In recent years, drones have become essential tools across both civil and defense sectors, driving the need for clear regulatory structures. One of the most significant developments in this field is the introduction of the Light UAS Operator Certificate (LUC), a framework established by the European Union Aviation Safety Agency (EASA) under Regulation (EU) 2019/947.

The LUC allows certified operators to self-authorize specific drone operations without applying for separate approval from their national aviation authority. This creates a major improvement in operational efficiency, enabling faster deployment and greater flexibility for cross-border activities within the European Union.

The purpose of the LUC is to ensure that organizations conducting unmanned aircraft operations maintain a high standard of safety management, risk assessment, and compliance. However, obtaining this certification is complex. The process requires a mature Safety Management System (SMS), advanced knowledge of the Specific Operations Risk Assessment (SORA) methodology, and an organization capable of demonstrating operational and procedural integrity.

This article examines the systematics of the LUC application process, discusses challenges commonly faced by operators, and presents practical solutions and best practices for successfully achieving and maintaining certification under EASA’s regulatory framework.

Risk Assessment within the LUC Application

(SORA and SAIL Levels)

As part of the LUC application process, every operation that an organization intends to conduct must undergo a Specific Operations Risk Assessment (SORA). This standardized EASA methodology is used to evaluate both ground risk and air risk and to determine the Specific Assurance and Integrity Level (SAIL) for each type of operation.

The ground risk assessment considers the potential impact on people or property in the event of an incident, depending on factors such as population density, flight area, and operation type (VLOS or BVLOS). Air risk focuses on the likelihood of collision with other aircraft, based on traffic density and the presence of airspace separation measures.

The resulting SAIL level defines the level of assurance and safety requirements that must be met. Lower SAIL levels (I–II) indicate low-risk operations, while higher levels (V–VI) require robust mitigation strategies, more complex procedures, and stricter technical compliance.

For LUC applicants, demonstrating proficiency in conducting SORA analyses is essential. Authorities evaluate not only the completeness of the risk assessments but also whether the operator’s Safety Management System (SMS) and documentation reflect a consistent and mature approach to risk management. In practice, operators with prior SORA experience and well-documented safety processes are far more likely to achieve LUC approval.

Key Factors in the LUC Application Process

UWhen applying for a Light UAS Operator Certificate (LUC), authorities evaluate the organizational capability of the applicant rather than the physical characteristics of a single drone. The process focuses on whether the operator can systematically manage safety and operational risk across all planned missions.

Organizational Structure:

The applicant must demonstrate a clearly defined structure with responsible personnel for operations, maintenance, safety, compliance, and authorization functions. Each key role—such as the Accountable Manager, Safety Manager, and Operations Manager—must be formally assigned and documented in the LUC application.

Safety Management System (SMS):

A fully functional SMS is the foundation of LUC eligibility. The system must include internal audits, hazard reporting mechanisms, and procedures for continuous improvement. Authorities verify that the SMS is not only documented but actively used in day-to-day operations.

Operational Experience:

Applicants are expected to have prior experience conducting Specific Category operations under existing authorizations. This demonstrates maturity and practical understanding of risk assessment, particularly with the SORA methodology.

Documentation and Compliance:

The LUC application must include an Operations Manual and a Safety Management Manual. These documents describe how the organization plans, executes, and monitors flight operations in accordance with Regulation (EU) 2019/947. Incomplete or inconsistent documentation is one of the most common reasons for delayed or rejected applications.

Level of Requested Privileges:

Operators may apply for different levels of LUC privileges—from limited self-authorization for standard scenarios to full approval for all Specific Category operations. The authority assesses whether the organization’s experience and systems justify the requested level.

Together, these factors determine whether an organization is ready to hold LUC status and operate independently within the EU framework.

Application Stages in the LUC Process

The LUC application follows a structured, step-by-step process defined by EASA Regulation (EU) 2019/947, Annex Part C. While national authorities may vary slightly in approach, the main stages remain consistent across all Member States.

Pre-Application:

Before submitting a formal request, most aviation authorities hold a preliminary meeting with the operator. This helps clarify the level of privileges sought and ensures the applicant understands the regulatory expectations. It also allows the authority to review the applicant’s existing operational history and safety performance.

