Minimum age and remote pilot competency
Two distinct requirements bear on the person at the controls: an age and a proven competency. They do not move together (the age can be lowered by a State, the competency cannot) and the examination exploits precisely that gap.
Key points
- The minimum age for a remote pilot in the ‘open’ category is 16 (Art. 9(1)). A Member State may lower it by up to 4 years in the ‘open’ category, and by up to 2 years in the ‘specific’ category, following a risk-based approach (Art. 9(3)).
- A pilot flying thanks to a national lowering is allowed to operate only on the territory of the State that decided it (Art. 9(4)). That permission does not cross the border.
- Three cases need no minimum age (Art. 9(2)): operating in A1 with a class C0 UAS that is a toy within the meaning of Directive 2009/48/EC, a privately built UAS of less than 250 g, and flying under the direct supervision of a remote pilot who himself meets the requirements.
- A1/A3 competency: an online training course, then an online theoretical knowledge examination of 40 multiple-choice questions spread over nine subjects, passed with at least 75 % of the overall marks (UAS.OPEN.020(4)(b)). The regulation sets NO duration for the paper.
- A2 competency: three steps that the text imposes in the order indicated (UAS.OPEN.030(2)): first pass the A1/A3 online theoretical examination, then complete a self-practical training in the operating conditions of A3, then declare that self-practical training and pass the additional theoretical examination of at least 30 questions, at 75 % or more.
- The remote pilot carries his proof of competency WHILE operating (UAS.OPEN.060(1)(a)), except for the aircraft referred to in points (5)(a), (b) and (c) of UAS.OPEN.020, all of which stay under 250 g.
- The operator, for his part, must ensure that his remote pilots do have the competency of the intended subcategory (UAS.OPEN.050(4)). The two obligations coexist and do not replace one another.
The trap. A2 does not replace A1/A3: it is added to it, and the order of the three steps is part of the rule. Another frequent trap, the duration of the examination: no European stopwatch exists. Where there is one, it comes from the national authority and varies from country to country.
Source
Implementing Regulation (EU) 2019/947 (CELEX 02019R0947, consolidated on 01/05/2025), art. 8 and art. 9, paragraph 1 to paragraph 4, and Annex Part A, points UAS.OPEN.020(4)(b), UAS.OPEN.030(2), UAS.OPEN.050(4) and UAS.OPEN.060(1)(a)