EASA Opinion No 06/2026: the 100 g threshold, registration and Direct Remote ID in detail

What this opinion is

The opinion belongs to rulemaking task RMT.0729. It was consulted in NPA 2026-103, which mixed simplification and security, and at a workshop on 16 June 2026. Only the security part is in this document. Simplification will be a separate opinion, announced for the fourth quarter of 2026.

More than one hundred comments came in from national authorities, model-aircraft clubs, manufacturers, operators and air navigation service providers. EASA then consulted the Member States Advisory Body from 14 August to 4 September 2026, and held an online workshop on 8 September. The opinion is submitted to the Commission, which decides whether to take up the amendments to Regulations (EU) 2019/947 and 2019/945.

Why this text exists

Malicious, negligent or unidentified use has shown the gaps in the current framework. Registration and Direct Remote ID exist, but not in every case. Enforcement needs a reliable registry, an identifiable operator, and a technical means to stop the use of a drone that is not tied to a valid number.

The 11 February plan called for registration above 100 g, an extension of direct identification to smaller drones, and an inability to take off without a loaded operator number. The opinion only takes what can be done by amending the two UAS regulations. The 100 g threshold comes from the security authorities behind the plan, not from an aviation-safety assessment by EASA. Requests to raise it were not accepted.

Registration: one threshold, and a verified identity

Today, in the open category, an operator registers if the drone reaches 250 g, or if it carries a sensor capable of capturing personal data — with an exception for certain toys. The opinion replaces those criteria with a single take-off mass: 100 g or more. The reference to the toys directive goes, because it is no longer needed.

Article 14 would require Member States to verify identity before completing registration. Standardisation inspections have shown uneven practice. The means — digital identity, a third-country operator — stays national. EASA is considering acceptable means of compliance, not a single procedure inside the regulation.

Two details matter. Tethered UAS up to 1 kg stay exempt: the risk is lower, and Union competence on tethered aircraft starts only above 1 kg. In the specific category, every operator still registers, whatever the mass.

A consequence that is easy to miss: a drone under 100 g fitted with a camera, which must be registered today, would no longer have to be. EASA notes this as a privacy drawback, while pointing out that without remote identification that registration has little effect in the field. Neither the lower threshold nor identity verification would have a transition period: they could apply from entry into force.

Direct Remote ID: who is in scope

In the open category, every UAS of 100 g or more would have to carry an active Direct Remote ID function and use it. Under 100 g, no mandatory class mark and no Direct Remote ID, unless the manufacturer voluntarily affixes a class label: direct identification then becomes mandatory. For those aircraft, which have no declared maximum mass, the criterion is the actual take-off mass, not an MTOM.

In the specific category, the duty would cover every UAS flying below 120 m above the surface, whatever its mass. A very light aircraft, beyond visual line of sight or with long endurance, would not escape it.

Privately built drones of 100 g or more are in scope, including research and prototypes. EASA refused to take them out. For a standard scenario, a privately built aircraft must carry a class label; otherwise an operational authorisation is required, not the declarative regime.

Mobile-network identification is not accepted as an equivalent. It depends on a connection and on a provider. Direct Remote ID is a local broadcast, readable without infrastructure. That is the signal a passive detector receives on site. A component is integrated by the manufacturer; an add-on is installed later by the operator. Both must follow Part 6 of the Annex to Regulation 2019/945.

No take-off without an operator number

The February plan wanted to prevent take-off if the operator number is not loaded and the consistency check fails. The opinion keeps the function. It relies on the identification component, but it is a function of the UAS, written in Parts 1 to 5 of the Annex, not in Part 6.

The point is not only to catch an oversight. It is to make registration effective, now that it is tied to a verified identity. Comments were split. EASA kept it as a proportionate measure. Aircraft already placed on the market before the transition deadline would be exempt: fitting it requires a major modification.

Drones already sold will not switch overnight

The delays below are proposals. They run from entry into force, which has no date. This is not current law.

The opinion calls “legacy” open-category UAS placed on the market before 1 January 2024, C0 and C4 aircraft placed on the market before the future text enters into force, and specific-category UAS covered by an authorisation issued before adoption and entry into force.

