Registering an RPA: who may own one, what the application says, and what you must show

Know who is qualified to be the registered owner of a remotely piloted aircraft, what the application and the certificate each contain, where the weight line falls once accessories are added, and what you have to be able to produce when someone asks.

• You know the aircraft is 250 g or more in operating weight, because registration is required from that line up. CAR 900.13
• You know what operating weight measures, and what it leaves out. AIM 2.0
• You know the difference between the certificate of registration and the registration number that has to be visible on the aircraft. CAR 900.14

Section 900.15 sets three categories and one floor: a Canadian citizen or permanent resident; a corporation or entity incorporated or formed under the laws of Canada or a province; or a government in Canada, or an agent or mandatary of one. No individual is qualified unless they are at least 14 years of age. CAR 900.15

The AIM restates the same three categories with the age minimum in front of them, and adds the foreign-operator case: a foreign operator or pilot needs a special flight operations certificate to comply with the registration and marking requirements — but not if they are operating an RPA already registered by an owner qualified under section 900.15. AIM 3.1

The application changes shape with the applicant, and the three shapes are worth keeping apart: CAR 900.16

The applicant	What the application includes
An individual	Name and address; date of birth; whether they are a Canadian citizen or a permanent resident CAR 900.16
A corporation or entity	Legal name and address; the name and title of the person making the application; the business number assigned by the Minister of National Revenue, if any CAR 900.16
His Majesty in right of Canada or a province	The name of the government body; the name and title of the person making the application CAR 900.16

Then there are the items every applicant supplies: whether the aircraft was purchased or built by the applicant; the date of purchase, if applicable; the manufacturer and model, if applicable; the serial number, if applicable; the category of aircraft — fixed-wing, rotary-wing, hybrid or lighter-than-air; and any Canadian registration number previously issued for that aircraft. CAR 900.16

Those "if applicable" qualifiers are the point of a whole question: the date of purchase is not required of an applicant who built the aircraft. CAR 900.16

The certificate of registration issued under subsection 900.16(3) contains three things: a registration number, the name and address of the registered owner, and the serial number of the aircraft, if applicable. CAR 900.16

The register the Minister maintains under section 900.17 is a different list: it holds the registered owner's name and address, the registration number, and any other particulars the Minister determines are necessary. The serial number is on the certificate; section 900.17 does not name it as a register entry. CAR 900.17

Registration is completed online through the Drone Management Portal, and a certificate with a registration number is provided immediately once the required information is submitted and the fee is paid. AIM 3.1

The registration number must then be clearly visible on the aircraft; no pilot may operate the system without it. CAR 900.14 The method of marking is left to the owner's discretion, but the AIM's guidance is to put it on the main body rather than on frangible or removable parts such as batteries, motor mounts or payloads — the parts that come off. AIM 3.1

A micro-RPA is one with an operational weight below 250 g; a small RPA is 250 g to 25 kg. Two rules decide which side an aircraft is on: AIM 2.0 AIM 1.0

Element	Counted in operational weight?
The control station	No — it is not factored into the calculation AIM 2.0 AIM 1.0
A payload, such as an optional camera, lens filter, pegs, propeller guards, stickers or lights	Yes AIM 2.0

So a 240 g micro-RPA fitted with propeller guards that bring it to 250 g is a small RPA: it must be registered and marked, and its pilot must meet the small-RPA requirements — and once registered it may be used for a flight review, with the caveat that it has no safety assurance declaration and so cannot be flown in controlled airspace or close to people. Demodify it back below 250 g and the registration certificate is no longer valid — the aircraft is a micro-RPA again — but there is no need to deregister it. AIM 2.0

The certificate of registration must be easily accessible to the pilot for the duration of the operation, or the flight is not permitted at all. CAR 900.20

And proof of registration — digital or physical — must be presented on request to a peace officer, an immigration officer, or a person delegated by the Minister of Transport, such as a Transport Canada inspector. The authority to demand it is in the CARs' document-production section as well as in section 900.20. AIM 3.1 CAR 103.02

Two different failures carry two different exposures, and they are easy to mix up: AIM 3.1 AIM 3.1.1

The failure	Individual	Corporate
Failing to register, mark, or present proof of registration	Up to $5,000 AIM 3.1 AIM 3.0	Up to $25,000 AIM 3.1 AIM 3.0
Failing to notify the Minister under the cancellation and change-of-address rules	Up to $1,000 AIM 3.1.1	Up to $5,000 AIM 3.1.1

Question	The answer
Who may be a registered owner?	A citizen or permanent resident; a Canadian or provincial corporation or entity; a government in Canada or its agent or mandatary — and no individual under 14 CAR 900.15
What does an individual applicant give?	Name and address, date of birth, and citizenship or permanent-residence status CAR 900.16
What does the certificate contain?	Registration number, the owner's name and address, and the serial number if applicable CAR 900.16
Is the control station counted in operational weight?	No — payloads and accessories are AIM 2.0
Who may demand proof of registration?	A peace officer, an immigration officer, or a person delegated by the Minister CAR 103.02
Is a digital copy enough?	Yes — proof may be digital or physical AIM 3.1

• The certificate is accessible for the duration of the operation CAR 900.20
• The registration number is clearly visible on the aircraft CAR 900.14
• The date of purchase, manufacturer, model and serial number are required only if applicable CAR 900.16
• The serial number is a certificate item, not one section 900.17 lists in the register CAR 900.17

Symptom	Likely cause	What to do
The control station is added to the weight	It is excluded	Count the aircraft and its payload only AIM 2.0
A 240 g micro is still treated as a micro after guards are fitted	Accessories count	Register and mark it as a small RPA AIM 2.0
The date of purchase is answered as always required	It is "if applicable"	Check whether the applicant built the aircraft CAR 900.16
A paper certificate is thought to be the only proof	Digital counts	Show the digital copy AIM 3.1
The $1,000 / $5,000 pair is given for failing to register	That pair belongs to notification	Registration, marking and proof failures are $5,000 / $25,000 AIM 3.1
The serial number is looked for in the register	Section 900.17 does not list it	It is on the certificate CAR 900.17

Practise: Registration operational weight

Practise: Registration application

Practise: Registration certificate

Practise: Registration proof of registration

Practise: Registration proof

Practise: Registration penalties

• CAR 103.02 — Production of Documents and Records
• CAR 900.13 — Registration
• CAR 900.14 — Registration Number
• CAR 900.15 — Qualifications To Be Registered Owner
• CAR 900.16 — Registration Requirements
• CAR 900.17 — Register of Remotely Piloted Aircraft
• CAR 900.20 — Access to Certificate of Registration
• TC AIM RPA 2.0 — Micro Remotely Piloted Aircraft
• TC AIM RPA 3.0 — Small and Medium RPAs
• TC AIM RPA 3.1 — Registration of RPAs
• TC AIM RPA 3.1.1 — Modifying a Registration