BVLOS Compliance Checklist 2026: Current Part 107 Waivers and the Proposed Part 108 Framework

Revised September 16, 2026. This checklist was substantively updated to separate current authority from proposal. As of bounded official checks through September 15, 2026, Part 108 remains a notice of proposed rulemaking — no final rule has been located, and a September 4, 2026 TSA notice still describes the FAA and TSA final rules as forthcoming. Your operating authority today is Part 107 plus whatever waiver, exemption, or other authorization you actually hold, under its specific conditions. This update also removed several earlier claims this page could not support, including a universal insurance dollar range, pilot type-rating and 6–12-month recurrent-training requirements, and a promised 90–120-day waiver timeline; it further corrects the airspace-authorization item (ATC authorization applies in the controlled airspace § 107.41 specifies, not universally) and tightens the DAA and transponder descriptions in the FAQ. Details are in the sections below.

Beyond Visual Line of Sight (BVLOS) operations represent the next frontier in commercial drone applications. From my experience leading eVTOL test programs and consulting on advanced UAS operations, I've developed this checklist to help operators prepare for BVLOS work under current Part 107 waivers while planning against the proposed Part 108 framework.

Use it for what it is: a planning and preparation tool aligned with the proposed FAA Part 108 framework and current waiver practice. It is not an authoritative statement of requirements — your actual waiver, exemption, or certificate conditions control, and you should verify current regulations before any operation.

Regulatory Transition Period

We're in a transitional period between Part 107 BVLOS waivers and the proposed Part 108 framework. Items below are labeled by which regime they belong to. Current-authority items reflect Part 107 and published FAA waiver practice; Part 108 items are planning against a proposal that could change before any final rule. Nothing in the proposal grants operating authority today, and nothing on this page substitutes for the conditions in your own authorization.

Regulatory Compliance Foundation

Part 107 BVLOS Waiver Items (current authority)

• Valid remote pilot certificate for the remote pilot in command (visual observers, when used, must meet the § 107.33 conditions; the regulation does not itself require a certificate for the VO role — but your specific waiver conditions may say otherwise, and they control)
• Aircraft registration current and properly marked
• Remote ID compliance verified and operational
• ATC airspace authorization obtained where your operating area requires it: § 107.41 requires authorization (LAANC or manual) for operations in the controlled airspace it specifies — Class B, C, or D, or within the lateral boundaries of the surface area of Class E designated for an airport. Operations elsewhere need no ATC authorization under § 107.41, though your waiver's own conditions control either way
• Waiver application submitted and approved (a waiver is the FAA's official document approving operations outside specific Part 107 limitations, such as § 107.31 visual line of sight)
• Insurance coverage meeting your operation's and clients' contractual requirements (see the insurance FAQ below — there is no universal FAA-mandated figure for Part 107 operations)
• NOTAMs published for operational area (if required by waiver)
• Letter of Agreement (LOA) with controlling ATC facility (if applicable)

Part 108 Preparatory Items (proposal — planning only)

• Understand the proposal's two authorization types: permits for lower-risk operations and certificates for higher-risk ones. Which path would fit your operation shapes everything else you prepare
• Training curriculum developed and documented for the roles your operation would actually use (the proposal's defined positions would not require FAA airman or remote pilot certificates; see the training FAQ below)
• Safety management system (SMS) framework established
• Maintenance program documentation completed
• Quality assurance program procedures written
• Environmental review posture understood for your intended operating areas
• Community engagement and stakeholder coordination documented

Aircraft and Systems Requirements

Aircraft Documentation

• Aircraft meets weight and performance specifications for intended operations
• Airworthiness documentation matched to your actual path: for current operations, whatever your waiver or exemption conditions require; for proposed Part 108 planning, note the proposal would use airworthiness acceptance based on industry consensus standards, not traditional FAA airworthiness certificates
• Aircraft flight manual and performance data available
• Weight and balance calculations current and within limits
• Aircraft configuration control documentation maintained
• Modification and alteration records up-to-date
• Serial number and registration marking clearly visible
• Aircraft logbooks and maintenance records current

Propulsion and Power Systems

• Battery health and capacity verification completed
• Backup power systems tested and operational
• Power management system calibrated
• Charging and storage procedures documented
• Low-power warning and automatic return-to-home configured

Detect and Avoid (DAA) Capability

DAA items below are planning considerations for your safety case, not a universal equipment mandate. What you must actually field is whatever your waiver, exemption, or (eventually) Part 108 authorization conditions require for your operation.

