable steps” to ensure reliable VHF and mobile phone coverage and to maintain a listening watch on ATC frequency from 15 minutes before flight until landing. “Reasonable steps” is fact‑sensitive; in marginal coverage areas a regulator or inspector could scrutinise whether a pilot’s preparations met the reasonableness standard. Also note the exception in s 5(5) where the listening watch requirement does not apply for operations within 100 metres laterally from, and below, an obstacle other than an aircraft , this is a narrow exception that may not commonly apply.

5. Immediate notification obligation on leaving operating area (s 5(6)). If the RPA leaves the operating area for any reason, whether or not under pilot control, the pilot must notify ATC immediately after the event. That imposes an instantaneous reporting duty which requires pilots to have procedures and contingencies to contact ATC promptly.

6. Restrictions on ATC frequency transmissions (s 5(7)). Pilots must not transmit on the ATC frequency during the operation unless directed by ATC or to notify an exit under s 5(6). Pilots accustomed to routine transmissions might breach this prohibition if they speak without ATC direction.

7. Fail‑safe capability mandatory (s 5(8)). The RPA must be equipped and operated with an active fail‑safe mode that meets three cumulative requirements: adjust altitude to minimum safe level for obstacle clearance and minimal collision potential; transit to a predefined safe landing or flight termination area; and land or otherwise end the flight. Older or hobbyist RPA lacking such fail‑safe programming may not be capable of lawful operation in these areas.

8. Prohibition on transponder/ADS‑B activation (s 5(9)). Pilots must not activate any transponder fitted to the RPA or ADS‑B position transmission unless ATC directs. RPA that routinely broadcast ADS‑B may need to ensure they can disable that function during these operations, or obtain an explicit ATC direction.

9. Operator documentation subordinate to instrument directions (s 5(10)). If there is any inconsistency between an RPA operator’s documented practices and procedures and a direction in section 5, the pilot must comply with the instrument. That means operator checklists and SOPs must be reviewed against section 5 to avoid internal conflicts; otherwise the pilot is obliged to follow the instrument over operator policy.

10. App veracity and list availability (Definitions). The instrument requires use of a “CASA‑verified drone safety app”, defined as a software application connected to the CASA RPAS digital platform and listed as a verified app on the CASA website. The practical availability of verified apps, timing to be listed, and interface performance are points of operational fragility not addressed in the instrument.

11. Geographical and vertical limits (s 4(2)). The approved areas are strictly defined as below 400 ft AGL and within 3 NM of the runway measurement point. Pilots must ascertain whether their planned operation falls within the exact geometric definition of an operating area as published on the app; misreading the measurement point or vertical datum could lead to inadvertent breach.

12. No penalty language in the instrument. The instrument contains no penalties; however, the duties are cast as directions under CASR authority. Practitioners must therefore be careful to align operational practice with the instrument while also consulting CASR for enforcement consequences.

Each of the above items is a potential compliance pitfall that requires explicit operational procedures, equipment checks, app availability verification, and training for pilots and operators.

Complying with the instrument requires an operational checklist that maps the instrument’s mandatory directions onto concrete actions by operators and pilots. The following steps follow directly from the instrument’s text and notes, with section references provided for each step.

1. Establish whether the intended flight is within a relevant approved area. Section 4(2) approves areas that are below 400 ft AGL and within 3 nautical miles of the measurement point of any runway of a relevant controlled aerodrome. Confirm the exact operating area as published on a CASA‑verified drone safety app; the instrument defines an “operating area” as the segment of airspace described on that app (Definitions; s 4(2)).

2. Ensure the operation will be conducted only as an aerial work operation. Section 5(3) requires that the pilot conduct the RPA operation only as an aerial work operation. If the proposed flight is not aerial work, do not proceed under this instrument.

3. Use an authorised, CASA‑verified drone safety app. The instrument requires registration and notification via a CASA‑verified app that is connected to the CASA RPAS digital platform and listed on the CASA website (Definitions; s 5(1)-(2)). Confirm the app is on CASA’s verified list at https://www.casa.gov.au/drones/safety-apps (Definitions note). If necessary, coordinate with the app developer or CASA for access.

4. Register the RPA operator or ensure you are personnel of a registered operator. If you are the operator, register using the verified app to be authorised to operate in the operating area during the period notified on the app (s 5(1)(a)). If you are a pilot employed by an operator, confirm the operator has registered via the app and that you are included as personnel authorised under that registration (s 5(1)(b)).

5. Confirm the authorised period and comply with app‑notified operating limitations. The app will notify the period of authorisation and any relevant operating limitations; compliance with those limitations during the operation is mandatory (s 5(2)). Incorporate those app‑notified limits into flight planning and SOPs.

6. Ensure aircraft and equipment meet fail‑safe requirements. The RPA must be equipped and operated with an active fail‑safe mode that, in case of data link loss, adjusts altitude to the minimum safe level, transits to a predefined safe landing or flight termination area, and lands or otherwise ends the flight (s 5(8)(a)-(c)). Verify the RPA’s control software and hardware can perform these functions and document the pre‑defined safe landing area.

7. Prepare communications capability and procedures. Take reasonable steps to ensure reliable VHF coverage in the operating area and maintain a listening watch on the relevant ATC frequency from 15 minutes before takeoff until landing (s 5(4)(b)(i)-(ii)). Also take reasonable steps to ensure reliable mobile phone coverage (s 5(4)(c)). If operating within 100 metres laterally from, and below, an obstacle other than an aircraft, the listening watch requirement does not apply (s 5(5)). Establish and rehearse procedures for immediate notification to ATC if the RPA leaves the operating area (s 5(6)).

8. Train pilots on ATC interaction and transmission limits. Pilots must comply with ATC directions and must not transmit on the ATC frequency during the RPA operation unless directed by ATC or making the s 5(6) notification (s 5(4)(d) and s 5(7)). Train pilots to await ATC directions before transmission and to prepare concise notification messages for exit events.

9. Disable transponder/ADS‑B transmission unless ATC directs activation. Unless directed by ATC, pilots must not activate any transponder fitted to the RPA or transmit ADS‑B position information during the operation (s 5(9)). Ensure RPA equipment settings can comply with this restriction and document the procedures to enable/disable these functions consistent with ATC direction.

10. Avoid operating other RPAs simultaneously. The pilot must not operate any other RPA during the operation (s 5(4)(a)). Planning must ensure no concurrent RPA flights by the pilot.

11. Align operator documented practices and SOPs with section 5. Because s 5(10) requires pilots to comply with the instrument where it conflicts with operator documented practices and procedures, operators should update their documentation to reflect the instrument’s duties to avoid internal conflicts and confusion.

12. Monitor for app updates and changes to operating limitations. Because the app notifies operating limitations and periods, maintain processes to monitor the app for changes that could affect an authorised operation and communicate those changes to pilots promptly.

13. Recordkeeping and proof of registration/authorisation. Maintain records that show the operator’s registration via the CASA‑verified app, the authorised period, and the operating limitations in force for a given flight. These records will be contemporaneous evidence that the authorisation mechanisms in s 5(1)-(2) were used.

14. Consult CASR and Part 101 MOS for enforcement and licensing context. While the instrument does not provide penalties or enforcement wording, it is made under CASR provisions and the MOS. To complete compliance planning, consult the applicable CASR provisions and the Part 101 Manual of Standards referenced by the instrument for licensing, enforcement and other supervisory matters.

By following these steps and documenting each compliance element (registration evidence, app notifications, pilot briefings, fail‑safe tests, communications checks, and event notification scripts), operators and pilots can align operational practice with the instrument’s directions.