Official Application Submission:

The operator submits the complete LUC application to its national aviation authority. The submission must include detailed documentation of the company’s organizational structure, list of responsible personnel, operational manuals, and safety management procedures. All documentation must be signed by authorized representatives and verified for accuracy.

Risk Assessment (SORA):

Each type of operation proposed within the LUC must undergo a Specific Operations Risk Assessment (SORA) to define the required operational safety objectives. The quality of these assessments is a key factor in determining whether the operator demonstrates sufficient maturity to self-authorize future missions.

Evaluation and Feedback (CRD Process):

Once the authority begins its review, findings are shared through a formal Common Response Document (CRD). Identified issues are categorized as Major, Minor, or Editorial. The operator must address each point and resubmit updated documentation. This exchange may occur several times until all requirements are met.

Approval and Certification:

When the authority confirms full compliance, it issues the Light UAS Operator Certificate (LUC). The certificate defines the privileges granted, including whether the operator may self-authorize Specific Category operations or must continue to notify the authority for each flight.

Operator’s Responsibilities and Compliance Measures

TWithin the LUC framework, the focus is not on the mitigation of a single flight risk but on the operator’s organizational ability to manage risk continuously. The measures evaluated by authorities are therefore structural, procedural, and cultural rather than purely technical.

Safety Management Implementation:

The operator must establish a functioning Safety Management System (SMS) that ensures hazards are systematically identified, analyzed, and mitigated. This includes internal reporting mechanisms, incident follow-up, and corrective action tracking. The effectiveness of the SMS is a major determinant in the LUC assessment.

Operational Control and Documentation:

Clear operational control procedures must be in place. Authorities verify whether the operator can control and supervise each mission, from authorization to post-flight reporting. Comprehensive documentation—covering risk assessments, maintenance logs, and personnel training—must be readily available for inspection.

Personnel Competence and Training:

Key personnel such as the Accountable Manager, Operations Manager, and Safety Manager must hold appropriate qualifications and demonstrate practical understanding of their roles. Regular training and recurrent assessments are required to maintain competence across the organization.

Continuous Compliance and Audit Readiness:

Unlike single operation approvals, LUC certification requires permanent compliance. Operators are subject to periodic audits, during which authorities examine records, procedures, and performance indicators. Maintaining readiness for such audits is essential for keeping the LUC valid.

By maintaining these organizational and procedural precautions, an operator demonstrates the ability to self-authorize operations responsibly under its LUC privileges—achieving safety assurance through structured governance rather than one-time risk mitigations.

Cross-Border Validity of the LUC Authorization

One of the most important advantages of the Light UAS Operator Certificate (LUC) is its automatic recognition across all EASA Member States. Under Regulation (EU) 2019/947, Article 13, a LUC issued by any EU country is valid throughout the Union without the need for separate national approvals.

This means that an operator certified in one state—for example, Nordic Unmanned in Norway or SwissDrones in Malta—can conduct missions in other EU countries under the same certificate. By eliminating the need for multiple applications, the LUC creates a single, harmonized authorization system for professional drone operations within Europe.

When operating in another Member State, the LUC holder must simply notify the local aviation authority by providing:

1. A copy of the LUC certificate and its terms of approval, and
2. The specific location and nature of the planned operation.

This notification allows national authorities to remain informed while avoiding redundant approval procedures. Although no additional authorization is required, operators must still comply with local airspace restrictions, U-space requirements, and national security provisions that may apply to certain regions or sensitive areas.

This cross-border validity principle has had a major positive impact on the European drone industry. Operators like SwissDrones have used their Malta-issued LUC to perform BVLOS test flights across Europe, while Nordic Unmanned reports that the majority of its operations now occur outside its home country. The LUC thus functions as a “one-stop” operational certificate, enabling safer, faster, and more consistent drone missions across the EU market.AA airworthiness certificate) are not permitted to fly over people, as they cannot demonstrate compliance with national safety and design standards.

EASA’s Harmonized Approach to LUC Authorization

Before the introduction of the Light UAS Operator Certificate (LUC), drone operators in Europe faced a fragmented system in which each national authority applied its own approval process. This often resulted in lengthy delays and inconsistent regulatory interpretations between countries.

