The Post-2025 Horizon: What Comes After "Level 1" for Canadian Drone Pilots?

By: Colonel (ret) Bernie Derbach, KR Droneworks, 13 Jan 26

It has been exactly sixty-nine days since the Canadian drone industry collectively exhaled. On November 4, 2025, the regulatory dam finally broke. For years, pilots and operators had been navigating a system where flying a drone over 25kg or conducting even the simplest Beyond Visual Line of Sight (BVLOS) mission meant drowning in Special Flight Operations Certificate (SFOC) paperwork.

Today, that landscape has shifted permanently. The implementation of the Level 1 Complex Pilot Certificate and the deregulation of Medium RPAS (25kg–150kg) for VLOS operations has democratized the lower skies. We are now seeing agricultural spray drones operating on standard certificates and infrastructure inspectors flying miles of pipeline without filing a single SFOC.

But if you think Transport Canada (TC) is finished, you are looking at the wrong map. The nomenclature itself—"Level 1"—implies a ladder that we have only just begun to climb. The current regulations were designed to solve the "easy" problems: rural, remote, and uncontrolled airspace. The hard problems—urban density, heavy cargo, and human passengers—are still ahead.

Based on current regulatory frameworks, international roadmaps (FAA/EASA harmonization), and the technical gaps left by the 2025 amendments, this article theorizes what the Level 2 Complex, Heavy Lift, and Passenger certifications will look like—and when you might be holding them in your hand.

Part I: The "New" Status Quo (2025–2026)

Before looking forward, we must understand the baseline we are standing on today. The November 2025 amendment (SOR/2025-70) introduced three critical pillars that form the foundation for all future certifications.

1. The RPAS Operator Certificate (RPOC)

This is arguably the most significant shift. Previously, safety was tied to the pilot. Now, for Complex operations, it is tied to the organization. The RPOC acts like an "airline operating certificate" for drone companies. It requires an Accountable Executive and a Safety Management System (SMS). This structure is scalable; TC can add new privileges to an existing RPOC without rewriting the regulations for every pilot.

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2. Level 1 Complex: "The Rural BVLOS"

The new Level 1 certificate allows for BVLOS, but the "safety case" relies on isolation rather than technology. You can fly BVLOS because you are in uncontrolled airspace, below 400 feet, and >1 km away from populated areas. You don't need a radar on your drone because the risk of hitting a person or a Cessna is statistically managed by where you fly, not what you fly.

3. Medium RPAS Freedom

The removal of the SFOC requirement for drones between 25kg and 150kg (provided they are flown VLOS) was a nod to the maturity of the hardware. This has unleashed the "middle mile" logistics and agricultural sectors, allowing heavy sprayers and delivery drones to operate almost as easily as a DJI Mavic.

Part II: The Next Step — "Level 2 Complex" (The Urban Frontier)

The Theory: A standardized certificate for High-Risk BVLOS in populated areas and controlled airspace.

Estimated Timeline: 2027–2028

Key Technology: Detect-and-Avoid (DAA)

The gap in the current 2025 regulations is obvious: cities. Currently, if you want to fly a delivery drone over a suburb (Populated Area) or inspect a bridge inside a Control Zone (Controlled Airspace) while BVLOS, you are stuck in the SFOC process. This is because the "isolation" safety case of Level 1 doesn't work here. You are now sharing airspace with helicopters, medevacs, and general aviation.

We predict the Level 2 Complex Certificate will emerge to standardize these operations.

The "See and Avoid" Problem

To fly BVLOS in a city, the drone must replace the pilot's eyes. It must be able to "see" a non-cooperative aircraft (a Piper Cub without a transponder) and automatically maneuver to avoid it.

Level 2 Requirements (Theorized):

• Mandatory DAA: The drone must be equipped with onboard radar, acoustic sensors, or camera-based vision systems certified to a specific standard (likely ASTM F3442).

• Robust C2 Link: The Command and Control (C2) link will need to be run over a managed network (like LTE/5G) with guaranteed Quality of Service (QoS), rather than the unlicensed 2.4GHz bands used today.

• SORA-Based Training: Pilot training will shift from "stick and rudder" skills to Systems Management. The pilot will likely be managing multiple drones (m:N operations) and interpreting data from the DAA system rather than manually flying the aircraft.

The Timeline Driver

Why 2028? Transport Canada needs data. The Level 1 operations occurring right now (2026) are generating the safety data required to prove that the RPOC structure works. Furthermore, the DAA technology is currently expensive and heavy. By 2027/2028, miniaturized radar and standardized 5G drone networks will be mature enough to mandate as a requirement for Level 2.

Part III: The Heavyweight Division — >150kg Certification

The Theory: A "Heavy RPAS" License closer to a Commercial Pilot License (CPL).

