Transport Canada’s Latest RPAS Regulation Proposal
What You Need to Know and Why Your Feedback Matters
Transport Canada has published a new Notice of Proposed Amendment, NPA 2026-06, addressing three significant areas of the Canadian RPAS regulatory framework:
- Remote Identification
- Community-Based Organizations and
- Designated RPAS airspace
An NPA is an early consultation document so to be clear, these things are not yet regulation. This process allows Transport Canada to present its intended approach and collect feedback before drafting the proposed regulatory text.
This is an important opportunity for RPAS pilots, operators, manufacturers, training providers, recreational organizations and other stakeholders to identify unintended consequences and influence how the proposal develops. In my experience, this isn’t simply for show. They truly do process all feedback and incorporate changes as they are able.
How to provide feedback
The consultation period is open until September 9, 2026 and comments can be submitted via this official survey. During a recent info session, TC also informed that if you run out of space, you can submit the form and email the additional content to the address below.
TC.CARConsultations-RACConsultations.TC@tc.gc.ca
Feedback does not need to be lengthy or written in formal regulatory language. It is most useful when it clearly identifies:
- the proposal or section being discussed
- how it would affect you or your organization
- the concern, gap or unintended consequence you foresee
- any alternative or recommendation you would like Transport Canada to consider
If you feel like you don’t have enough to submit but want to flag something, you can also send your comments to me at kate@indrorobotics.com. I will be collecting industry feedback and can incorporate individual comments into a broader submission. I hope this is useful for anyone who has an important concern or question but does not have the time to prepare a complete response.
The full NPA should still be reviewed by anyone likely to be significantly affected, as it contains much more detail than can be covered in a general summary.
Why is Transport Canada proposing these changes?
Canada’s RPAS rules have so far relied heavily on keeping drones relatively separated from conventional aviation. Most operations remain below 400 feet, controlled-airspace operations require authorization, and routine BVLOS operations are currently limited to lower-risk environments.
Transport Canada expects RPAS operations to become more numerous, automated and complex, including additional BVLOS operations in controlled airspace and populated areas. The current proposal introduces some of the regulatory and technical building blocks required for that future environment.
Remote ID would provide electronic identification and positioning information. Designated RPAS airspace would communicate RPAS-specific restrictions and operating requirements digitally. Together, these concepts are intended to support the longer-term development of RPAS Traffic Management in Canada. With the designation of Community-Based Organizations, Transport is looking to enable important pathways for recreational and educational drone use.
Let’s take a look at each of the main ideas contained in the NPA:
- Remote ID
- Community-Based Organizations
- Designated Airspace
Remote Identification
Remote ID is the ability of an RPA or RPAS to transmit identification, location, altitude and related information.
Transport Canada is proposing that small and medium RPA (but not microdrones) be Remote ID compliant when conducting Basic, Advanced or Level 1 Complex operations. Compliance could be built into the aircraft or provided through an aftermarket broadcast module.
Pilots would be expected to:
- use an aircraft or module covered by a manufacturer declaration;
- associate its Remote ID information with the aircraft’s registration;
- confirm the system is functioning before flight;
- monitor its operation during flight; and
- land as soon as feasible and safe if Remote ID stops functioning.
The proposal states that the public would not receive the pilot’s name or other directly identifying registration information. However, a nearby person using an appropriate device or application could potentially see both the aircraft’s location and the location of the control station. Transport Canada and authorized law-enforcement partners could use the transmitted serial number to identify the registered owner.
Main questions and areas of concern
Privacy and pilot security
Even if a pilot’s name is not transmitted, broadcasting the location of the control station may effectively reveal the pilot’s physical location. This could create security concerns for public-safety operations, critical-infrastructure inspections, sensitive commercial work and pilots working alone.
Questions I have include:
- What is the objective in the public receiving the control-station location?
- Who will be able to access control-station location information?
- Will there be protections against stalking, harassment or interference with a flight crew?
- Should certain operations be eligible for automatic suppression or restricted access?
