For survey, inspection, utility, and security operations. Based on the proposed rule (NPRM, docket FAA-2025-1908) as of July 2026; re-check every item against the final rule when it publishes.
The proposal keys its heaviest requirements to airspace and population density, so this classification does the most work:
Map your actual mission footprint against those three buckets. Many mid-market operations will discover most of their flying sits in the lightest bucket, and that the requirements concentrate on a small share of missions. The ADSP explainer covers what the certificated services are.
Permits (lower-risk, streamlined) versus operating certificates (larger or riskier, with SMS and a training program). Read your operation honestly against both: fleet size, mission risk, proximity to people. If the certificate tier is where you're headed, its documentation expectations are the long-lead item, and item 4 matters more.
The proposal attaches responsibility to the company through an operations supervisor and a flight coordinator, not to a new individual certificate. Decide who would hold each role, and note the open question: how today's Part 107 certificate holders map into these roles is unresolved in the draft.
SMS structure, training records, operational procedures. If you run BVLOS waivers today, you have most of this; keeping it current is what makes an eventual transition a filing exercise. If you're pre-BVLOS, starting the documentation habit now is the cheapest possible preparation.
Airworthiness under the proposal works by manufacturer declaration against consensus standards (aircraft up to 1,320 lb). Whether your airframes will carry those declarations is your manufacturer's question to answer, and asking it early tells you whether your fleet plan and your Part 108 plan agree.
The final rule (timing unknown; the timeline page tracks it) and, if you hold a waiver, the transition provisions (what the draft says). Everything else is commentary.
The operational layer under all of this, live video from the aircraft to the people who need to see it, is a today problem with a today answer: a live drone feed on any network.
Under the proposal it depends on where you fly: operations in controlled airspace (Class B, C, D, and surface-area Class E) would require both strategic deconfliction and conformance monitoring from a certificated provider; operations near denser population areas (Category 3 and up) would require strategic deconfliction; operations in sparse areas under Category 1 or 2 would require neither.
The proposal splits authorization into permits for lower-risk operations (a streamlined path) and operating certificates for larger or riskier ones. The certificate tier carries a safety management system (SMS) and a formal training program. Which side your operation lands on depends on its scale and risk profile, and is worth mapping now rather than after the final rule.
The proposal defines company roles rather than an individual pilot certificate: an operations supervisor and a flight coordinator. Identifying who in your organization would hold those roles is a readiness step you can take today.
Under the proposal, airworthiness works by manufacturer Declaration of Compliance against industry consensus standards, for aircraft up to 1,320 lb. Whether your airframes will carry such declarations is a question for your manufacturer, and worth asking before the final rule.
It is preparation, not panic. The final rule's timing is uncertain, and experienced operators note the proposed conditions are in some respects lighter than existing waiver conditions. The value of preparing now is that the readiness steps are cheap, and doing them early converts the eventual transition into a filing exercise.
FAA/TSA joint NPRM "Normalizing UAS Beyond Visual Line of Sight Operations" (docket FAA-2025-1908), including its operational-requirement matrix, as of July 2026. This checklist reflects the PROPOSED rule; re-verify every item against the final rule when it publishes.
This page is for general orientation and may not reflect the latest regulatory changes. It is not legal advice: confirm current rules, fees, and permitted zones with your country's civil aviation authority before you fly.