ORS9 CAA SORA Decision No. 46: A Structured Framework for UAS Regulation with Cost Implications

On 7 March 2025, the UK Civil Aviation Authority (CAA) published ORS9 CAA Decision No. 46, establishing the UK Specific Operation Risk Assessment (UK SORA) as an Acceptable Means of Compliance (AMC) to Article 11 of UK Regulation (EU) 2019/947. Effective from 23 April 2025, this decision introduces a comprehensive, systematic approach to risk assessment for Unmanned Aircraft Systems (UAS) operations within the UK’s ‘Specific’ category. Supported by updates to CAP 722J (Recognised Assessment Entity for Flightworthiness, RAE(F)), CAP 722B (Recognised Assessment Entity for Remote Pilot Competence, RAE(PC)), and the forthcoming CAP 722K (SAIL Mark Policy), alongside a digital UK SORA Application Service, this regulatory shift brings clarity and consistency. However, it also imposes notable financial and operational burdens on operators, designers, and assessment entities. This article provides a detailed examination of the decision, its frameworks, associated costs, and its implications for the UAS sector.

Overview of ORS9 CAA Decision No. 46

ORS9 serves as the CAA’s mechanism for issuing general exemptions, permissions, and AMCs under UK aviation legislation. Decision No. 46 specifically designates UK SORA as a formal compliance pathway for UAS operations in the Specific category, as mandated by Article 11 of UK Reg (EU) 2019/947, which requires a risk assessment for operations exceeding the ‘Open’ category’s scope but not reaching the ‘Certified’ category’s complexity. Published in the CAA’s Regulatory Library, UK SORA adapts the Joint Authorities for Rulemaking on Unmanned Systems (JARUS) SORA v2.5 to align with UK airspace requirements.

This decision integrates technical assurance via RAE(F)s, pilot competency standards through RAE(PC)s, and a digital application platform launching on 23 April 2025. It aims to standardise risk assessments, replacing less structured methodologies such as the Operating Safety Case (OSC), and aligns UK practices with international UAS regulatory trends.

UK SORA: Methodology and Requirements

UK SORA provides a risk-based framework, assessing ground and air risks to assign a Specific Assurance and Integrity Level (SAIL) ranging from 1 (lowest risk) to 6 (highest risk) (CAP 722J, p. 10). The SAIL determines the required robustness of mitigation measures, encompassing UAS design, construction, operational characteristics, and procedures. Key components include:

- UK SORA Requirements: Detailed in Annexes B and E, these include Operational Safety Objectives (OSOs) such as OSO 2 (mitigation of technical issues) and containment requirements (CAP 722J, p. 32-33). Operators must document compliance in a ‘compliance matrix’—a spreadsheet specifying each requirement, a concise compliance method, and evidence such as flight logs or technical data sheets (CAP 722J, p. 5-6).

- Assessment Pathways:

1. SAIL Mark: UAS designers may seek a SAIL Mark certificate, verified by an RAE(F) and issued by the CAA, confirming compliance with UK SORA requirements for a designated SAIL (CAP 722J, p. 11). Governed by CAP 722K, this pre-approval facilitates subsequent OA applications.

2. Flightworthiness Assessment: For operators without a SAIL Mark, an RAE(F) evaluates the UAS during the OA process, producing a flightworthiness report to confirm its suitability for the intended operation (CAP 722J, p. 34). Flightworthiness is defined as the technical assurance of safe operation (CAP 722J, p. 6).

- Pilot Competency: Linked to SAIL levels, pilot training and assessment are managed by RAE(PC)s under CAP 722B, issuing Remote Pilot Certificates (RPCs) from L1 to L4 (CAP 722B, p. 7-8).

Supporting Frameworks: CAP 722J and CAP 722B

1. CAP 722J: Recognised Assessment Entity for Flightworthiness (RAE(F))

- Purpose: RAE(F)s assess UAS flightworthiness, advising the CAA on SAIL Mark eligibility and OA suitability (CAP 722J, p. 13). To ensure objectivity, they are prohibited from evaluating UAS they design or operate (CAP 722J, p. 14).