- Could steps be taken in the third-party information displays to reassure the public that viewable flights are legitimate and do not require vigilante action?
Legacy aircraft and retrofit costs
Transport Canada acknowledges that some existing aircraft may not receive compliant firmware updates. Operators may need to purchase an aftermarket module or replace otherwise serviceable aircraft.
The tentative implementation schedule anticipates final regulations in 2028, manufacturer declarations in 2029 and pilot compliance in 2030. That provides transition time, but it does not resolve questions about older fleets.
Questions I have include:
- What is the expected module availability and cost?
- Can a module realistically be installed on all aircraft types?
- Can a module transmit from the ground station or does it need to be on board the RPA?
- Why were microdrones excluded from this requirement?
- What are the effects on small businesses, training providers and public agencies with large fleets?
- Are additional transition measures appropriate or should there be an exemption process?
Technical performance
The detailed requirements will be placed in a future performance-based standard. This means many of the most important technical details are not yet available.
Questions remain about:
- minimum effective broadcast range
- position accuracy
- update rates
- system-failure indications
- cybersecurity and spoofing protection
- interference
- operation without GNSS
- operation in areas without network coverage
- how a pilot will confirm that the system is genuinely transmitting rather than simply powered on
- guidance to manufacturers to ensure adoption and compliance
A note on Broadcast versus Network Remote ID
Broadcast Remote ID uses an attached module or the aircraft itself to send information locally, probably over WIFI or Bluetooth type technology. Network Remote ID sends the information through an internet connection (cellular, satellite etc) to a service provider.
Broadcast Remote ID appears likely to be the most common means of general compliance, while Network Remote ID is more directly relevant to future traffic-management services. Since Network ID would require a service provider, TC would need to regulate those providers too.
Community-Based Organizations
The NPA proposes a new Community-Based Organization, or CBO, framework primarily intended for recreational RPAS and model-aircraft organizations. It might also apply to educational and research institutions.
An approved CBO could establish its own Transport Canada-accepted safety procedures and apply for certain relief from Part IX requirements at designated fixed locations. Information about these fixed-sites would likely be published digitally so other airspace users and planning services could identify the site.
To receive CBO status, an organization would need to provide information about its structure, membership, typical activities, operating procedures, oversight, competency requirements, incident reporting and safety-management arrangements.
The proposal recognizes that organized recreational and model-aircraft groups may safely conduct activities that do not fit comfortably within the general Part IX rules. Depending on the approved conditions, this could support activities such as:
- flight above 400 feet;
- FPV flight without a visual observer;
- operation of larger model aircraft;
- alternative registration arrangements; and
- operation without Remote ID at an approved fixed site.
Main questions and areas of concern
Eligibility and access
It’s clear this is meant to address the MAAC exemption that expired so the proposal appears best suited to established national or regional organizations with formal governance and safety systems.
I’m curious to hear from MAAC and modellers generally to see if they feel this has addressed their concerns.
Questions that I have include:
- What will the proposed fee structure look like?
- What size and structure must an organization have to qualify?
- Could educational institutions, makerspaces or research groups qualify without belonging to a national body?
- What resources will be required to develop and maintain an acceptable application?
There is a risk that the framework could provide useful flexibility to large organizations while remaining inaccessible to smaller groups.
Designated RPAS airspace, geo-zones and geo-awareness
Transport Canada is proposing a new mechanism to create airspace restrictions or operating conditions specifically for RPAS.
Designated RPAS airspace could be established temporarily or permanently and could include:
- prohibitions or restrictions (similar to CYRs)
- operating conditions
- equipment requirements
- relief from an equipment requirement such as Remote ID
- areas of caution (similar to CYAs) and
- future notifications that RPAS Traffic Management services are in use
This would not create a new conventional class of airspace, nor would it change the existing Class A-to-G structure. It would instead create an additional layer of requirements applying specifically to RPAS. It doesn’t mean the airspace is specifically for RPAS, either.
The information would be distributed in a complement to or modified Designated Airspace Handbook (DAH).
