When do I need a visual observer?

Decide whether your flight needs a visual observer, and if it does, set up the communication that makes the arrangement lawful.

A visual observer is not a spare pair of eyes you add when convenient. Once one is used, the regulation imposes conditions on the pilot, on the observer, and on the link between them.

• You know whether you are using a visual observer at all — because the rules in this lesson only bite once you are. CAR 901.20
• You know which operation you are conducting: VLOS, EVLOS, or BVLOS.
• You know that a visual observer is a crew member under the CARs, with the duties that carries. CAR 101.01

If visual observers are used to help the pilot detect and avoid conflicting air traffic and other hazards, the pilot must maintain reliable and timely communication with each visual observer during the operation. CAR 901.20

Two words carry the weight. Reliable means it works throughout the flight, not at the start. Each means every observer, not the one with the radio.

The observer's duty is active: they must communicate information to the pilot in a timely manner, during the operation, whenever they detect conflicting air traffic, hazards to aviation safety, or hazards to persons on the surface. CAR 901.20

Note the three categories, and that the third is about people on the ground rather than aircraft. An observer briefed only to "watch for planes" is briefed incompletely.

No visual observer may perform observer duties for more than one remotely piloted aircraft at a time, unless the aircraft are operated in accordance with CAR 901.40(1) or under a special flight operations certificate — RPAS. CAR 901.20

So a single observer cannot cover two aircraft flying separately. If your operation needs that, it needs either the 901.40(1) conditions or an SFOC.

No visual observer may perform observer duties while operating a moving vehicle, vessel or aircraft. CAR 901.20

This is the same principle as CAR 901.37, which prohibits the pilot from operating an aircraft while operating a moving vehicle, vessel or manned aircraft. CAR 901.37 Neither role can be combined with driving.

Using an FPV device outside Division VI requires a visual observer who maintains unaided visual contact with the airspace beyond the field of view displayed on the device — not merely eyes on the aircraft. CAR 901.38

The observer's job in that case is specifically to watch what the camera cannot see.

The AIM states the FPV case in its own terms. An FPV system offers an immersive piloting experience but cuts the pilot off from their surroundings and greatly affects detect and avoid capability — the pilot's ability to scan for other aircraft. The consequence is a requirement: if you are using an FPV system that reduces the pilot's field of view, visual observers must be used, and how many depends on the complexity and the area of the operation. AIM 3.2.26 AIM 3.2.6

There is a second consequence that is easy to overlook: the area surrounding the pilot should also be safe and free of hazards, because an FPV system prevents the pilot from being aware of their own surroundings as well. AIM 3.2.26

The same page carries the crew consequence of flying more than one aircraft from one station: pilots should take extra care to ensure that sufficient visual observers are employed to ensure that each aircraft is kept within VLOS and monitored. AIM 3.2.28

A visual observer is not a pair of eyes you point at the sky. The AIM requires observers to be trained to perform any duties assigned to them by the pilot, and it says what that training includes: visual scanning techniques, aircraft identification, communications, and any other knowledge needed to perform their duties successfully. AIM 3.2.8

The duties have content. The observer must be able to determine the aircraft's proximity to all aviation activities and inform the pilot of its relative distance, altitude and flight path, together with other hazards such as terrain, weather and structures, so that it does not create a collision hazard. AIM 3.2.8

And one duty that surprises people because it is not about the sky: the observer also helps keep the operational environment sterile — free of irrelevant conversation — and minimises disturbance to the pilot and crew. AIM 3.2.8

Before beginning an operation, the crew should agree upon a consistent communication language specific to the mission at hand. The information the pilot is looking for is broadly the aircraft's relative distance, altitude and flight path in relation to traditional aircraft, and the other hazards already named — terrain, weather and structures. AIM 3.2.8

That is what makes the reliability requirement concrete. A crew that agrees to speak only at pre-briefed checkpoints has not agreed a language for the hazards that appear between checkpoints. AIM 3.2.8

Finally, the certificate question: visual observers are not required to possess an RPA pilot certificate when they are crew members of a small RPA (VLOS) carrying out basic or advanced operations — except for extended VLOS operations, which require basic pilot certification as a minimum. AIM 3.2.8

Your arrangement complies only when all of the following hold:

• Communication with each observer is reliable and timely, and stays so CAR 901.20
• Each observer knows to report traffic, aviation hazards and surface hazards CAR 901.20
• No observer is covering more than one aircraft, absent 901.40(1) or an SFOC CAR 901.20
• No observer is operating a vehicle or manned aircraft while observing CAR 901.20
• If flying FPV outside Division VI, the observer watches beyond the camera's field of view CAR 901.38
• Any FPV system that reduces the pilot's field of view has observers assigned, in a number matching the complexity and area AIM 3.2.26
• Observers are trained for the duties assigned, including scanning techniques, aircraft identification and communications AIM 3.2.8
• The crew has agreed a consistent communication language for this mission AIM 3.2.8
• Observers can report relative distance, altitude and flight path, plus terrain, weather and structures AIM 3.2.8
• Any extended VLOS operation has at least basic pilot certification available to the observer role AIM 3.2.8

Symptom	Likely cause	What to do
You lost radio contact mid-flight and kept going	Communication must be reliable and timely throughout	Treat loss of contact as a reason to terminate, not to continue CAR 901.20
One observer was watching two aircraft	Prohibited unless 901.40(1) conditions or an SFOC apply	One observer per aircraft, or change the operation CAR 901.20
The observer was also driving the chase vehicle	An observer may not observe while operating a vehicle	Stop the vehicle, or assign a separate person CAR 901.20
Flying FPV and the observer was watching the drone, not the sky	The duty is to watch beyond the device's field of view	Re-brief the observer on what they are looking for CAR 901.38
You assumed the observer needed a pilot certificate	Not required for small RPA VLOS basic or advanced operations	The exception is extended VLOS, which needs basic certification at minimum AIM 3.2.8
The crew agreed to speak only at checkpoints	Hazards appear between checkpoints	Agree a consistent language for the mission AIM 3.2.8
The observer can see the aircraft but cannot describe where it is	They must report relative distance, altitude and flight path	Train them for the duties you assign AIM 3.2.8
You briefed the observer to "watch for planes"	Terrain, weather and structures are also on the list	Broaden the brief AIM 3.2.8
Radio chatter during a busy phase	The observer helps keep the environment sterile	Cut irrelevant conversation AIM 3.2.8

Practise: Visual observers

• CAR 901.20 — Visual Observers
• CAR 901.37 — Operation of Moving Vehicles, Vessels and Manned Aircraft
• CAR 901.38 — Use of First-person View Devices
• CAR 101.01 — Interpretation (crew member)
• AIM RPA 3.2.8 — Visual Observers
• AIM RPA 3.2.26 — First-person View (FPV) Devices
• Consolidation: CARs current to 2026-09-21