Murzilli Consulting’s regulatory newsletter for the latest in UAS, eVTOL and AAM/IAM updates.
EASA has introduced new Acceptable Means of Compliance (AMC) and Guidance Material (GM) to support the safe and harmonised integration of manned VTOL-capable aircraft (VCA) within Europe’s airspace. This marks a pivotal step in advancing the regulatory foundations for Innovative Air Mobility (IAM) across the continent.
Key highlights include:
🔸 Air Operations (Air OPS): Amendments to Regulation (EU) No 965/2012 and the creation of Part-IAM provide operators with clear guidance on preflight planning, vertiport access, diversion procedures, and fuel/energy management tailored for VCA operations.
🔸 Flight Crew Licensing (FCL): AMC for Article 4f of Regulation (EU) No 1178/2011 introduces a flexible approach to type rating and theoretical knowledge requirements for novel aircraft architectures.
🔸 Standardised European Rules of the Air (SERA): Updates include terminology changes (e.g. “fuel/energy”) to reflect electric propulsion systems and ensure VCA integration in ATM environments.
The AMC and GM are published under EASA Executive Director Decisions 2025/010/R, 2025/011/R, and 2025/012/R, developed within Rulemaking Task RMT.0230 (Subtask C#3). This initiative lays the groundwork for the safe, early adoption of IAM technologies by authorities, operators, and European citizens.
The UK Civil Aviation Authority (CAA) has published CAP3139, a consolidated study evaluating the potential of Electronic Conspicuity (EC) technologies to support the Airspace Modernisation Strategy and the Future of Flight programme. The report, produced by Baringa, Murzilli Consulting, and QinetiQ, draws on five interlinked workstreams conducted throughout 2024.
Key insights include:
🔸 Operational Applications: EC is positioned as a key enabler for integrating diverse airspace users; including drones, general aviation, and emerging urban air mobility within a modernised UK airspace framework.
🔸 Technology Landscape & Maturity: The study identifies a fragmented EC environment with varied capabilities, limited interoperability, and no universal standard. Innovations such as digital ID, ADS-B, and detect-and-avoid systems are progressing, but technical harmonisation remains critical.
🔸 Safety & Surveillance Integration: EC is not a silver bullet for deconfliction. The report stresses that it must complement a layered approach to surveillance and traffic management, especially in mixed-use and low-level airspace.
🔸 Adoption Barriers: Key challenges include equipment costs, inconsistent standards, limited regulatory mandates and unclear value propositions for some users. The study recommends targeted policy interventions, including regulatory incentives and stakeholder engagement, to stimulate uptake.
🔸 Strategic Recommendations: CAP3139 sets out a roadmap for a future EC strategy, calling for performance-based requirements, cross-sector trials (including federated airspace models) and alignment with European and global regulatory frameworks.
This work provides a robust evidence base to guide the CAA’s ongoing efforts in shaping an inclusive, efficient and future-proof UK airspace ecosystem.
The UK CAA is also consulting on its draft Initial Technical Concept of Operations (ConOps) for EC, outlining proposed technical, operational, and equipage requirements to support the safe integration of all airspace users, including uncrewed systems, into the UK’s evolving airspace structure.
Key points include:
🔸 Nine Draft Policy Positions: The ConOps sets out nine foundational positions covering device standards, minimum technical specifications, signal integrity, interoperability and equipage expectations. These are designed to enable a phased approach to EC deployment from initial concept testing through to routine use by 2027.
🔸 Use Case Integration: EC is positioned as a tactical and strategic enabler for mixed-use airspace, particularly for UAS, general aviation and emerging aviation segments. The concept supports both detect-and-avoid functionality and strategic pre-flight planning.
🔸 Stakeholder Participation: Input is welcomed from a wide range of stakeholders including GA pilots, drone operators, ANSPs, aerodrome managers, manufacturers, regulators and policy experts. The CAA encourages responses to the areas most relevant to each participant’s domain of expertise.
🔸 Call for Evidence on Mandate: The consultation also includes an early-stage Call for Evidence to inform potential future EC mandates. This is being considered jointly by the CAA and the Department for Transport.
🔸 Modernisation Alignment: The ConOps aligns with the UK’s Airspace Modernisation Strategy and broader Future of Flight ambitions, reinforcing the role of EC in enabling scalable, inclusive and safety-enhanced airspace operations.
The consultation is open until 6 October.
On 14 July, at the 2nd Meeting of Asia-Pacific Regulators on AAM, authorities from 24 Asia-Pacific States launched the region’s first jointly developed Reference Materials for Regulators. Led by the Civil Aviation Authority of Singapore, the initiative marks a significant regulatory milestone, designed to support the safe introduction of air taxis and drones, while also being submitted to ICAO for global reference.
Key highlights include:
🔸 Comprehensive Regulatory Framework: The Reference Materials provide practical guidance for regulators on the commercial introduction of AAM technologies. For eVTOL aircraft, six areas are addressed: certification and validation, entry into service, inter-agency coordination, economic regulation, capability development and social acceptance. For UAS, the focus is on BVLOS implementation and operator training.
