How to fly a UAS in Spain

Operations in Spain by cross-border and third-country UAS operators

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When an UAS operator not registered in Spain intends to conduct an operation that is intended to take place partially or entirely in the airspace of Spain, the UAS operator will have to comply with different requirements and follow different procedures depending on its State of registration and whether such operations fall under:

a) the open category,

b) the specific category under a declaration, authorization or possession of a Light UAS Operator Certificate (LUC) in accordance with Article 13 of Commission Implementing Regulation (EU) 2019/947 of 24 May 2019.

1. OPERATORS WITH RESIDENCE OR PRINCIPAL PLACE OF BUSINESS IN AN EASA MEMBER STATE

The different EASA Member States are listed in the following link.

The State of registration of the UAS operator must be the one where they have their residence for natural persons or where they have their principal place of business for legal persons. A UAS operator cannot be registered in more than one Member State at a time.

The following guide details all the requirements that the UAS operator registered in another Member State must comply with in order to conduct operations in Spain and/or cross-border operations in each of the categories of operation, together with the different possible methods of identification, authentication and electronic signature in the UAS application, where all the procedures with AESA will be carried out:

• Spanish Edition: Guía para la realización de operaciones transfronterizas, fuera del estado de registro o por terceros países. Ed.03
• English Edition: Guide to conducting cross-border operations, outside of the state of registration or by third countries. Ed.03

1.1. Operations in the open category

As a summary, the main requirements that the UAS operator must meet in the open category are:

a. Be registered in its State of registration and incorporate its operator number on its aircrafts. 
b. Ensure that remote pilots who are to conduct UAS operations are adequately trained for the relevant subcategory.
c. Check specific requirements with respect to the place of operation or type of activity to be performed.
d. To have an insurance policy covering civil liability against third parties.

For further information on this subject, please refer to section 3 of the guide to conducting cross-border operations available above. .

1.2. Operations in the specific category

There are three options for cross-border operations in Spain within this operational category:

1. Operation under a Standard Scenario subject to an operational declaration.
2. Operation under operational authorization.
3. Operations conducted under the cover of a LUC (Light UAS Operator Certificate).

In order to perform cross-border operations in Spain in any of the three options mentioned above, the UAS operator must complete a procedure with AESA, which will vary depending on the option chosen.

For operations conducted under an operational authorization, AESA may recognise the authorisation in two different ways, depending on the scope of the intended operations in Spain:

• Precise recognition: intended for operators wishing to conduct a particular operation at a specific location.
• Generic recognition: intended for operators planning to conduct multiple operations in Spain under the same operational concept and within the limits of their operational authorization. AESA recommends this option for operators whose competent authority has already issued a generic operational authorization in their country of primary operation, as it facilitates the recognition process for future operations in Spain.

The main advantage of generic recognition is that the operator does not need to obtain a new recognition for each individual operation, provided that every operation:

• remains within the scope of the operational authorization granted to the UAS operator by the competent authority of the Member State of registration; 
• complies with the confirmation of acceptability and the applicable local conditions in Spain. 

All the information about the different procedures to follow at AESA and any additional requirements to be fulfilled, are described in section 4 of the guide to conducting cross-border operations available above.

Additionally, a template is made available to UAS operators to justify compliance with local conditions and the adequacy of mitigation measures, if necessary:

• Spanish Edition: ANEXO IV. Procedimientos actualizados para cumplir con las condiciones locales y actualización de mitigaciones. Ed.03
• English Edition: APPENDIX IV. Updated procedures for compliance with local conditions and updated mitigating measures. Ed.03

2. THIRD-COUNTRY OPERATORS (NON-EASA MEMBER STATE)

UAS operators that have their principal place of business, are established, or are resident in a third country, shall comply with Implementing Regulation (EU) 2019/947 for the purpose of UAS operations within the single European sky airspace.
Therefore, UAS operators from a third country that is not considered an EASA Member State must register as a UAS operator in the first Member State in which the UAS operator intends to conduct operations.

a. If Spain is the first State in which the UAS operator intends to conduct its operations, this operator must register and the same procedures and requirements will apply to it as to a Spanish operator. For more information, please access this link.
b. If the third-country UAS operator is registered in any EASA Member State, other than Spain, and decides to start operating in Spain it must follow the same procedures as any other UAS operator registered in an EASA Member State. See more details in the guide to conducting cross-border operations available above.

UAS flight requirements and limitations depending on the place of operation (UAS geographical zones) in Spain

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In addition to the general rules of UAS operation depending on the operational category, depending on the place of operation or the type of activity to be carried out, the operator may be subject to compliance with other requirements or find the flight limited or prohibited.

Depending on the nature of the planned operation, the applicable conditions of use of airspace, which by their content establish requirements associated with UAS geographical areas, are determined by Royal Decree 517/2024 of 4 June, which develops the legal regime for the civil use of unmanned aircraft systems (UAS).

In section “Zonas geográficas de UAS” you can find the guide that provides detailed information on the requirements and limitations for flying in certain locations such as controlled airspace, over urban environment, in prohibited and restricted areas, etc.: 

In the ENAIRE drones application you can consult the airspace areas in which there are drone flight prohibitions or restrictions, as well as dangerous areas and other alerts:

Before conducting UAS operations in Spain, operators should familiarise themselves with the national conditions applicable in addition to Regulation (EU) 2019/947.

