In flight: keeping control, losing the link
The ‘open’ category does not prohibit automatic modes. It prohibits putting yourself in a situation where you can no longer take back control. The whole subject rests on that distinction, and lost link is its limiting case.
Key points
- Article 2(17) defines an autonomous operation as one during which the remote pilot is not able to intervene. GM1 UAS.OPEN.060(2)(d) draws the consequence: autonomous operations are not allowed in the ‘open’ category.
- The remote pilot must have the ability to maintain control of the unmanned aircraft at any moment, except in the case of a lost link or of a free-flight aircraft. A waypoint mission therefore remains possible: walking away while it runs does not.
- AMC1 UAS.OPEN.060(2)(d) states three requirements: stay focused on the operation, do not fly while driving a moving vehicle, and operate only one aircraft at a time.
- Flying from a land vehicle or a boat driven by someone else is accepted, provided the speed stays low enough to maintain visual line of sight, control at all times, situational awareness and orientation. No speed is quantified: it is those four requirements that determine it.
- Handing control over to a second control unit during the flight is ruled out in the ‘open’ category (GM1 UAS.OPEN.050(3)). The hard-law anchors are point UAS.OPEN.050(3), which requires a designated remote pilot for each flight, and point UAS.OPEN.060(2)(d).
- The recovery function after a loss of the command and control link is checked BEFORE the flight: AMC1 UAS.OPEN.060(1)(d) asks you to make sure it allows a safe recovery for the intended operation, and to set its parameters where they are programmable.
- The textbook case is the return height left at its default value, lower than the obstacles on the site: the aircraft climbs, heads for the take-off point and hits a tree or a building. The automatic return is a safety net only if it is configured.
- Class C1, C2 and C3 aircraft must give the pilot a clear warning when the battery reaches a low level, with enough margin to land safely. It is an ALERT leaving time to act, not an automatic manoeuvre deciding in his place.
The trap. The buddy-box set-up from model flying, with two paired transmitters, is the recurring trap: it stays outside the ‘open’ category. One flight, one designated remote pilot, one control unit.
Source
Implementing Regulation (EU) 2019/947 (CELEX 02019R0947, consolidated on 01/05/2025), art. 2, point 17), and Annex Part A, points UAS.OPEN.050(3), UAS.OPEN.060(2)(b) and UAS.OPEN.060(2)(d); AMC1 UAS.OPEN.060(1)(d), AMC1 UAS.OPEN.060(2)(d) and GM1 UAS.OPEN.060(2)(d) (ED Decision 2019/021/R); GM1 UAS.OPEN.050(3) (ED Decision 2022/002/R); Delegated Regulation (EU) 2019/945 (CELEX 02019R0945, consolidated on 24/06/2025), Annex, Parts 2, 3 and 4