Transport Canada's 2025 RPAS Overhaul: BVLOS Without an SFOC, the New RPOC, and What's Changed

The Biggest Rewrite in Canadian Drone Regulation Since 2019

In 2019, Transport Canada's foundational RPAS regulations introduced the Basic and Advanced certificate regime that Canadian drone pilots still use today. In 2025, TC rolled out the most significant update to those rules since then - a two-phase implementation that changed how BVLOS operations are authorized, created a new operator-level certification, established rules for medium drones (25 kg–150 kg), and introduced new fees across the board.

If you hold an Advanced certificate and operate commercially, at least some of these changes affect what you can now do - and what you're now required to have in place. This guide covers both phases, what each change means in practice, and what action items exist for operators heading into the second half of 2026.

Two-Phase Implementation: A Quick Map

Transport Canada split the rollout into two dates to give the industry time to prepare:

• Phase 1 - April 1, 2025: The Level 1 Complex exam became available, and operators could begin submitting RPAS Operator Certificate (RPOC) applications through the Drone Management Portal (DMP).
• Phase 2 - November 4, 2025: The full rule set came into force - new operation types activated, BVLOS pathways opened, medium drone rules applied, new fees took effect.

If you've been operating under an existing Advanced certificate and SFOC regime, the Phase 2 changes are the ones with practical operational impact. Phase 1 was essentially the preparation window.

The RPAS Operator Certificate (RPOC): What It Is and Who Needs One

The RPOC is a new organizational-level certification issued by Transport Canada to individuals, businesses, and organizations that want to conduct BVLOS or certain complex operations. It is separate from the pilot certificate you hold personally - it authorizes an operator (which can be a sole proprietor, a company, or an organization) to conduct operations that require organizational accountability.

Who needs an RPOC:

• Any individual or organization wanting to conduct BVLOS operations under the new framework (instead of applying for a per-operation SFOC)
• Operators conducting medium drone operations in certain scenarios
• Organizations conducting operations requiring a formal Safety Management System (SMS)

What the RPOC application requires: The core of the RPOC application is a declaration through the Drone Management Portal that your organization has the policies, procedures, and personnel in place to safely conduct the operations described in your certificate. TC is not just certifying a pilot - it's certifying that an operating entity has the internal governance to conduct complex or high-risk operations. What this means in practice:

• Documented operational procedures - how operations are planned, approved, and recorded
• Crew roles and responsibilities in writing, including command authority and decision-making authority
• Emergency and contingency procedures for each operation type you intend to conduct
• Maintenance and airworthiness procedures for the aircraft involved
• A safety management process appropriate to the scale of your operations

The fee: The RPOC application fee is CA$125. This is a one-time fee per certificate, not a per-operation charge. The RPOC does not replace the pilot certificate - pilots must still hold the appropriate individual certification (Advanced or Level 1 Complex) for the operations they personally conduct under the RPOC.

Individual operators: If you operate as a sole proprietor - one pilot, one drone, your own clients - you can apply for an RPOC as an individual. The requirements are the same: documented procedures and a declaration through the DMP. You do not need to be a registered business to hold an RPOC, but you do need to be at least 18 years old and hold an Advanced RPAS Pilot Certificate (with an additional Level 1 Complex designation if you want BVLOS authorization).

The Level 1 Complex Designation: The BVLOS Pilot Credential

The Level 1 Complex designation is the individual pilot qualification required to conduct the BVLOS operations enabled by the new rules. It sits above the Advanced certificate in the certification hierarchy.

How to obtain it: To earn a Level 1 Complex designation, a pilot must:

1. Hold a valid Advanced RPAS Pilot Certificate
2. Complete at least 20 hours of ground school training covering the additional subjects in the Level 1 Complex curriculum (crew resource management, advanced airspace coordination, BVLOS operational procedures, contingency management)
3. Pass the Level 1 Complex online exam through the TC Drone Management Portal - this is a separate exam from the Advanced operations exam, not an extension of it
4. Pass a flight review with a TC-approved organization, as with the initial Advanced certification

The exam structure: The Level 1 Complex exam covers material not included in the standard Advanced exam: BVLOS operational procedures, crew coordination, detect-and-avoid concepts, airspace deconfliction for non-VLOS operations, and communications procedures. The pass mark and format are consistent with the Advanced exam. Like the Advanced certificate, the Level 1 Complex designation expires every 24 months and requires the knowledge exam again to renew.