- Requirements: Entities must implement a Quality Management System (QMS) with documented procedures (CAP 722J, p. 16-17), appoint an accountable manager responsible for compliance (p. 18), and employ staff with expertise in UAS design, safety, and standards (p. 19). Data must be securely stored for three months following an OA decision (p. 30-31). Approvals are valid for one year, renewable through reapplication, with CAA oversight via audits (p. 26-28).

- Application Process: Entities submit an exposition detailing their organisation and a Technical Procedures Manual (TPM) to uavenquiries@caa.co.uk (p. 22-25). Significant changes, such as ownership transitions or QMS revisions, require CAA approval (p. 20-21).

- Modifications: If an OA applicant alters a SAIL Marked UAS, the RAE(F) reassesses the change, potentially deeming the SAIL Mark invalid if the modification is significant (p. 35-36).

2. CAP 722B: Recognised Assessment Entity for Remote Pilot Competence (RAE(PC))

- Purpose: RAE(PC)s train and assess pilots, issuing RPCs (L1-L4) and A2 Certificates of Competency under Article 8(2) of UK Reg (EU) 2019/947 (CAP 722B, p. 6, 10).

- Requirements: Entities must appoint an accountable manager (p. 13), employ staff with defined competencies—e.g., Theoretical Knowledge Instructors with teaching skills and Practical Flight Assessors with logged flight hours (p. 14-18)—and hold a valid OA for flight training (p. 25). Records are retained for five years (p. 12), and Flight Simulator Training Devices (FSTDs) must meet technical specifications, including flight dynamics and instructor stations (p. 30-36).

- Application Process: Applications are submitted via Form SRG 1322, accompanied by an exposition, training manuals, and an FSTD Simulator Qualification Manual (SQM) (p. 22-26). Approvals are annual, subject to CAA audits (p. 27-29).

- Transition Arrangements: Entities approved under the Fourth Edition may continue issuing General VLOS Certificates (GVCs) until expiry, but new RPC training requires compliance with this Fifth Edition (p. 8).

Financial Implications: Comprehensive Cost Analysis

ORS9 No. 46 and its supporting frameworks introduce a range of direct and indirect costs for operators, designers, and RAEs, reflecting the investment required for enhanced safety and compliance.

1. Application Fees:

- RAE(F) and RAE(PC) Approvals: Initial applications, renewals, and variations are governed by the CAA Scheme of Charges. The 2024/2025 Scheme (ORS5 No. 410) lists initial RAE applications at £1,850, renewals at £1,480, and variations at £370 (CAP 722B, p. 8; CAP 722J, p. 23). These rates apply until 31 March 2025, with revised figures effective from 1 April 2025, available on the CAA website. Additional assessment hours are charged at £92 per hour, with prior notification provided (p. 23). Payment is a prerequisite for processing (p. 23).

- Estimated Annual Cost: For a small RAE, initial approval and one renewal total approximately £3,330 over two years, excluding variations or extra hours.

2. Overseas Operations:

- RAE(F): Conducting assessments abroad incurs additional oversight costs, fully borne by the entity (CAP 722J, p. 22). ORS5 specifies £92 per hour for audits, plus travel expenses (e.g., flights, accommodation). A five-day audit in Europe could cost £2,000-£5,000, depending on location and logistics.

- RAE(PC): Training in third countries, such as for advantageous weather conditions, follows the same cost structure—£92 per hour plus travel (CAP 722B, p. 22). A single overseas training session might range from £1,500 to £3,000.

3. Operational Expenses:

- Insurance: RAE(F)s require liability insurance for UAS assessments (CAP 722J, p. 16), estimated at £500-£2,000 annually based on coverage scope. RAE(PC)s need insurance for training and flight operations, compliant with EC 785/2004 (CAP 722B, p. 12), costing £1,000-£3,000 yearly for a small entity.

- Staff Training: RAE(F) personnel must maintain expertise in UK SORA and technical standards (CAP 722J, p. 20), with industry courses costing £200-£1,000 per individual annually. RAE(PC)s train staff using competency-based programs, potentially adapted from ICAO Doc 9868 (CAP 722B, p. 19-20), at £300-£1,500 per person. For a team of five, this could total £1,000-£7,500 yearly.

- FSTD Compliance: RAE(PC)s deploying FSTDs face significant costs: initial hardware ranges from £10,000-£50,000 per unit, with qualification testing adding £1,000-£5,000 (CAP 722B, p. 30-36). Annual maintenance and updates may cost £500-£2,000 per simulator.

