Is my aircraft declared for this — and what does the declarant owe afterwards?

Know what a safety assurance declaration actually states, which Standard 922 declarations each operation depends on, who is allowed to declare, and what the declarant has to keep doing after the declaration is made.

The companion lesson covers when a declaration is required and what happens to a modified system. This one covers the declaration itself: its content, its coverage, and its afterlife. CAR 901.194 AIM 3.4.1 AIM 3.4.1

• You know whether the operation is Advanced or Level 1 Complex, because those are the operations a declaration supports. AIM 3.4.4
• You know which Standard 922 requirements your operation leans on, because the declaration is a statement about those requirements and nothing else. AIM 3.4.4
• You know whether the model has an acceptance letter, because that is what brings the after-declaration duties into play. CAR 901.197

Advanced and Level 1 Complex operations of a small or medium remotely piloted aircraft require the Declarant or Declaring Entity to provide the Minister a safety assurance declaration stating that the system is intended for those operations, that it has all necessary documentation, and that it meets the technical requirements set out in Standard 922. AIM 3.4.4

Three claims, and none of them is about your flight plan. The declaration is a statement about a model and the standard requirements that model is asserted to meet. CAR 901.194

The AIM publishes a summary of which Standard 922 declarations go with which operation, and it is the table worth knowing:

Operation	Small aircraft	Medium aircraft
VLOS uncontrolled, more than 100 ft / 500 ft from people	No declaration — Basic Operations AIM 3.4.4	922.08 for 901.69(e) AIM 3.4.4
Controlled airspace	922.04 for 901.69(a) AIM 3.4.4	922.04 + 922.08 for 901.69(h) AIM 3.4.4
Less than 100 ft but more than 16.4 ft from people	922.05 for 901.69(b) AIM 3.4.4	922.07 pre-validated declaration for 901.69(f) AIM 3.4.4
Less than 16.4 ft from people	922.06 for 901.69(c) AIM 3.4.4	922.07 pre-validated declaration for 901.69(g) AIM 3.4.4
Sheltered operation in controlled airspace	922.04 for 901.69(d) AIM 3.4.4	Not permitted AIM 3.4.4
BVLOS more than 1 km from populated areas	922.08, 922.09, 922.10, 922.11 for 901.87(a) AIM 3.4.4	922.08(3–6), 922.09, 922.10, 922.11 AIM 3.4.4
BVLOS less than 1 km from populated, or over sparsely populated areas	922.07 pre-validated declaration with 922.09, 922.10, 922.11 and 922.12 for 901.87(b) AIM 3.4.4 Std 922.12	High-complexity SFOC — RPAS, not a declaration AIM 3.4.4

Two things fall out of that table. A medium aircraft reaches its close-in operations only through a pre-validated declaration, and its closest BVLOS case is not available by declaration at all. And the environmental envelope (922.12 — the demonstrated environmental envelope) appears only in the row for BVLOS near or over populated areas. AIM 3.4.4 Std 922.12

The model's safety assurance declarant is not necessarily the original manufacturer. A declarant declaring for a modification — an after-market parachute system, for example — or for the provision of a service such as detect-and-avoid or command and control may have less complete configuration control over the system, which makes the declaration harder to support. AIM 3.4.4

Ideally the declarant has a relationship with the original equipment manufacturer, through API documentation or specifications and tolerances that expose variations in the original system. The practical consequence is stated plainly: where that relationship is not possible, it is the declarant's responsibility to perform the tests and analyses needed to ensure that the final system as declared — including their service or modification — meets the declared Standard 922 requirements. AIM 3.4.4

Section 901.24(b) requires the pilot to be familiar with any declaration made for the model — and the AIM puts the operational version of that duty plainly: before commencing a flight, the pilot must ensure the system has a valid and appropriate safety assurance declaration before conducting Advanced or Level 1 Complex operations. CAR 901.24 AIM 3.4.4

"Valid and appropriate" is two questions. Valid — is it still in force? Appropriate — does it cover the operation I am about to conduct? CAR 901.194

A system operated outside the manufacturer's instructions — wind, temperature, centre of gravity, or other operational limits and minimums — is not considered to be within the declared capabilities of the system, and is not safe for flight under section 901.31. It may attract individual penalties of $1,000 and corporate penalties of $5,000, per violation. AIM 3.4.4 CAR 901.31

That single sentence is why the operating limits in the manual are not advice. Exceeding one puts the flight outside the declaration the operation depends on. AIM 3.4.4

The declarant does not need to submit the results of their design verification tests with the declaration, but must be able to provide them if requested by Transport Canada. AIM 3.4.4

So the declaration is a claim whose evidence is retained rather than filed — which is a distinction worth holding on to when a question asks what accompanies the declaration. AIM 3.4.4