The flight review requirement: The flight review for Level 1 Complex certification must be conducted by a TC-approved organization - the same requirement as the Advanced certificate's initial flight review. The review scope is broader than the Advanced review, typically including demonstration of EVLOS and simulated BVLOS scenarios. Budget additional time (and cost) beyond a standard Advanced flight review.

BVLOS Without an SFOC: What the New Rules Actually Allow

This is the headline change for commercial operators who have been navigating the SFOC process for BVLOS work. Under the new rules, a Level 1 Complex-certified pilot with an RPOC can conduct BVLOS operations in certain conditions without applying for an individual SFOC.

The conditions that allow SFOC-free BVLOS:

• Operations in Class G (uncontrolled) airspace only
• Below 400 feet AGL
• A minimum of 1 km from populated areas
• Daylight operations only
• Within the drone's certified operating range for command-and-control link reliability
• The RPOC is in force and covers the operation type

What this does not eliminate: The SFOC-free BVLOS pathway has meaningful limitations. Operations that do not meet all conditions listed above still require an SFOC. Specifically:

• BVLOS in controlled airspace (Class C, D, E) still requires an SFOC and Nav Canada coordination
• BVLOS within 1 km of a populated area still requires an SFOC
• Night BVLOS still requires an SFOC
• Any BVLOS with a drone over 25 kg remains in SFOC territory unless you meet medium drone operation rules (discussed below)

The practical effect is that operators conducting BVLOS pipeline inspection, agricultural survey, or infrastructure inspection in rural Class G airspace - one of the most common commercial BVLOS use cases - can now do so under their RPOC without per-flight SFOC applications. For operators who were previously filing 20+ SFOCs per year for routine rural surveys, this is a substantial administrative reduction.

For operations that still require an SFOC, the process described in our SFOC application guide still applies - including the 20 business day lead time and the risk assessment requirements. The new rules reduce but do not eliminate the SFOC requirement for BVLOS work.

Extended Visual Line of Sight (EVLOS): New Access for Advanced Pilots

EVLOS is a new operation category enabled by the Phase 2 changes. An Advanced Pilot Certificate holder (without Level 1 Complex) can now conduct EVLOS operations - flights where the drone travels beyond the pilot's unaided visual range, but a visual observer maintains continuous observation of the aircraft and can hand off situational awareness to the pilot.

How EVLOS differs from BVLOS: In EVLOS, the drone is always within the visual range of at least one person in the crew - typically a visual observer stationed at a forward position. The pilot may not be able to see the drone directly, but the overall crew maintains the aircraft in continuous visual contact. In BVLOS, no crew member is required to maintain visual contact with the drone.

Practical applications: EVLOS unlocks real utility for operations like linear infrastructure inspection (following a pipeline or powerline beyond the pilot's visual range), boundary surveys, and corridor mapping where a single stationary pilot position cannot observe the entire flight path. A crew of two - pilot and forward observer - can effectively extend the operational envelope without requiring Level 1 Complex certification or RPOC authorization.

EVLOS conditions: EVLOS operations must be conducted in conditions where the visual observer can continuously observe the drone. Poor visibility, adverse weather, or obscuring terrain features that prevent the observer from maintaining visual contact push the operation back into BVLOS territory - requiring Level 1 Complex certification and RPOC authorization. Crew communications during EVLOS must be reliable and well-documented in your operational procedures.

Medium Drone Operations: 25 kg to 150 kg Without an SFOC

Before November 2025, any drone weighing over 25 kg required an SFOC regardless of airspace or operation type. The Phase 2 changes created a new regulatory category - "medium drones" (25 kg to 150 kg) - and established a VLOS pathway for flying them without an SFOC, provided you hold an Advanced certificate and meet technical and safety requirements.

What the new medium drone rules allow: An Advanced certificate holder can now fly a medium drone within visual line of sight, in Class G airspace, below 400 feet AGL, without an SFOC - provided the drone meets the technical standards specified in TC's updated airworthiness requirements for this category, and the pilot has submitted the required safety assurance declarations through the DMP.

