What you will know
Decide whether the operation you intend needs a declaration on the model, an acceptance letter, or a special flight operations certificate — and know what a modification does to all three.
The declaration is the concept most often misread as a per-flight permission. It is not. It is a statement about a model of system and the specific technical requirements the operation depends on, and your flight relies on it. CAR 901.69
Before this lesson
- You know the model of the system you fly, not just the aircraft, because a declaration is made in respect of a model. CAR 901.194 AIM 3.4.1 AIM 3.4.1 AIM 3.4.4
- You know the operating weight class: small or medium. The two lists in 901.69 are separated by exactly that. CAR 901.69
- You know the complexity tier of the operation you are applying to conduct. CAR 903.02 AIM 3.6
How it works
1. A declaration is about the model, not your flight
No pilot shall operate under Division V to conduct any of the operations in 901.69 unless a declaration has been made to the Minister in respect of that model of system and in respect of each of the technical requirements set out in Standard 922 that applies to the operation. CAR 901.69
That sentence has two objects — the model, and the technical requirements — and the declaration must cover both. A declaration that names the model but not the applicable Standard 922 requirements does not satisfy it. CAR 901.194
2. The eight operations that need one under Division V
All eight are VLOS operations; seven of them are about distance from people or airspace, and they differ by aircraft class: CAR 901.69
| Operation | Aircraft |
|---|---|
| VLOS in controlled airspace | small CAR 901.69 |
| VLOS at less than 100 ft (30 m) but not less than 16.4 ft (5 m) from a person not involved | small CAR 901.69 |
| VLOS at less than 16.4 ft (5 m) from a person not involved | small CAR 901.69 |
| A sheltered operation in controlled airspace | small CAR 901.69 |
| VLOS at 500 ft (152.4 m) or more from a person not involved | medium CAR 901.69 |
| VLOS at less than 500 ft (152.4 m) but not less than 100 ft (30 m) | medium CAR 901.69 |
| VLOS at less than 100 ft (30 m) from a person not involved | medium CAR 901.69 |
| VLOS in controlled airspace | medium CAR 901.69 |
Note what is not on the list: there is no entry for flying far from everyone in uncontrolled airspace. The declaration attaches to the operations that carry the risk, not to operating as such. CAR 901.69
3. Under Division VI the requirement is general
Under Division VI, no pilot shall operate at all unless a declaration has been made in respect of the model and of each applicable Standard 922 requirement. CAR 901.95
There is one carve-out, and it is specific: for the technical requirement in section 922.10 — detect and avoid — a pilot may operate without a declaration for that requirement if a visual observer maintains unaided visual contact with the airspace sufficient to detect conflicting air traffic and other hazards and take action to avoid them, and the operation is conducted in accordance with the Standard 923 — Vision-Based Detect and Avoid. CAR 901.95 Std 922.10 Std 923
It is a carve-out for one requirement, not for the Division.
4. What the declaration itself must say
The declaration must specify the legal name, trade name, address and contact information of the person making it and, for the system: the model name; the configurable elements; the operations described in section 901.69 or 901.87 that the model is intended to conduct; and the Standard 922 requirements that are its subject. It must also indicate that the person has verified that the model meets those requirements — and if an acceptance letter was issued for the model, that the verification was completed using the means set out in the acceptance-letter application. CAR 901.194
Two consequences follow. A declaration is scoped to the operations it names, and it is a claim of verification, not a registration. CAR 901.194
For a model intended to conduct the operations in paragraph 901.69(f) or (g) or 901.87(b), no one may even provide a declaration to the Minister unless an acceptance letter was issued in respect of that model in the two years before the declaration. CAR 901.194
And the declarant must notify the Minister within 30 days after any change to that name, address or contact information. CAR 901.194
5. The acceptance letter, and what it takes to get one
The Minister issues an acceptance letter if the applicant demonstrates the ability to: verify that the model meets the Standard 922 requirements for which the declaration is proposed; establish and maintain a service-difficulty reporting system meeting section 901.197; and, for a manufacturer of a system element, ensure production consistency — or, for a service provider, ensure consistent activation and delivery of the service. CAR 901.196
An acceptance letter is therefore about a capability, not a product. It is the means by which the Minister knows the declarant can do the verifying it will later claim. CAR 901.196