Level 1 Complex operations carry a higher level of risk and require the declarant to apply for a pre-validated declaration, or PVD. The process involves a review of how the system or a configurable element complies with the applicable Standard 922 requirements before a safety assurance declaration is made. AIM 3.4.4 Std 922.07

Once the manufacturer has shown that it has the resources and ability to design a safe system, Transport Canada issues a Letter of Acceptance for that model, which is what allows the manufacturer to make a declaration. AIM 3.4.4

A PVD also brings obligations with it: manufacturers must submit annual safety reports to Transport Canada and collect service difficulty reports from operators. And a PVD can cover the system as a whole, specific components that expand operational capabilities — parachutes, detect-and-avoid, command and control — or a combination. AIM 3.4.4

The order matters here as much as it does elsewhere: the letter of acceptance comes before the declaration, not after it. CAR 901.194

A declaration is the beginning of a duty, not the end of one, and the three sections that carry it are all conditioned on the model having an acceptance letter.

A service difficulty reporting system. The person who made the declaration shall establish and maintain a system for receiving, recording, analysing and investigating reports and information about any reportable service difficulty for that model. The system must include a means of receiving reports and information, and instructions on what information must be submitted to the declarant. CAR 901.197

Investigation and mandatory action. On receiving a service difficulty report for such a model, the declarant shall investigate it and, if it results from a deficiency that means the system no longer meets the technical requirements specified in the declaration, develop a mandatory action to rectify the deficiency. CAR 901.198

An annual report. The declarant shall submit an annual report for the model containing the name of the person submitting it; the name of the model; the actual, or estimated, total hours of operation in Canada of systems of that model during the year; and the number of reportable service difficulty reports received, a summary of the reports for which mandatory actions were developed, and a description of those actions. It is submitted each year not later than the anniversary of the day the declaration was made. CAR 901.199

That last deadline is the one to remember, because it is tied to the declaration rather than to the calendar year. CAR 901.199

Question	Answer
What does a declaration state?	The system is intended for those operations, has all necessary documentation, and meets the Standard 922 requirements AIM 3.4.4
Who may declare?	The Declarant or Declaring Entity — not necessarily the original manufacturer AIM 3.4.4
No relationship with the OEM?	The declarant performs the tests and analyses for the system as declared AIM 3.4.4
The pilot's duty before flight	Ensure a valid and appropriate declaration for Advanced or Level 1 Complex operations CAR 901.24
Flying outside the manual's limits	Outside the declared capabilities, not safe for flight, penalties per violation CAR 901.31
Design verification test results	Not submitted with the declaration, but available on request AIM 3.4.4
Pre-validated declaration	A review of Standard 922 compliance before declaring; a Letter of Acceptance follows AIM 3.4.4
Service difficulty reporting system	Required where an acceptance letter exists: receiving reports and instructing what to submit CAR 901.197
A service difficulty report arrives	Investigate; if the model no longer meets the declared requirements, develop a mandatory action CAR 901.198
The annual report	Due not later than the anniversary of the declaration CAR 901.199

Warning The declaration is not a one-off filing. Where the model has an acceptance letter, the declarant must keep a service difficulty reporting system, investigate what it receives, develop mandatory actions when the model stops meeting the declared requirements, and file an annual report by the anniversary of the declaration. A declaration nobody maintains is a claim going stale. CAR 901.197 CAR 901.199

Symptom	Likely cause	What to do
Your aircraft is declared, but not for this operation	The declaration names the operations it supports	Check the coverage before flying AIM 3.4.4
You fly above the manual's stated wind limit	Outside the instructions is outside the declared capabilities	Stay within the limits AIM 3.4.4
TC asks for your design verification results	They are retained, not submitted	Provide them AIM 3.4.4
You declared a modification and have no OEM relationship	The obligation falls on the declarant	Perform the tests and analyses for the system as declared AIM 3.4.4
You hold an acceptance letter but no reporting system	901.197 requires one	Establish a means of receiving reports and instructions on what to submit CAR 901.197
A service difficulty report arrives and nothing happens	901.198 requires investigation and, where needed, a mandatory action	Investigate and act CAR 901.198
The annual report is two months late	It is due by the declaration's anniversary	File it CAR 901.199

Practise: Declarations under section 901.194

Practise: Rpas declaration

• CAR 901.24 — Pre-flight Information
• CAR 901.31 — Operating Manuals
• CAR 901.194 — Declaration
• CAR 901.197 — Establishing a Service Difficulty Reporting System
• CAR 901.198 — Investigation of Service Difficulty Reports
• CAR 901.199 — Annual Report
• Standard 922 s.922.07 — Safety and Reliability (the standard behind a pre-validated declaration)
• Standard 922 s.922.12 — Demonstrated Environmental Envelope
• AIM RPA 3.4.4 — RPAS Safety Assurance Declaration
• Consolidation: CARs current to 2026-09-21