Flying near bystanders with a medium drone: The rules allow medium drone operations near people, with a tiered separation requirement:

• Within 30 metres (100 feet) horizontally of bystanders: allowed with additional safety assurance declarations confirming your drone meets specific design and reliability standards
• Between 30 metres (100 feet) and 152.4 metres (500 feet) horizontally of bystanders: allowed with standard safety assurance declarations
• Beyond 152.4 metres (500 feet) from bystanders: standard medium drone VLOS rules apply

What "safety assurance declarations" require: The declarations are not a self-certification checkbox - they require documented evidence that your specific drone meets TC's technical performance standards for the medium category. This includes failsafe behaviour documentation from the manufacturer, command-and-control link reliability data, and confirmation that the aircraft can execute its programmed emergency landing procedure. TC expects this documentation to be filed through the DMP before the relevant operation type is conducted.

Above 150 kg: Drones weighing more than 150 kg remain outside the medium category and still require an SFOC for any operation, regardless of airspace class or operation type.

Sheltered Operations: What Changed

Sheltered operations - where the drone is flown in close proximity to structures, terrain, or visual observer positions that provide operational coverage for areas the pilot cannot directly observe - are now formally codified in the regulation framework. Advanced certificate holders can conduct sheltered operations without special approvals, provided they meet operational conditions and document the sheltered configuration in their pre-flight planning.

Before the Phase 2 changes, sheltered operations existed as a practical workaround but had no formal regulatory status. The explicit codification matters because it clarifies what's permitted, establishes documentation requirements, and gives operators a defensible regulatory basis if a sheltered operation is questioned.

New and Updated Fees: What Operators Are Now Paying

The 2025 regulation changes introduced a fee structure that didn't exist in the same form previously. Commercial operators need to budget for these in their compliance and administrative costs:

• Drone registration fee: Increased to CA$10 as of April 1, 2025 (from the previous $5/year for individual operators). Commercial operators registering multiple aircraft now pay $10 per aircraft per registration period.
• RPOC application fee: CA$125 per certificate application - a new fee category that did not exist before 2025.
• SFOC application fee: As of November 4, 2025, SFOC applications that are not submitted by government organizations involved in emergency response now require a fee. Fee amounts vary by operation type and complexity. Government emergency response organizations are exempt. Commercial operators who previously submitted SFOCs without cost are now paying for each application - factor this into project budgets.

Fee context for planning: The SFOC fee change is the most significant for commercial operators who regularly file SFOCs. If you're conducting operations that still require SFOC authorization (BVLOS in controlled airspace, near populated areas, night operations), the per-application cost now needs to be factored into your project pricing. The RPOC pathway - one CA$125 fee covering a class of SFOC-eligible operations going forward - is financially advantageous for operators who file SFOCs frequently for routine rural BVLOS work.

Microdrones at Advertised Events: The New Requirement

The Phase 2 changes introduced specific requirements for operations involving microdrones (under 250 g) at advertised events. Previously, microdrones operated in a largely unregulated space - their sub-250 g weight placed them outside the registration and certification requirements that apply to heavier drones.

Under the new rules, flying a microdrone at an advertised event (a concert, a public festival, a sporting event, or any event publicly advertised to attract attendees) requires a specific authorization, regardless of the drone's weight. The authorization is obtained through the DMP and involves a simplified process compared to a full SFOC, but it is not automatic. Operators of microdrones for commercial event coverage, real estate photography at open houses, and similar scenarios at publicly advertised events need to be aware of this change - it's one area where the new rules expanded requirements for operators who previously operated below the registration threshold.

What the 2025 Changes Mean for Your Certificate (If You Already Have Advanced)

If you hold a current Advanced RPAS Pilot Certificate and have been operating under the previous framework, your certificate remains valid. The 2025 changes do not invalidate existing certifications. What changes is your operational scope:

• You can now conduct EVLOS operations without Level 1 Complex - but you need to document the crew configuration and handoff procedures
• You can fly medium drones (25–150 kg) within VLOS without an SFOC - but the drone must meet TC's medium category technical standards and you must file safety assurance declarations
• Sheltered operations are now explicitly codified and available without special approval
• BVLOS without SFOC requires Level 1 Complex + RPOC - your existing Advanced certificate is a prerequisite but not sufficient on its own

For a full breakdown of what your Advanced certificate covers and how the certification hierarchy works, see our guide on RPAS Basic vs Advanced certification. The Level 1 Complex designation sits above Advanced in that hierarchy and is the entry point to the new BVLOS framework.