• DAA approach defined for your operation and documented in your safety case
• Sensor coverage analysis completed for operational area
• DAA system integration with flight control verified
• False alarm and missed detection rates documented
• Performance documented against the separation standard your authorization specifies
• System failure modes and procedures documented
• Regular DAA system validation testing scheduled
• Integration with air traffic control systems tested (where applicable)

Cooperative Detection (ADS-B In, Transponder)

• ADS-B In receiver installed and operational, if part of your safety case
• Transponder (if required by your authorization) installed and coded correctly
• Aircraft position reporting accuracy verified
• Traffic display system operational and calibrated
• Caution — ADS-B Out: under current 14 CFR § 107.53, no person may operate a small UAS with ADS-B Out equipment in transmit mode unless otherwise authorized by the Administrator. Do not add ADS-B Out transmission to your aircraft as a "safety extra" without that authorization

Non-Cooperative Detection (Radar, Optical)

• Ground-based or airborne radar system operational, if part of your safety case
• Optical detection systems (if used) calibrated
• Detection range and accuracy validated for operational environment
• Weather and environmental impact assessments completed

Communication and Navigation Systems

Communication Requirements

• Primary command and control link tested and verified
• Backup communication system operational
• Lost link procedures programmed and tested
• Radio frequencies coordinated with ATC (if required)
• Voice communication capability with ATC established (where applicable)
• Data link performance meets latency and reliability requirements
• Communication encryption and security protocols active
• Emergency communication procedures documented and tested

Navigation and Positioning

• GNSS/GPS primary navigation system operational
• Navigation accuracy meets operational requirements
• Alternative navigation capability available (if required)
• Navigation database current and validated
• Waypoint and route planning completed and verified
• Geofencing and virtual boundaries configured
• Navigation system integrity monitoring active

Operational Procedures and Planning

Pre-Flight Planning

• Weather briefing obtained and evaluated for entire route
• NOTAMs and TFRs reviewed for operational area
• Airspace analysis completed for entire flight path
• Risk assessment completed and mitigation strategies implemented
• Alternative landing sites identified and briefed
• Fuel/battery endurance calculated with reserves
• Load and performance calculations completed
• Mission timeline and critical decision points established

Route Planning and Analysis

• Primary route planned and programmed
• Alternative routes identified and programmed
• Obstacle analysis completed for all routes
• Minimum safe altitudes calculated
• Populated area analysis and overfly restrictions confirmed
• Emergency landing zone identification completed

Crew Resource Management

• Pilot-in-command qualifications and currency verified
• Visual observer(s) assigned and briefed (if used or required by your waiver)
• Ground crew roles and responsibilities assigned
• Communication protocols and phraseology briefed
• Emergency procedures reviewed with all crew members
• Decision-making authority clearly established
• Backup crew availability confirmed

Training and Qualifications

• All crew members meet the certificate and qualification conditions of your actual authorization
• Current Part 107 recency satisfied: under § 107.65, remote PIC privileges require completing qualifying training or testing within the previous 24 calendar months
• BVLOS-specific training completed and documented for your operation
• Emergency procedure training current
• Aircraft make/model-specific training completed and documented (the Part 108 proposal ties some role recency to experience on the same make and model — see the training FAQ)
• Crew resource management training current

Emergency Procedures and Contingency Planning

System Failure Procedures

• Lost link procedures documented and tested
• DAA system failure procedures established
• Communication failure protocols defined
• Navigation system failure procedures documented
• Power/propulsion failure emergency procedures established
• Automatic emergency descent/landing procedures configured
• Manual override capabilities verified
• Emergency termination procedures (if applicable) documented

Airspace and Traffic Management

• Air traffic conflict resolution procedures established
• Emergency descent and diversion procedures documented
• Coordination procedures with ATC during emergencies defined
• Manned aircraft encounter procedures established
• Emergency communication frequencies programmed
• Search and rescue coordination plan documented

Safety Management and Quality Assurance

Safety Management System (SMS)

• Safety policy and objectives documented
• Hazard identification and risk assessment process established
• Safety performance monitoring procedures implemented
• Safety reporting and investigation procedures documented
• Safety training program established
• Safety audit and review schedule maintained
• Safety communication and consultation procedures defined
• Continuous improvement processes implemented

Record Keeping and Documentation

• Flight operation records maintained per your authorization's requirements
• Maintenance logs and inspection records current
• Pilot and crew training records documented
• Incident and accident reporting procedures established
• Equipment modification and configuration control records maintained
• Operational data collection and analysis procedures implemented
• Regulatory correspondence and approvals filed
• Insurance and liability documentation current

Environmental and Community Considerations

Environmental Compliance

• Noise impact assessment completed
• Wildlife and bird strike risk assessment conducted
• Environmental protection measures implemented
• Weather and seasonal operational restrictions identified
• Visual intrusion and privacy impact assessment completed
• Cultural and historical site consideration documented
• Environmental monitoring and reporting procedures established

Community Relations and Coordination

• Local authority coordination and notification completed
• Public information and community engagement conducted
• Emergency services coordination established
• Property owner permissions obtained (where required)
• Media relations and communication plan developed
• Complaint handling procedures established
• Community feedback integration process implemented

Consulting Intake Paused

UAVHQ is not currently accepting new consulting clients. Existing commitments remain supported; select time-sensitive safety or regulatory inquiries may be reviewed as availability allows. The published resources on this site — including this checklist and the broker and counsel question worksheet — are the intended starting point in the meantime.