Any UAS placed on the market before twelve months after entry into force would be exempt from take-off prevention. At 900 g or below, it would also be exempt from an add-on Direct Remote ID module: EASA considers retrofit unrealistic on very light aircraft. Above 900 g, the compliant module would have to be installed within forty-eight months.

In the specific category, an authorisation or a light UAS operator certificate (LUC) issued before that twelve-month mark would allow continued operation without Direct Remote ID and without take-off prevention, including if it is extended, until forty-eight months, as long as the UAS model does not change.

For a site, the reading is direct. Minis, light FPV racers and a large share of leisure aircraft already sold under 900 g will stay non-cooperative for years if this regime is adopted as drafted. An operator can be on the registry while the aircraft broadcasts nothing. The registry does not replace detection. Listening to Wi-Fi and Bluetooth links, and radar where modified aircraft are plausible, remain necessary. New drones will widen the cooperative share — and a receiver already compliant with EN 4709-002 will benefit with no hardware change.

Geographical zones and national conditions

Article 15 stays discretionary: a State “may” create a zone, it does not “shall”. Before a zone or a national condition justified by aviation safety, privacy, personal data or the environment, the measure would have to be necessary and proportionate, and documented where appropriate. That check does not apply to zones created on security grounds, for example in response to a specific threat.

National conditions are not new rules. Insurance, pilot age: they are requirements that already exist nationally, which the State would have to make findable from a single source. They cannot be used to impose electronic conspicuity on manned aviation. Regulation 2019/947 covers UAS operations only.

Publication would have to be human- and machine-readable, at least in English, with geometry, time validity and restrictions in a common digital format defined by EASA. The Agency plans a module in the IAM Hub. Part of these publication duties would apply only twelve months after entry into force. Numeric duties on timelines and availability will go into guidance, not the regulation.

The opinion does not introduce a notion of “critical infrastructure”. The directive that defined it has been repealed. Prisons, energy sites, events: protection continues through zones, including temporary ones. A published zone does not stop a drone. It becomes useful if the crossing is evidenced — timestamp, trajectory, Remote ID when it exists.

What the consultation removed

• Extending geo-awareness to every drone of 100 g or more, and the matching module. GNSS dependency, a burden judged disproportionate for model flying and the specific category, and a reminder that the pilot’s first duty is still to check the zones before flight.
• A standalone ban on flying near critical infrastructure. The term was not stably defined.
• An automatic exemption for model-aircraft clubs. The State may specify, in the club authorisation, whether Direct Remote ID applies. It is no longer an exemption in principle.
• The minimum age is aligned with the 100 g threshold. The exemption for toy drones is kept, at the clubs’ request.

A few details that concern manufacturers

Instructions would have to state the maximum take-off mass, a term that is already defined, rather than an ambiguous “UA mass”. An explicit tolerance of 2% or 3%, depending on the class, is proposed between the actual mass in possible configurations and the declared MTOM.

For heavier-than-air tethered UAS, the tether strength factor moves from 10 to 4 times maximum thrust, aligned with lighter-than-air tethered aircraft. The unique serial number stays required in Article 6; repeating it in the EU declaration of conformity was judged disproportionate and removed.

EASA will monitor implementation through standardisation inspections, safety data and the IAM Hub. Acceptable means of compliance are planned for identity verification, zone assessments, the format for publishing national conditions, and the discretion left to clubs.

What a security manager can do with this now

Do not write into a procedure that the 100 g threshold is already enforceable. The current pair — 250 g or a camera for registration, classes C1 to C6 for Direct Remote ID, French electronic conspicuity above 800 g — remains the applicable law.

Do prepare two horizons. New aircraft, once the text is adopted, will broadcast more. The light fleet already sold will not. Detection that only read Remote ID would miss most small-drone overflights throughout the transition. That is the point the February plan left open, and that the opinion settles: the retrofit exemption at or below 900 g is explicit.

The operational detail — zones, personal data, ADS-B, the existing fleet — is developed in the knowledge hub. The official source remains the EASA page for Opinion No 06/2026.