6. A declaration can become invalid — partly
A declaration is invalid if the Minister determines that the model does not meet the declared technical requirements; if the declarant gave a notification under section 901.195; or if the declarant failed to submit the annual report under section 901.199. CAR 901.194
The last two are narrower than they look. For a notification, the declaration is invalid only with respect to the operations in paragraphs 901.69(f) and (g) and 901.87(b); for a missing annual report, only with respect to those same operations, and only for the period during which the report is outstanding. CAR 901.194
So the annual report is not an administrative afterthought: while it is outstanding, the declaration does not cover the closest operations. CAR 901.194
7. A modified system has to keep its basis
No pilot shall conduct any of the 901.69 operations using a system that has been modified in any way unless the pilot can demonstrate to the Minister that, despite the modification, the system continues to meet the applicable Standard 922 requirements, and — if applicable — that the modification was performed in accordance with the manufacturer's instructions for the part or equipment used. CAR 901.70
For the operations in paragraph 901.69(f) or (g), the bar rises: the modification must have been performed in accordance with the instructions of the person who made the declaration. CAR 901.70
Division VI states the same rule for its operations, with 901.87(b) as the equivalent close-in case. CAR 901.96 CAR 901.87
8. When it is an SFOC instead: the complexity tiers
An application for a special flight operations certificate — RPAS is classified by complexity, and the classification decides what you must submit: CAR 903.02
| Tier | Operations |
|---|---|
| Very low | Operating an unregistered aircraft, other than to provide a commercial air service CAR 903.02 |
| Low | Operating at an advertised event CAR 903.02 |
| Medium | More than 150 kg; a commercial air service with an unregistered aircraft; above the altitudes in subsection 901.25(1) unless authorized; more than five aircraft VLOS, or more than one non-VLOS aircraft, from a single control station; outside Canadian Domestic Airspace CAR 903.02 CAR 901.25 |
| High | Without the pilot or a visual observer having the aircraft in sight (outside the sheltered, extended VLOS and BVLOS cases); the payloads in subsection 901.43(1); BVLOS within five nautical miles of a listed aerodrome; weather outside section 901.34; carrying persons; or any operation the Minister determines needs one CAR 903.02 CAR 901.43 CAR 901.34 |
Two rules decide edge cases. If the application covers several operations, the highest complexity level applies — but an application for two or more medium-complexity operations is deemed high-complexity. CAR 903.02
The information you submit differs by tier: very low and low are described in subsection (6), and medium and high in subsection (7), which adds a detailed plan of how the operations will be carried out, a risk assessment accounting for ground and air risks, instructions for maintaining the system, and the details of any detect-and-avoid system. CAR 903.02
The Minister shall issue or amend the certificate if the applicant demonstrates the ability to perform the proposed operations without adversely affecting aviation safety or the safety of any person. CAR 903.03
8. What the complexity level costs, and how long it takes
Two numbers follow from the complexity level, and the AIM publishes both. Since 4 November 2025 new service standards and charges apply to the issuance of an SFOC — RPAS:
| Complexity | Service standard | Charge |
|---|---|---|
| Very low (903.02(1)) | 30 business days from a complete application | $20 AIM 3.6.3 |
| Low (903.02(2)) | 30 business days from a complete application | $75 AIM 3.6.3 |
| Medium (903.02(3)) | 60 business days from a complete application | $900 AIM 3.6.3 |
| High (903.02(4)) | 60 business days from a complete application | $2,000 AIM 3.6.3 |
| Two or more medium-complexity operations | 60 business days from a complete application | $2,000 AIM 3.6.3 |
Three things about the table are worth noticing. The clock is business days from a COMPLETE application, so an incomplete one does not start it. Services outside Transport Canada — ISED or NAV CANADA, for example — are beyond its control and may extend the processing time, which is the reason a charge does not buy a date. And special aviation event SFOCs issued under 603.02 already had service standards, so they sit outside this table. AIM 3.6.3
9. Modification is where a declaration can be lost
The declaration covers a model as declared, so a change to the aircraft is the event that puts it outside. Three rules make that concrete:
- Attaching a flight termination system to an RPAS for which it is not standard equipment is a modification and must meet the requirements of section 901.70. The section also says initiation of such a system may only be done if it does not endanger aviation safety or the safety of any person (901.44). AIM 3.2.32
- Section 900.01 defines maintenance as the inspection, repair or modification of a system that is necessary to prevent an unsafe or potentially unsafe condition — a definition about purpose, not about who performs the work. CAR 900.01
- A third party changing equipment — the electrical systems, for instance — outside the specification moves the aircraft away from what was declared, which is the reason the modification questions sit under the declaration rules rather than under maintenance. AIM 3.4.4
And where a declaration is not required at all. For basic operations no RPA manufacturer declaration is needed — although the aircraft must be operated in accordance with the manufacturer's instructions and must carry a clearly visible registration number. AIM 3.3.3
The micro case completes it. A micro-RPA that was modified or fitted with accessories to reach 250 g may be used in the conduct of a flight review once registered — taking into account that it will not have an RPAS safety assurance declaration, and therefore cannot be used to operate in controlled airspace or close to people. AIM 2.0
Which operations the declaration attaches to is set by section 901.62, the application section of Division V: the VLOS operation of a small RPA in controlled airspace, at less than 100 ft but not less than 16.4 ft from a person not involved, at less than 16.4 ft, and within 3 NM of an airport or 1 NM of a heliport. Those are the operations a declaration unlocks, and the list is why the question "may I fly closer?" is answered by the model rather than by the pilot. CAR 901.62
And the declaration is not a formality performed blind: under the advisory circular that carries the standard, the applicable Standard 922 clause identifies the technical requirements that are to be verified before the declaration is made — the verification precedes the declaration rather than following it. 922 05
Quick answers
| Situation | What is required |
|---|---|
| A 901.69 operation, Division V | A declaration on the model, covering the applicable Standard 922 requirements CAR 901.69 |
| Any Division VI operation | A declaration on the model, unless the 922.10 requirement is met by a visual observer under Standard 923 CAR 901.95 |
| The 901.69(f)/(g) or 901.87(b) operations | An acceptance letter issued within the previous two years, then the declaration CAR 901.194 |
| A modified system | Demonstrate it still meets Standard 922; for the close-in operations, follow the declarant's instructions CAR 901.70 |
| Missing annual report | The declaration is invalid for the close-in operations while it is outstanding CAR 901.194 |
| An advertised event | A low-complexity SFOC application CAR 903.02 |
| Two or more medium-complexity operations | Deemed a high-complexity application CAR 903.02 |
Warning The declaration is not a licence for your flight; it is a claim about a model. It names the operations the model is intended to conduct and the Standard 922 requirements that are its subject. Flying an operation outside those, or on a modified system that no longer meets them, is not covered by it. CAR 901.194 CAR 901.70
Where people go wrong
| Symptom | Likely cause | What to do |
|---|---|---|
| Your model has a declaration and you assumed any operation is covered | The declaration names the intended operations and the technical requirements | Check both against the operation CAR 901.194 |
| You modified the aircraft after the declaration | 901.70 requires the system to keep meeting Standard 922, and the declarant's instructions for the close-in operations | Re-establish compliance before flying CAR 901.70 |
| The annual report is late | The declaration is invalid for the close-in operations while it is outstanding | Submit it CAR 901.194 |
| You applied for two medium-complexity operations | Two or more medium operations are deemed high-complexity | Expect the high-complexity requirements CAR 903.02 |
| You want to fly above the 901.25 altitudes | Medium-complexity, unless authorized under subsection 901.71(2) | Apply accordingly CAR 903.02 |
| You intend BVLOS near a listed aerodrome | High-complexity | Apply as high-complexity CAR 903.02 |
Test yourself
Sources
— SFOC—RPAS Service Standard and Charges
CAR 901.69 — Declaration — Permitted Operations
CAR 901.70 — Operation of a Modified Remotely Piloted Aircraft System
CAR 901.87 — Application
CAR 901.95 — Declaration — Permitted Operations
CAR 901.96 — Operation of a Modified Remotely Piloted Aircraft System
CAR 901.194 — Declaration
CAR 901.196 — Issuance of Acceptance Letter
CAR 903.02 — Application for Special Flight Operations Certificate — RPAS
CAR 903.03 — Issuance or Amendment of Special Flight Operations Certificate — RPAS
Standard 922 s.922.10, Standard 923 (referenced)
Consolidation: CARs current to 2026-09-21