Estimated Timeline: 2028+

Key Enabler: Type Certification

The current "Medium" category caps strictly at 150kg. But the industry is already pushing past this. Agricultural drones are carrying larger tanks, and forestry companies are looking at drones that can haul 500lbs of saplings or equipment.

Once a drone exceeds 150kg, the kinetic energy involved in a crash is comparable to a small manned aircraft. The "Manufacturer Declaration" system (where a company simply declares "our drone is safe") is insufficient for this risk class.

The Shift to "Type Certification"

We predict a new Heavy RPAS category that will require the aircraft to hold a formal Type Certificate. This means the aircraft design is rigorously tested and approved by Transport Canada Civil Aviation (TCCA), identical to the process for a Cessna 172.

Implications for Pilots:

• Ground School: Expect a curriculum that mirrors the Private Pilot License (PPL) or CPL, with heavy emphasis on weight and balance, meteorology, and air law.

• Maintenance: You won't be fixing these drones yourself. Maintenance will likely require a licensed AME (Aircraft Maintenance Engineer) or a new "R-AME" (Remote AME) rating.

Part IV: Passenger Carrying & UAM (The "Level 3" Dream)

The Theory: Powered Lift Pilot License

Estimated Timeline: 2030+

Key Enabler: UTM (Unmanned Traffic Management) and Public Trust

The ultimate tier is Urban Air Mobility (UAM)—the "Air Taxis" or eVTOLs (electric Vertical Take-Off and Landing) promised by companies like Joby, Archer, and Wisk.

Canada is a signatory to the Advanced Air Mobility (AAM) Roadmap alongside the FAA (USA), CAA (UK), and CASA (Australia). This roadmap suggests that passenger-carrying drones will not be flown under an RPAS certificate initially.

The "Pilot on Board" Phase

The first generation of Air Taxis (expected late 2020s) will have a pilot on board. They will fly under existing Commercial Pilot regulations, likely with a "Powered Lift" type rating.

The "Remotely Piloted" Phase (2030+)

When the pilot is removed from the cockpit, we enter the true "Level 3" domain. This will require a fully integrated UTM (Unmanned Traffic Management) ecosystem.

• UTM Explained: Unlike current Air Traffic Control (where a human speaks to a human), UTM is digital-to-digital. The drone negotiates its path with a server, which negotiates with other drones and ATC automatically.

This level of certification will be incredibly exclusive, likely restricted to pilots employed by major "Air Taxi Airlines" rather than independent operators.

Part V: What This Means for You (The "RPOC" Economy)

The most subtle but important shift in the 2025 regulations is the move away from the individual and toward the organization.

In the past, an Advanced Pilot Certificate was your ticket to work. In the post-2025 world, the RPOC is the ticket.

• For Freelancers: The value of being a "lone wolf" is diminishing. To access Level 1 (and eventually Level 2) privileges, you generally need to be flying under an RPOC. This means independent pilots will likely need to incorporate and obtain their own RPOC (a significant administrative burden) or contract themselves out to larger RPOC-holding agencies.

• The "Airline" Model: We are moving toward a model where pilots are employees or contractors of "Drone Airlines." These organizations handle the complex regulatory maintenance (SMS, audits, equipment declarations), allowing the pilot to focus on operations.

Actionable Advice for 2026

If you are holding an Advanced Certificate today, you are now the "entry-level" professional. To future-proof your career:

1. Get Level 1 Certified: Even if you don't fly BVLOS, the training for Level 1 Complex introduces you to the Safety Management Systems (SMS) and risk methodologies (like SORA) that will be mandatory for Level 2.

2. Learn the "Radio": Not the handheld controller, but the RF spectrum. Understanding C2 links, LTE/5G latency, and network reliability will be a critical skill for urban BVLOS.

3. Specialize: The days of the "generalist" drone pilot are numbered. The future licenses (Heavy Lift, Urban Complex) will be specialized ratings. Pick a lane—Inspection, Cargo, or Agriculture—and master the specific platforms used in that sector.

Conclusion

The "Level 1" era has officially begun. It has removed the shackles for rural and industrial operations, but it has also drawn a clear line in the sand: the easy days of wild-west flying are over. The next levels of certification will demand professional discipline, organizational maturity, and a deep reliance on automation.

Transport Canada has built the ladder. It is now up to us to climb it.

References & Further Reading

• SOR/2025-70: Regulations Amending the Canadian Aviation Regulations (Remotely Piloted Aircraft Systems).

• Advisory Circular (AC) 903-002: Remotely Piloted Aircraft Systems (RPAS) Safety Assurance.

• Transport Canada NPA 2023-03: Notice of Proposed Amendment for Lower-Risk BVLOS.

• JARUS SORA: Joint Authorities for Rulemaking on Unmanned Systems – Specific Operations Risk Assessment.