🔸 Enabling Innovation and Reducing Risk: Developed with industry input, the framework aims to reduce regulatory uncertainty and investment risk while supporting early-stage deployment and adoption of AAM and drone services across the region.
🔸 Feedback-Driven and Consultative: Following closed and public consultations, which drew feedback from 48 organisations and nearly 600 submissions, the materials were refined to include structured safety targets, cross-border aircraft acceptance and a catalogue of globally recognised compliance standards.
🔸 Forward-Looking and Continuously Updated: The materials are intended as a living document, with future iterations expected to address hybrid propulsion systems, remotely piloted aircraft and autonomous operations.
🔸 Regional Collaboration in Action: The meeting, attended by 20 regulators and 21 AAM companies, reinforced the importance of public-private coordination to unlock the economic, social and environmental benefits of low-altitude aviation. Use cases discussed included eVTOL services for inter-island transport and drones for productivity and logistics enhancement.
EASA has published new means of compliance (MoC) to support UAS operations under the Specific Assurance and Integrity Level (SAIL) III classification. These MoCs, developed in collaboration with the UAS Technical Body’s Airworthiness Task Force, represent a key milestone in advancing the technical enablers for operations under the Specific Operations Risk Assessment (SORA) framework.
Key points include:
🔸 Support for Declarative SAIL III Operations: The MoC to OSO #2 and OSO #8, now open for consultation until 12 September, address essential requirements for UAS not subject to full certification under Regulation (EU) 748/2012 (Part 21). They provide clarity on organisational structures, flight manual content, structural integrity, configuration control and the management of design changes.
🔸 Guidance on Airworthiness that Does Not Require Compliance with Part 21: These MoCs fill a critical regulatory gap for mid-level risk operations that don’t require full design certification, enabling operators to proceed under a declaration-based model rather than seeking full authority review.
🔸 Design Verification Path for SAIL IV: For higher-risk SAIL IV operations, EASA has also published a reference table to support applicants seeking Design Verification Reports (DVR) under the Special Condition Light UAS. The table provides a mapping between regulatory requirements, recognised standards and existing MoCs; serving as a practical tool for demonstrating compliance.
🔸 Living Framework: The DVR reference table is a dynamic document, continuously updated to reflect new developments, standards and operational learnings as the UAS sector matures.
Together, these developments strengthen Europe’s UAS regulatory architecture by offering a scalable and proportionate approach to airworthiness, tailored to the diverse risk profiles of modern drone operations.
EASA has released its 2025 Annual Safety Recommendations Review, consolidating insights from 40 recommendations linked to 26 significant occurrences in 2024. Over half related to procedures and regulations, reinforcing the importance of consistent safety oversight.
While only one recommendation specifically addressed UAS, the report reflects EASA’s broader safety role, including 97 formal responses and active support to investigations in Japan, Brazil, Serbia, and Lithuania.
Key themes include certification updates, operational safety, maintenance, fire safety and infrastructure oversight.
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See you in the skies and beyond,
Team Murzilli
Quality Policy of Murzilli Consulting - Spanish office
The activities developed by M&K UAS & SPACE SPAIN SL according to the requirements expressed in the International ISO 9001: 2015 standard are:
Consultancy and training services on Uncrewed Aerial Systems (Drones) and Flight Procedure Design (FPD).
The main points of action issued by the management in the quality policy statement issued by the management are:
Our quality commitment to all the interested parties (customer, suppliers, stakeholders, employees, competence and public administration) leads us to provide reliable and effective products and services. These product and services are provided worldwide in compliance with the regulatory requirements and in full alignment with our company values.
The Quality culture and mindset is promoted through proper training to each member of M&K UAS & SAPCE SPAIN SL so that everybody has full awareness of the quality importance.
Management makes this policy accessible and available to its customers, its employees, suppliers and the general public
The Policy is kept up-to-date through periodic reviews, coinciding with the management review of the system, in order to take into account changes in environmental conditions and the information received. In this sense, the management provides and will provide all the human, technical and economic resources needed to achieve the objectives and targets established scheduled and periodically.
07/01/2025. Ed. 1.
Chief Executive Office
Quality Policy of Murzilli Consulting - German office
The activities developed by M&K Germany GmbH according to the requirements expressed in the International ISO 9001: 2015 standard are:
Consultancy on Uncrewed Aerial Systems (Drones) and other related areas in a wide range of services, including: "Unmanned aerial systems (drone) consultancy".
The main points of action issued by the management in the quality policy statement issued by the management are:
Our quality commitment to all the interested parties (customer, suppliers, stakeholders, employees, competence and public administration) leads us to provide reliable and effective products and services. These product and services are provided worldwide in compliance with the regulatory requirements and in full alignment with our company values.
The Quality culture and mindset is promoted through proper training to each member of M&K Germany GmbH so that everybody has full awareness of the quality importance.
Management makes this policy accessible and available to its customers, its employees, suppliers and the general public
The Policy is kept up-to-date through periodic reviews, coinciding with the management review of the system, in order to take into account changes in environmental conditions and the information received. In this sense, the management provides and will provide all the human, technical and economic resources needed to achieve the objectives and targets established scheduled and periodically
2st Ed.; 16/02/2026
Chef Executive Office
