Proposal for new rules for drone operation

The National Civil Aviation Agency (ANAC) is proposing a new regulation to update and modernize the rules for drone operations in Brazil. The document suggests adopting the Brazilian Civil Aviation Regulation (RBAC) No. 100 and repealing RBAC-E No. 94. Unlike traditional rules, the new regulation does not dictate detailed procedures for companies to follow, but rather sets safety and performance objectives to be achieved. This allows operators and organizations greater freedom to innovate, as long as they demonstrate the safety of their operations.

On ANAC’s Public Consultation page, the draft of RBAC No. 100 is available for review, along with standard scenarios, a proposed resolution for drones up to 250 grams and model aircraft, respective justifications, and additional supporting documents.

Contributions and suggestions must be submitted via a specific form available on the page, by July 18th, 2025.
Note: The public consultation will be made available in Portuguese only.

KEY POINTS OF RBAC 100 PROPOSAL

Change in Terminology

The RBAC No. 100 draft introduces a significant change in terminology. Instead of using the traditional acronym “RPA” (Remotely Piloted Aircraft), the regulation now officially adopts the term “UA,” which stands for “Unmanned Aircraft.”
This change aligns with international regulations, particularly from the International Civil Aviation Organization (ICAO), and aims to make the rules clearer and more technical. “UA” refers specifically to the aircraft itself, while “UAS” (Unmanned Aircraft System) refers to the entire system, including the aircraft, remote control system, communication links, sensors, and any other necessary components.

Change from Categories to Operational Classes

Drone operations are now classified by the type of operation rather than by weight. See the operational categories:

RBAC 100 does not apply to recreational drone operations (model aircraft) or drones with takeoff weight of up to 250 grams operating at altitudes up to 120 meters. These drones will be regulated by a dedicated resolution, as explained in the section Drones up to 250g and Model Aircraft.

Regardless of the operational category, regulations from other authorities must be observed, such as the National Telecommunications Agency (ANATEL), the Department of Airspace Control (DECEA), the Ministry of Defense, the Ministry of Agriculture and Livestock (MAPA), among others.

Drones in the Open and Specific categories must be registered in the Unmanned Aircraft System (SISANT), while those in the Certified category must be registered with the Brazilian Aeronautical Registry (RAB).

Open Category

In the Open category, drone operations are allowed more simply and with fewer regulatory requirements, provided they present low operational risk. The max takeoff weight is 25kg, and this category is aimed at basic activities and operations away from third parties.
Operators must follow basic safety rules such as maintaining Visual Line of Sight (VLOS) or Extended VLOS (EVLOS with observer), not exceeding 120 meters in altitude, not overflying uninvolved people, and registering the equipment in SISANT.

Specific Category

This category includes operations that do not fall into the Open category. Operators must submit an operational risk assessment to ANAC, preferably using the SORA (Specific Operations Risk Assessment) methodology. Based on this analysis, appropriate mitigation measures should be adopted (e.g., ANAC-approved drone design, operational limits, trained personnel, etc.).

Some operations may fall under Standard Scenarios—predefined models by ANAC with specific criteria. In these cases, as the mitigation measures have already been evaluated by ANAC, implementation by the operator is streamlined. For this public consultation, ANAC defined two standard scenarios: agricultural operations and operations by public security forces and state-controlled entities.

Some operations in this category will require the Specific Category Operator Registration (COE) to demonstrate proper structure and procedures for safety.

Certified Category

This category is for high-risk drone operations requiring safety levels beyond SORA methodology. It includes operations in densely populated areas or high-traffic controlled airspace.

Operators, drones, and remote pilots must all be certified by ANAC.

Specific Category Operator Registration (COE)

A new feature is the introduction of the Specific Category Operator Registration (COE), which works as a license proving the operator's technical capability, organizational structure, and procedures to ensure operational safety. The COE is mandatory for certain complex operations in the Specific category.

To obtain it, the operator must submit a risk analysis (SORA-based) and prove compliance with the safety objectives, including effective risk mitigation mechanisms and proper operational management.

SORA Assessment

SORA (Specific Operations Risk Assessment) is used to assess operational risks and determine the safety measures needed, both in the air and on the ground. It considers drone size and speed, operational environment, population density, flight complexity, and consequences of technical or operational failures.

In practice, SORA helps the operator demonstrate to ANAC that the risks are understood and mitigated. It’s essential for getting approvals in the Specific category and enables proportional regulation based on risk instead of generic requirements.

Standard Scenarios

Standard scenarios are predefined drone operation models created by ANAC to simplify the approval process in the Specific category. These scenarios involve known risks with established mitigation, allowing the operator to declare compliance without a full SORA assessment.

They are especially useful for routine or repetitive operations such as in controlled zones or rural areas. Operators must strictly follow all the parameters set by ANAC, including drone type, operation location, max height, distance from people, and required safety equipment.

ANAC will define and publish these scenarios through complementary regulations after RBAC 100 comes into force. Two standard scenarios proposed in this consultation are: Agricultural Operations and Operations for Public Security Forces and State-Controlled Entities.

Drones up to 250g and Model Aircraft

For drones with takeoff weight equal to or less than 250 grams and model aircraft, ANAC will issue a dedicated resolution with clear guidelines for this segment to create a more accessible and understandable regulatory environment.

A model aircraft refers to any unmanned aircraft (UA) used for recreational purposes. The regulation will be proportional to the risks posed.

Key points include:

• A minimum 30-meter distance from people not involved in operations for aircraft over 250g unless a physical barrier or explicit consent is present.
• Compliance with airspace rules from DECEA.
• Max altitude of 120 meters.
• Prohibited to transport people, animals, or hazardous materials.
• The remote pilot must be in proper physical and mental condition and operate responsibly. Minors may operate only under adult supervision.
• Model aircraft over 250g must be registered with SISANT and visibly identified. Foreigners may register using valid documentation.
• Drones up to 250g are exempt from registration and considered automatically licensed for operation.