4. Costs for UAS Operators:

- RAE Services: Engaging an RAE(F) for a flightworthiness report costs approximately £500-£2,000 per assessment, varying by SAIL complexity (CAP 722J, p. 29). RAE(PC) pilot training ranges from £200-£1,000 per pilot, escalating with RPC level (CAP 722B, p. 10).

- Compliance Evidence: Without a SAIL Mark, operators must compile evidence (e.g., flight tests, technical documentation), potentially costing £1,000-£10,000 per OA application (CAP 722J, p. 6). This includes labour, testing equipment, and consultancy fees.

- Digital Application: The UK SORA Application Service is free to access, but preparing digital submissions may require software or professional assistance, estimated at £200-£1,000 per application.

5. Consequences of Non-Compliance:

- Audit Findings: A level-one finding (safety-related non-compliance) requires correction within 21 days, with costs for retraining or equipment upgrades ranging from £500-£2,000 (CAP 722J, p. 27-28; CAP 722B, p. 28). Level-two findings allow up to six months, with similar cost implications. Suspension or revocation disrupts operations, leading to potential revenue losses exceeding initial compliance costs.

- Additional Oversight: While annual audits are covered by application fees, unscheduled inspections due to issues may incur extra charges, such as £92 per hour (CAP 722J, p. 26; CAP 722B, p. 27).

Operational Impacts Across Stakeholders

- PDRA-01 Operators: Those operating under Pre-Defined Risk Assessment 01 (PDRA-01) are unaffected, incurring no immediate costs or changes (CAA email).

- OSC Operators: Holders of Operating Safety Case OAs must transition to UK SORA, facing expenses for RAE assessments, pilot retraining, and updated documentation. The CAA offers tailored guidance and a webinar to address differences between OSC’s narrative approach and UK SORA’s SAIL-based methodology (CAA email).

- New Applicants: Starting 23 April 2025, new operators adopting UK SORA will encounter upfront costs for RAE services and evidence preparation but may benefit from expedited approvals via the digital service (CAA email).

- UAS Designers: Pursuing a SAIL Mark involves RAE(F) fees and design compliance costs, estimated at £5,000-£20,000 per UAS type (CAP 722J, p. 11). This investment streamlines future OA processes, offering long-term savings.

CAA Support and Implementation Strategy

Recognising the complexity of this transition, the CAA has outlined a robust support framework:

- Webinars: Two sessions will be available on the CAA YouTube channel: “Introduction to UK SORA” details the methodology and application process, including RAE interactions, while “Transitioning OSC to UK SORA” assists OSC operators with methodological shifts (CAA email).

- Direct Consultation: Operators are encouraged to contact uksora@caa.co.uk for personalised advice, with the CAA arranging calls to discuss specific operational needs (CAA email).

- Ongoing Support: A year-long programme through 2025 will provide further guidance and updates to facilitate UK SORA adoption (CAA email).

- Resources: The CAA website’s UK SORA page offers access to ORS9 No. 46, updated CAP documents, and additional materials.

Strategic Importance of ORS9 No. 46

ORS9 No. 46 represents a pivotal advancement in UK UAS regulation, replacing inconsistent risk assessment practices with a scalable, SAIL-driven framework. For operators like those delivering medical supplies or conducting aerial surveys, this ensures safety and regulatory clarity—critical as UAS applications expand. Designers benefit from a pre-approval mechanism via SAIL Marks, while pilots gain structured training pathways. However, the financial burden—spanning application fees, RAE services, and compliance costs—may strain smaller entities, despite potential long-term efficiencies from the digital platform.

The human element is undeniable: operators must adapt to protect livelihoods, designers invest to innovate safely, and regulators balance oversight with industry growth. By 23 April 2025, compliance with ORS9 No. 46 will be non-negotiable. Stakeholders are advised to engage early via uksora@caa.co.uk to navigate this transition effectively.

Drone Docs is primed to guide UAS operators through the UK SORA update process. With ORS9 CAA Decision No. 46 effective 23 April 2025, we’re your trusted partner for seamless compliance and a hassle-free transition—especially for OSC holders—ensuring your operations can carry on with zero interruption.