The EASA framework addressed this challenge by introducing a uniform, risk-based certification model that emphasizes organizational capability rather than national borders. The LUC allows qualified operators to self-authorize Specific Category operations within clearly defined limits, provided they maintain a functional Safety Management System (SMS) and demonstrate consistent compliance with EASA’s operational safety objectives.

Unlike the earlier national authorization schemes, which focused on individual missions or local jurisdictions, the LUC system establishes mutual recognition across all EASA Member States. Once a certificate is granted by one authority, it remains valid throughout the EU without reapplication or additional administrative steps.

This harmonized model ensures a common safety baseline for drone operations in Europe, while still allowing flexibility in implementation and oversight. It reflects EASA’s broader objective: creating a single, predictable regulatory environment that supports operational efficiency, safety assurance, and cross-border scalability for professional drone operators.

Conclusion

Under EASA Regulation (EU) 2019/947, the Light UAS Operator Certificate (LUC) represents the highest level of organizational approval for drone operations in the Specific Category. It shifts the regulatory focus from single-operation risk assessment to the operator’s ability to manage safety systematically through a functioning Safety Management System and continuous compliance oversight.

Achieving the LUC requires significant preparation, robust documentation, and demonstrated operational maturity. However, once granted, it offers a decisive operational advantage: the ability to self-authorize missions across all EASA Member States without additional national approvals. This cross-border validity provides unmatched efficiency and supports the long-term scalability of professional drone activities in Europe.

In practice, the LUC framework embodies EASA’s goal of building a unified, safety-driven regulatory system for unmanned aviation. For operators, maintaining certification means sustaining a culture of accountability, transparent communication with authorities, and ongoing improvement of safety practices. When these elements are firmly in place, the LUC becomes not just a regulatory credential but a foundation for trust, flexibility, and operational excellence across the European drone industry.

References

• European Commission. (2019). Commission Implementing Regulation (EU) 2019/947 of 24 May 2019 on the rules and procedures for the operation of unmanned aircraft. https://www.dronespace.at/jart/prj3/dronespace/data/uploads/europaeisches_regulativ/VO_EU_2019_947_EN-konsolidiert.pdf#:~:text=,documentation%20submitted%20to%20the%20competent
• European Union. (2014). Regulation (EU) No 376/2014 of the European Parliament and of the Council of 3 April 2014 on the reporting, analysis and follow-up of occurrences in civil aviation.
• European Union Aviation Safety Agency (EASA). (n.d.). Light UAS Operator Certificate (LUC). https://www.easa.europa.eu/en/domains/drones-air-mobility/operating-drone/specific-category-civil-drones/light-uas-operator-certificate-luc#:~:text=The%20LUC%20is%20an%20optional,to%20be%20formalised%20and%20approved
• European Union Aviation Safety Agency (EASA). (n.d.). Easy access rules for unmanned aircraft systems (Regulations (EU) 2019/947 and (EU) 2019/945).
• European Union Aviation Safety Agency (EASA). (n.d.). Drones – Frequently asked questions. https://www.easa.europa.eu/en/the-agency/faqs/drones-uas#:~:text=The%20authorisation%20process%20requires%20that,for%20both%20authorities%20and%20operators
• Irish Aviation Authority (IAA). (2024, November 5). UAS Advisory Memorandum (UAM) No. 015 Issue 2 – Light UAS Operator Certificate (LUC) Application Guidance.
• Murzilli Consulting. (2023). Guide to the Light UAS Operator Certificate (LUC). https://murzilliconsulting.com/news/murzilli-consulting-guide-to-luc/#:~:text=SORA%E2%80%99s%20methodology%20is%20a%2010,associated%20with%20their%20intended%20operation
• Öz, E., Heikkilä, E., & Tiusanen, R. (2022). Development of an Organisational Certification Process for Specific Category Drone Operations. VTT Technical Research Centre of Finland.
• SUAS News. (2022, May 12). SwissDrones granted European drone operator license (LUC) by the Malta Civil Aviation Directorate. https://www.suasnews.com/2022/05/swissdrones-granted-european-drone-operator-license-luc-by-the-malta-civil-aviation-directorate/#:~:text=country%E2%80%99s%20Civil%20Aviation%20Authority
• EU Drone Port. (2024). Light UAS Operator Certificate (LUC) overview. https://eudroneport.com/blog/light-uas-certificate/#:~:text=Image