In particular, operators should consult the following information:

Type of information	Description
A. INFORMATION ON UAS GEOGRAPHICAL ZONES AND NATIONAL CONDITIONS
Information on UAS geographical zones and national conditions in a human-readable form	Graphical representation of UAS geographical zones: ENAIRE Drones All the information in Zonas geográficas de UAS | AESA-Agencia Estatal de Seguridad Aérea - MTMS Geographical zones guide and national conditions in section above . As for particular geographical zones in Spain, e.g: Particular geographical zones for aeromodelling: Aeromodelismo | AESA-Agencia Estatal de Seguridad Aérea - MTMS ADIF (Spanish Railway Infraestructure Manager) geographical zones: Autorización zonas de afección - Adif
Information on UAS geographical zones in the common unique digital format (ED-318)	Scrolling to the end of the website: AIP España . Published by ENAIRE There are three different datasheets: airports, urban environment and infrastructures.
B. NATIONAL OPERATIONAL AND LEGAL PROVISIONS
Minimum age for UAS operators	16 years old
Minimum age for remote pilots	Open category: 16 years in general 12 years old for operating UAS in subcategory A1 when flying: a C0 UAS that is not a toy; or a legacy UAS with an MTOM of less than 250 g. 14 years old in any of the following cases: when operating in subcategory A1 with a C1 UAS; when operating in subcategories A2 or A3 with a C2 UAS; when operating in subcategory A3 with: a C3 or C4 UAS; a privately built UAS with an MTOM of less than 25 kg; or a legacy UAS with an MTOM of less than 25 kg. Specific category: 16 years old
Insurance requirements	Third-party liability insurance is required in any of the following cases: when operating in the Open Category, subcategory A2; when operating in the Open Category, subcategory A3 with a UAS having an MTOM of 20 kg or more; when operating in the Specific Category; when operating in the Certified Category. Minimum insurance coverage For UAS with an MTOM of less than 20 kg, the minimum insurance requirements are established by Royal Decree 37/2001, with a minimum third-party liability coverage of 220,000 SDR For UAS with an MTOM of 20 kg or more, insurance must comply with Regulation (EC) No 785/2004, with a minimum third-party liability coverage of 750,000 SDR (for UAS up to 500 kg).
National radio regulations	Operations in Radio Mandatory Zones (RMZ) and in airspace requiring communications with ATS shall comply with the applicable conditions established by the relevant Air Navigation Service Provider and published in the Spanish Aeronautical Information Publication (AIP Spain). Prior coordination with the ANSP may be required. Compliance with the conditions published in AIP Spain is required. Two-way radio communications with the ATS unit may be required. Information on the requirements and training needed to obtain the UAS radiotelephony qualification for radio communications with ATS is available at Formación en Radiofonista UAS | AESA-Agencia Estatal de Seguridad Aérea - MTMS
Additional generic privacy requirements (if any)	Operations involving the processing of personal data shall comply with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD), as applicable
Alternative means of compliance (AltMoC) adopted by the Member State	Spain has adopted two Alternative Means of Compliance (AltMoC): a predefined risk assessment for aerial application operations PDRA-S01[F] (e.g. spraying and dispersion of agricultural and forestry products) with UAS up to 3 m characteristic dimension; acceptable means of compliance for UAS operations conducted under SAIL I and SAIL II.
Exemptions applicable in the Member State under Article 71(1) of Regulation (EU) 2018/1139	Spain applies an exemption for UAS swarm operations from the requirement for each unmanned aircraft to be individually equipped with a green flashing light for night operations and an active and updated direct remote identification system.
Applicable penalties and enforcement provisions	Non-compliance with UAS regulations may be subject to administrative sanctions under Law 21/2003 of 7 July on Aviation Safety, and other applicable national legislation. AESA is the competent authority for oversight and enforcement. Infringements related to the operation of UAS are established in Article 45 ter of Law 21/2003 on Aviation Safety, while applicable sanctions are set out in Article 55 of the same Law: Minor infringements: from 4500 EUR to 70000 EUR. Serious infringements: from 70001 EUR to 250000 EUR. Very serious infringements: from 250001 EUR to 4500000 EUR.
C. OPERATIONAL SUPPORT INFORMATION
Emergency contact details	National Emergency System: 112
The population density data source to be used for the determination of the ground risk in the specific category including standard scenarios	Section “Capas geoespaciales AESA”. The specific guide is on that section.
Other operational information relevant to UAS operators	Geographical zoning and U-Space Portal. Civil air demonstrations and public events involving UAS may be subject to additional national requirements under RD 1919/2009, including the submission of a declaration or responsible declaration to AESA prior to the event, where applicable.

Remote pilot training for cross-border and third-country UAS operations

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Third-country remote pilots or those who will conduct UAS operations in a Member State of operation other than their Member State of registration must be properly trained for the corresponding category and subcategory of operation.

If the remote pilot does not have the required training to operate in the corresponding category according to the Implementing Regulation (EU) 2019/947, the pilot may obtain it through the Competent Aviation Authority of any Member State [1]. Certificates issued by one Member State are valid for operations in all other EASA Member States.

To operate in controlled airspace or flight information zones (FIZ), the remote pilot must have additional training, as indicated in the following section.

In case of operations under European STS, remote pilots must have a certificate of theoretical knowledge issued by an EASA Member State, as well as the accreditation of practical skills for the relevant scenario issued by a recognized entity or UAS operator declared to provide training to a Member State.

For more information regarding remote pilot training in the different categories of operation, as well as access to the applications for training courses and exams, please access this link.

 

Contact AESA UAS Division:

In case of doubts or special situations related to UAS operations in Spain, you can send your query to the drones mailbox (drones.aesa@seguridadaerea.es).

 

_{[1] Important information: remote pilot courses and exams conducted by AESA are only available in Spanish.}