Single Market? - Drones
EU Rules for UAS: Existing Barriers in Cross-Border Operations
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    In principle, the regulations are clear. However, in practice, the “cross-border operation” of drones in the “specific” category is sometimes complicated. This is more than just a minor detail. On one hand, delays and additional requirements for “Cross-Border Operations” can hinder the scaling of business models. On the other hand, the issue highlights differences in how the European legal framework for drone operations is implemented.

    Despite the binding legal framework under Article 13 of EU Regulation 2019/947, the cross-border execution of drone operations in the specific category remains a complex challenge in practice. This is partly due to bureaucratic friction and interface problems between the respective authorities. Language barriers also cannot be underestimated. The most fundamental difficulties, however, stem from national special procedures and differences in how uniform European regulations are implemented into national law.

    In principle, the aviation authority responsible for the main residence (for natural persons) or the company headquarters (for legal entities) issues operating permits. This is intended to avoid duplicate processing and potentially differing assessments of the same applications, thereby accelerating procedures through established contacts. Once a permit is granted, the authority forwards it to the authority responsible for the specific operational location. Their task is no longer to evaluate the entire operational concept but merely to check whether adjustments to specific local conditions (Local Mitigating Measures) are necessary.

    Discretionary Authority

    What sounds like a mere formality in theory often becomes a real problem in practice. Because European regulations are interpreted differently across EU member states, national aviation authorities often exercise their di…


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