Transport Canada is also proposing geo-awareness obligations for aircraft capable of displaying airspace information. Manufacturers would need to use accurate, complete and current official data and provide alerts about potential or actual airspace breaches. Older or incompatible aircraft would not necessarily be required to add the capability. I like this because the old DJI Geo-Zones caused issues by implementing their own restrictions in the flight software that didn’t match up to NAV CANADA or TC expectations. It created layers of unnecessary confusion, making people think they were being compliant when they weren’t, or unnecessarily limiting people with appropriate permissions.
Main questions and areas of concern
The proposal could provide a more efficient way to protect correctional institutions, critical infrastructure, major events and other sensitive areas. It would however require a communication effort on the part of TC to ensure those effected know how to access the relevant information, and if additional layers still exist elsewhere such as in NOTAM or over parks.
There is a risk of complication or overly broad restrictions accumulating in low-level airspace if this clarity is not provided. And of course, it will do nothing to stop the people who don’t plan on following the rules anyway.
Transport Canada does not appear to be proposing that all aircraft must have a geo-awareness display. The obligation would apply where the aircraft is capable of supporting the function.
Temporary restrictions and notice
A digital system can publish changes much faster than the traditional 56-day aeronautical publication cycle. That is useful, but it also raises questions about how quickly pilots are expected to receive and respond to new restrictions.
Important questions include:
- How much advance notice will normally be provided?
- What happens if it changes during flight?
- Will pilots need continuous connectivity to remain informed?
Accuracy and responsibility
The proposal would require manufacturers to display official geo-zone information accurately. However, several parties may be involved in creating, publishing, distributing and displaying the data.
The regulatory framework should clearly assign responsibility when information is wrong or fails to alert the pilot.
The connection to future traffic management
Designated RPAS airspace may eventually identify areas where RPAS Traffic Management services are operating. This makes the proposal more than a new mapping tool: it creates part of the digital airspace structure required for future higher-volume and increasingly automated BVLOS operations.
Stakeholders should consider what future obligations could follow, including requirements to use a particular service provider, submit flight information, maintain network connectivity or comply with automated routing instructions.
What should you comment on?
A useful response does not need to reject or support the entire NPA. In fact, the survey will ask you about your thoughts on each section sequentially. You can leave what doesn’t apply to you blank, and can focus on one practical issue.
Consider commenting if:
- Remote ID could expose your operating location or create a security concern;
- you operate aircraft that may be difficult or expensive to retrofit;
- you manufacture, integrate or build RPAS;
- your operations take place in areas with limited connectivity;
- you operate a model-aircraft or recreational organization;
- you may seek CBO status or use a CBO fixed site;
- your work involves critical infrastructure, emergency response or sensitive locations;
- you are concerned about the expansion of RPAS-specific restricted airspace; or
- you see a technical or operational question that the proposal has not answered.
Specific examples are particularly helpful. Transport Canada needs to understand not only that a provision may create a problem, but how frequently it may arise, who will be affected, what it may cost and what alternative could achieve the same safety objective.
The key takeaway
For me, in some cases Transport Canada’s objectives are not immediately clear. In those situations, I aim to gather more information by attending the webinars, asking questions, sending emails and discussing with other industry professionals. I like to believe that TC wouldn’t put a lot of effort into this without good reason and that if I don’t understand something, it could just as likely be because I lack information and not simply be because it is unnecessary or overreach. That said, they can’t know everyone’s use cases and specifics. So use this feedback period as it is intended and we’ll shape progress collaboratively.
This NPA is part of a broader shift toward a digitally managed RPAS environment in which aircraft can be identified, airspace rules can be distributed in machine-readable form and increasingly complex operations can eventually be coordinated through RPAS Traffic Management services.
That broader direction may support more scalable BVLOS operations, but the details will determine whether the framework is practical, proportionate, secure and affordable.
The consultation closes on September 9, 2026. I hope you review the proposal now and provide feedback while the policy is still being shaped.
