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Transport Canada Advisory: Global Standards & The Future of RPAS Safety Management

By: Colonel (ret) Bernie Derbach, KR Droneworks, December 17, 2025



Introduction

We are writing today to share a significant update directly from the Canadian Aviation Regulation Advisory Council (CARAC). Transport Canada has officially announced that the Third Edition of Annex 19 – Safety Management has been adopted by the International Civil Aviation Organization (ICAO) Council.


For the broader aviation community, this is a procedural update. However, for Canadian RPAS pilots—specifically those holding or pursuing a Level 1 Complex RPAS Operator Certificate (RPOC)—this signals a critical shift in how safety systems must be structured and maintained. As Canada moves to align its regulations with these international standards, the expectations for your operational documentation are evolving. Here is what you need to know.


The Core Changes: NPA 2024-002


Transport Canada has published a Notice of Proposed Amendment (NPA 2024-002) detailing the "Safety Management Systems (SMS) Regulatory Modernization Initiative." This initiative is not just about changing rules; it is about harmonizing Canadian operations with the global aviation stage. The primary objectives of this initiative are to align the Canadian Aviation Regulations (CARs) with ICAO's Annex 19, strengthen Canada’s reputation as a leader in SMS, improve the clarity of the CARs, and support the competitiveness of Canada’s aviation sector.









Image Sub-text: Safety Management is no longer just a concept—it is a measurable standard. Level 1 operators must ensure their risk assessment tools and physical pre-flight checks align with the new international baseline.


What This Means for Level 1 Complex Pilots


If you are operating under a Level 1 Complex RPOC, you are considered a sophisticated airspace user. Unlike basic operations, your certificate relies heavily on your ability to maintain a compliant, "living" manual. With the adoption of the Third Edition of Annex 19, Transport Canada is signaling that SMS is the standard.


Your Required Actions:


  • Audit Your RPOC Manuals: You must review your existing Safety Management System (SMS) manual to ensuring it aligns with the definitions and structures outlined in NPA 2024-002.

  • Verify Compliance: Ensure your hazard identification and occurrence reporting procedures meet the modernized standards.

  • Stay Informed: Read the Fact Sheet provided by TCCA (linked below) to understand exactly how these changes impact service providers.

Failure to align your manuals with these changes could result in non-compliance during a Transport Canada audit or a lapse in your RPOC validity.




Image Sub-text: Complex operations require rigorous documentation. Maintaining clear version control when updating your manuals is essential for audit trails and regulatory compliance.


IMPORTANT NOTE: FOR KR DRONEWORKS CLIENTS


For those of you who have purchased our generic Suite of RPOC Manuals, we have you covered.


We have completed a comprehensive review and updated our SMS Manual to fully reflect these new Transport Canada changes and the ICAO Annex 19 alignment.


  • How to get it: You can request an updated version of this manual for FREE.

  • Contact: Simply email us at kr.droneworks@gmail.com with your request.


We are committed to ensuring your documentation remains audit-ready without any extra cost to you.


Moving Forward


The regulatory landscape is shifting to support a more competitive and safe aviation sector in Canada. KR Droneworks will continue to monitor the implementation of these rules by Transport Canada. We will keep you advised of any further changes that may affect your RPOC documentation or operational requirements.


Fly safe, stay compliant, and keep your manuals up to date.


References & Resources

 
 
 

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