Action Items for Commercial Operators Now

The Phase 2 rules have been in force since November 4, 2025. If you haven't reviewed your compliance posture against the new framework, here's what to work through:

1. Audit your operation types. List what you're currently flying and how. For each operation type, determine whether the new rules offer a more efficient pathway or impose new requirements (EVLOS, medium drone, advertised events).
2. Assess RPOC candidacy. If you conduct routine BVLOS in Class G airspace (pipeline, agriculture, infrastructure) and have previously filed SFOCs for those operations, the RPOC pathway likely reduces your administrative burden significantly. CA$125 and a policy documentation exercise versus per-flight SFOC fees going forward is worth modeling for your operation volume.
3. Level 1 Complex training planning. If BVLOS is a significant part of your commercial work and you're not yet Level 1 Complex certified, budget for the 20-hour ground school and flight review now. The exam has been available since April 2025 - waiting is just delaying access to the SFOC-free BVLOS pathway.
4. Update your documentation. Even if you don't need an RPOC, the 2025 changes are a forcing function to formalize operational procedures that many smaller commercial operators have kept informal. TC's enforcement focus on complex operations is increasing alongside the expanded permissions.
5. Check your SFOCs. If you have standing SFOCs from before November 2025, review their conditions - they remain valid, but confirm whether newer operational pathways now cover the same operations more efficiently or whether you're paying SFOC fees for work you could now conduct under an RPOC.

What Hasn't Changed

Amid a lot of change, several things remain constant:

• The Basic and Advanced certificate structure remains the foundation - nothing in the 2025 changes eliminates the need for individual pilot certification
• Pilot certificates do not expire, but the 24-month recency requirement still applies
• BVLOS in controlled airspace, at night, or near populated areas still requires an SFOC - the new framework provides a pathway around SFOCs for qualifying low-risk BVLOS, not for all BVLOS
• Parks Canada and provincial park drone rules are entirely separate from TC regulations and are unaffected by the 2025 changes - read our complete guide to flying near Canadian national parks if you have park-adjacent operations
• Liability insurance requirements remain in place - confirm your coverage extends to the new operation types you're now authorized to conduct

Tracking Your Certifications in the New Framework

The 2025 changes added layers to an already complex compliance stack. You now potentially need to track: Basic or Advanced certificate (24-month recency), Level 1 Complex certificate (24-month recency), RPOC status (organization-level, tied to your declarations and policies), drone registrations ($10/aircraft), any standing SFOCs with their own conditions and expiry dates, and - if you fly commercially - liability insurance coverage.

Complifly's compliance dashboard surfaces expiry alerts for certificates, RPOC status, registrations, and SFOCs in one place - with 30-day and 7-day reminders so nothing lapses mid-project under the new multi-layer framework.

Summary

• Phase 1 (April 1, 2025): Level 1 Complex exam and RPOC applications opened via the Drone Management Portal
• Phase 2 (November 4, 2025): All new operation types activated - BVLOS without SFOC, EVLOS, medium drones, sheltered operations, microdrone event rules, new fees
• RPOC (CA$125): Organization-level certificate required for BVLOS under the new framework; needs documented policies, procedures, and crew requirements
• Level 1 Complex: Individual pilot designation above Advanced - required for BVLOS; needs 20h ground school + exam + flight review
• BVLOS without SFOC: Now possible in Class G, below 400 ft AGL, ≥1 km from populated areas, daytime - with Level 1 Complex certification and RPOC
• EVLOS: Advanced certificate holders can now fly beyond their direct visual range using a visual observer, without Level 1 Complex or RPOC
• Medium drones (25–150 kg): VLOS operations now possible without SFOC - Advanced cert + safety assurance declarations + TC technical standards compliance
• New fees: SFOC applications now cost money (except government emergency response); RPOC CA$125; drone registration now CA$10
• SFOCs are still required for BVLOS in controlled airspace, near populated areas, at night, and for heavy-complex operations