EASA ED Decision 2025/018/R – Formal Regulatory Summary
Comprehensive Guide for Competent Authorities, Compliance Managers, and UAS Operators1. Introduction
On September 29 2025, the European Union Aviation Safety Agency (EASA) has issued Executive Director Decision 2025/018/R, introducing Amendment 3 to Issue 1 of the Acceptable Means of Compliance (AMC) and Guidance Material (GM) to Commission Implementing Regulation (EU) 2019/947.This amendment integrates the latest version of the Specific Operations Risk Assessment (SORA) 2.5, developed by the Joint Authorities for Rulemaking on Unmanned Systems (JARUS), into the European regulatory framework for unmanned aircraft systems (UAS) operations in the specific category.
The decision aims to ensure a harmonised, risk-based approach to UAS operations across EASA Member States, reflecting international best practices while addressing European-specific requirements. It also introduces clarifications and simplifications to reduce regulatory burden without compromising safety.
Official Source:
EASA Agency Decisions
2. Background
2.1 Regulatory Context
Commission Implementing Regulation (EU) 2019/947 establishes the rules and procedures for the operation of unmanned aircraft within the European Union. Under Article 11, UAS operators intending to conduct operations in the specific category must perform a risk assessment and obtain an operational authorisation from the competent authority.To support this process, EASA publishes AMC and GM, which provide non-binding standards and interpretative material. These documents help operators and authorities apply the regulation consistently.
Reference:
Regulation (EU) 2019/947
2.2 Evolution of SORA
The Specific Operations Risk Assessment (SORA) methodology was first introduced in Issue 1 of the AMC and GM through ED Decision 2019/021/R. After four years of practical application, stakeholders identified ambiguities and areas for improvement.In response, JARUS developed SORA 2.5, which underwent public consultation and incorporates lessons learned from global UAS operations. EASA adapted this methodology to the EU regulatory environment, ensuring consistency with Regulation (EU) 2018/1139 (the Basic Regulation) and related implementing acts.
Reference:
Basic Regulation (EU) 2018/1139
3. Objectives & Scope of the Amendment
- â–¸Enhance clarity and usability of the risk assessment process.
- â–¸Maintain a high level of safety while simplifying compliance.
- â–¸Promote harmonisation and a level playing field for UAS operators.
- â–¸Incorporate European-specific requirements, particularly regarding design verification and certification for higher-risk operations.
- â–¸UAS operators (private and commercial).
- â–¸National competent authorities (NAAs).
- â–¸UAS manufacturers and design organisations.
- â–¸Maintenance organisations and training entities.
4. Overview of Key Changes
4.1 Integration of SORA 2.5
The new methodology introduces a risk-proportionate approach for determining evidence and assurance required for UAS operations in the specific category.4.2 Removal of Cybersecurity Requirements
JARUS included cybersecurity provisions in SORA 2.5. EASA removed these from the EU version, deeming them insufficiently proportionate. A separate cybersecurity framework will be developed later.4.3 Clarification of Roles
- â–¸UAS Operator: Responsible for operational safety and compliance.
- â–¸Design Organisation: Provides design evidence for OSOs and mitigations.
- â–¸Competent Authority: Reviews applications and issues authorisations.
4.4 New Design Verification Requirements
- â–¸SAIL IV: Requires a Design Verification Report (DVR) issued by EASA.
- â–¸SAIL V & VI: Requires a Type Certificate under Part 21 of Regulation (EU) No 748/2012.
4.5 Updated Robustness Levels
Three levels of robustness—low, medium, high—are defined for mitigations and OSOs.4.6 Revised Templates
Operational authorisation forms now include fields for:- â–¸C2 link type.
- â–¸Adjacent ground area size.
- â–¸Propulsion system type.
- â–¸E-conspicuity and green flashing light.
5. Detailed Explanation of Amendments
5.1 AMC1 Article 11 – SORA Integration
The AMC now incorporates the European version of SORA 2.5, adapted from JARUS with EU-specific modifications:- ▸Removal of “guidance” vs. “requirement” distinction.
- ▸Replacement of “applicant” with specific organisational roles.
- ▸Clarification of NAAs’ and EASA’s responsibilities for design and operational compliance.
5.2 Annex A – Application Templates
Annex A provides templates for:- â–¸Risk assessment documentation.
- â–¸Operations manual structure.
- â–¸Compliance matrix linking OSOs and mitigations to evidence.
5.3 Annex B – Ground Risk Mitigations
Defines integrity and assurance criteria for mitigations such as:- â–¸M1(A): Sheltering.
- â–¸M1(B): Operational restrictions.
- â–¸M1(C): Ground observation.
- â–¸M2: Impact energy reduction (e.g., parachutes).
5.4 Annex C – Air Risk Strategic Mitigations
Includes mitigations like:- â–¸Operating in segregated airspace.
- â–¸Time-of-day restrictions.
- â–¸Use of U-space services.
5.5 Annex D – Tactical Mitigations
Defines Tactical Mitigation Performance Requirements (TMPRs) for BVLOS operations, including detect-and-avoid systems.5.6 Annex E – OSO Robustness Criteria
Operational Safety Objectives cover:- â–¸Organisational competence.
- â–¸UAS design and maintenance.
- â–¸Human factors and training.
- â–¸Environmental conditions.
5.7 Annex F – Ground Risk Model
Provides mathematical models for calculating critical areas and containment requirements.6. SORA 2.5 Methodology – Step-by-Step
The SORA process consists of 10 steps:- Document the proposed operation.
- Determine intrinsic ground risk class (iGRC).
- Apply ground risk mitigations (optional).
- Determine initial air risk class (iARC).
- Apply strategic mitigations to reduce ARC.
- Apply tactical mitigations and assess TMPRs.
- Determine Specific Assurance and Integrity Level (SAIL).
- Define containment requirements.
- Identify OSOs and required robustness levels.
- Compile Comprehensive Safety Portfolio (CSP).
Each step is detailed in AMC1 Article 11 and Annexes A–F.
7. Roles & Responsibilities
7.1 UAS Operator
- â–¸Conduct risk assessment using SORA.
- â–¸Prepare operations manual and compliance matrix.
- â–¸Submit application to competent authority.
7.2 Design Organisation
- â–¸Provide design evidence for OSOs and mitigations.
- â–¸Obtain DVR or Type Certificate for higher SAIL levels.
7.3 Competent Authority
- â–¸Review applications and supporting evidence.
- â–¸Issue operational authorisations.
- â–¸Conduct oversight and audits.
8. Transition Rules
- â–¸Immediate applicability: SORA 2.5 can be used for new applications.
- â–¸Grace period: Member States may accept SORA 2.0 for up to 6 months.
- â–¸Validity: Operational authorisations under SORA 2.0 remain valid for 2 years.
9. Monitoring & Evaluation
EASA will monitor implementation through:- â–¸Statistics from NAAs on authorisations issued.
- â–¸Feedback from operators and authorities.
- â–¸Usage and occurrence data collected via IAM HUB.
10. References
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About the Author
120mAGL Editorial Team
The 120mAGL Editorial Team is dedicated to providing clear, accurate, and accessible information about European UAS regulations. Our content is based on official EASA documentation and designed to help drone pilots fly safely and legally.
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This content is for educational purposes only and is based on EASA regulations current at the time of generation.
Always consult the official EASA documentation and your local aviation authorities for the most current regulations and legal compliance requirements before operating any UAS.