View Availability Status →

Frequently Asked Questions

What is BVLOS and why does it need special compliance?

Beyond Visual Line of Sight (BVLOS) operations allow drones to fly beyond the pilot's direct visual contact. What an operation must field, and how automated it must be, is set by its waiver or exemption conditions.

What are DAA systems and are they required for BVLOS?

Detect and Avoid (DAA) systems give a BVLOS operation the means to detect other aircraft and avoid them — through sensors, alerting, and procedures, with some implementations adding automated maneuvering. Current Part 107 does not mandate them as equipment; what an operation must field, and how automated it must be, is set by its waiver or exemption conditions. The proposed Part 108 takes a performance-based approach — including airworthiness acceptance against industry consensus standards — rather than prescribing a single universal equipment list, and it remains a proposal. Build the DAA case your authorization actually requires.

Can I conduct BVLOS operations under Part 107?

BVLOS operations under Part 107 require an operational waiver from the FAA — an official document approving operations outside specific limitations such as § 107.31. Applications require documentation and safety analysis. The FAA says it does its best to review and approve or disapprove waiver requests within 90 days of submission, with processing times varying by complexity and completeness; that is a stated target, not a guarantee.

What training is required for BVLOS operations?

For current operations: whatever your Part 107 certificate, recency (§ 107.65's 24-calendar-month cycle), and specific waiver conditions require, plus the operation-specific training your safety case commits you to. Under the proposed Part 108, the defined operating roles would not require FAA airman or remote pilot certificates; the proposal instead sets role-specific requirements — for example, proposed § 108.310(f) would require a flight coordinator to have at least 5 hours of operating experience on the same make and model within the preceding 12 calendar months. Earlier versions of this page claimed Part 108 would require pilot type ratings and recurrent training every 6–12 months; the proposal does not support those universal claims and they have been removed.

How long is this checklist valid?

This checklist was revised on September 16, 2026 against current Part 107 text, published FAA waiver guidance, and the Part 108 proposal, using source evidence checked through September 15, 2026. Regulations evolve; always verify current requirements before conducting operations.

Do I need special insurance for BVLOS operations?

There is no universal FAA-mandated coverage figure for Part 107 operations, and this page previously cited a market-wide dollar range it could not support; that claim has been removed. What actually drives your coverage: your clients' contractual requirements, your risk exposure, and — if you operate as an air carrier, for example in package delivery — separate DOT air-carrier obligations including economic authority and liability insurance, which the Part 108 NPRM itself notes would continue to apply (footnote 98). Work the numbers with your broker and counsel against your specific operation; our BVLOS insurance operator checks article and broker question worksheet are built for exactly that conversation.

What's the difference between cooperative and non-cooperative DAA?

Cooperative DAA relies on signals other aircraft transmit — ADS-B broadcasts carry position, while conventional transponder replies convey identity and altitude to interrogating systems rather than broadcasting coordinates. Non-cooperative DAA uses sensors like radar or optical systems to detect aircraft that may not be transmitting anything. Note the distinction between ADS-B In (receiving, generally usable) and ADS-B Out (transmitting, restricted for small UAS under § 107.53 absent authorization). Which capabilities you need is a function of your operating environment and your approved safety case.

Using This Checklist Effectively

This checklist is designed to be both comprehensive and practical. Use it as follows:

• Planning Phase: Review all sections during initial operation planning
• Preparation: Work through each checklist item systematically
• Pre-Flight: Use relevant sections for pre-flight verification
• Post-Flight: Review safety and documentation requirements
• Continuous Improvement: Update based on lessons learned and regulatory changes

Remember that compliance is not just about checking boxes—it's about implementing comprehensive safety practices that enable advanced operations while protecting both airspace users and communities on the ground.

As regulations continue to evolve, particularly if and when a final Part 108 publishes, staying current with requirements and best practices is essential for successful BVLOS operations.

Professional Consultation Recommended

BVLOS operations involve complex regulatory, technical, and safety considerations. This checklist provides a planning framework, but consultation with experienced aviation professionals and your own counsel is recommended for specific operations planning and regulatory compliance verification. Note that UAVHQ's own consulting intake is currently paused, as stated above.

Primary Sources

• 14 CFR Part 107 (eCFR, current text) — §§ 107.31, 107.33, 107.53, 107.65
• FAA, Part 107 Waivers (waiver definition and processing target)
• FAA, Fact Sheet: Normalizing UAS Beyond Visual Line of Sight Operations (proposed Part 108)
• FAA, Part 108 NPRM, 90 FR 38212, August 7, 2025 (GovInfo PDF) — insurance caveat at footnote 98 (90 FR 38267); proposed § 108.310(f) at 90 FR 38371
• TSA, Notice on UAS security roundtables, September 4, 2026 (GovInfo PDF)