What you obey in the air, and what you must be able to produce on the ground

Know which flights carry the duty to comply with air traffic control instructions, and which documents have to be accessible during a flight under Division VI — including the one a pilot most often leaves behind.

• You know whether you are in controlled airspace, because that is what engages the instruction duty. CAR 901.72
• You know whether the flight is under Division VI, because the document requirement is that Division's. CAR 901.92
• You know what your recency rests on, because a document has to demonstrate it. AIM 3.4.3

Section 901.72 is one sentence: the pilot of a remotely piloted aircraft operating in controlled airspace under this Division shall comply with all of the air traffic control instructions directed at the pilot. CAR 901.72

Three consequences follow from how it is written. The duty attaches to controlled airspace — a flight in Class G airspace is not caught by it. It covers all the instructions directed at the pilot, not a selection of them. And it is a duty to comply, not to consider: a pilot who judges an instruction unnecessary, or who already holds an authorization to be in that airspace, is still bound by it. CAR 901.72

Section 901.92 is the Division VI counterpart on the ground: no pilot shall operate a remotely piloted aircraft system under this Division unless the following are easily accessible during the operation: CAR 901.92

The item	What it is
(a)	The pilot certificate — remotely piloted aircraft — level 1 complex operations issued under section 901.90 CAR 901.92
(b)	Documentation demonstrating that the pilot meets the recency requirements set out in section 901.91 CAR 901.92

Two things about that list decide answers. It is a list of two, joined by "and": having the certificate at the site while the recency documentation is somewhere else does not satisfy the section. And the standard is "easily accessible during the operation", which is not the same as "carried on the pilot's person". CAR 901.92

The recency requirements themselves live in sections 901.56, 901.65 and 901.91, and the AIM summarises what satisfies them: the holder must show they have met the requirements within the previous 24 months, by attending a safety seminar endorsed by Transport Canada, completing an RPAS recurrent training program covering human factors, environmental factors, route planning, operations near aerodromes and the applicable rules, or completing a Transport Canada endorsed self-paced study program. Passing an RPAS pilot exam — any of them except the flight reviewer exam — also accomplishes it, whichever certificate the pilot holds. AIM 3.4.3

That is the content the 901.92(b) documentation is evidence of. CAR 901.92

Question	The answer
When must ATC instructions be obeyed?	When operating in controlled airspace under the Division CAR 901.72
Does Class G airspace engage the duty?	No — the section says controlled airspace CAR 901.72
Which instructions?	All of those directed at the pilot CAR 901.72
What must be accessible under Division VI?	The level 1 complex pilot certificate and the recency documentation CAR 901.92
Is one of the two enough?	No — the section names both CAR 901.92
Must they be on your person?	No — they must be easily accessible during the operation CAR 901.92
What does the recency documentation evidence?	Recency met within the previous 24 months, by seminar, recurrent training, self-paced study or an exam AIM 3.4.3

• The instruction duty is tied to controlled airspace CAR 901.72
• An authorization to be in the airspace does not displace an instruction CAR 901.72
• The document requirement is two items, not one CAR 901.92
• The standard is accessible, not carried CAR 901.92

Symptom	Likely cause	What to do
The instruction duty is applied in Class G	The section says controlled airspace	Check the airspace class first CAR 901.72
A pilot decides an instruction is unnecessary	The duty is to comply	Comply CAR 901.72
Only the certificate is at the site	The recency documentation is also required	Bring both CAR 901.92
A question asks whether the documents must be on your person	That is a stricter standard than the section's	Answer: easily accessible CAR 901.92
The recency documentation is assumed to be the certificate itself	They are two different items	The documentation evidences 901.91 CAR 901.92

Practise: Car 901 72 atc instruction compliance

Practise: Rpas access to certificate and proof

• CAR 901.72 — Compliance with Air Traffic Control Instructions
• CAR 901.92 — Access to Certificate and Proof
• TC AIM RPA 3.4.3 — Advanced and Level 1 Complex RPA Pilot Certificates