Murzilli Consulting’s regulatory newsletter brings you the latest UAS, eVTOL and AAM/IAM regulatory updates from August and September 2026. This edition covers developments in UAS occurrence reporting, Higher Airspace Operations, operational authorisation, airspace management and UAS security across Europe and the UK.
The European Commission has published Commission Implementing Regulation (EU) 2026/1821, amending the framework for occurrences in civil aviation that are subject to mandatory reporting. The regulation introduces a dedicated set of reporting requirements for Unmanned Aircraft Systems (UAS) and updates the framework to include specific U-space related occurrences. It was published in the Official Journal of the European Union on 28 July 2026 and entered into force on 17 August 2026.
Key elements:
🔸 A new dedicated annex establishes occurrences related to the operation of UAS that are subject to mandatory reporting.
🔸 The reporting requirements apply to UAS operations for which a certificate or declaration for design is required under the EU regulatory framework.
🔸 Specific U-space occurrences must be reported by remote pilots and UAS operators conducting operations in U-space airspace.
🔸 Reportable U-space occurrences include penetration into designated U-space without the required active e-conspicuity device, significant malfunctions affecting e-conspicuity systems and close encounters with unmanned aircraft.
🔸 The regulation also introduces changes relating to information security occurrences, including abnormal system behaviour resulting from incidents such as compromised information, malware or distributed denial of service attacks.
The update establishes more specific reporting requirements for safety occurrences involving UAS and U-space operations. This supports the collection of safety information as increasingly complex unmanned operations become integrated into the European aviation system.

AESA - Agencia Estatal de Seguridad Aérea, in collaboration with Spanish air navigation service provider ENAIRE , has published a new guide for the processing of applications for Higher Airspace Operations (HAO) with unmanned platforms. Developed with input from the AESA Working Group for HAO, to which Murzilli Consulting’s Chief Regulatory Officer, Juan José Sola, actively contributed, the guidance is intended for operators seeking to conduct high altitude civil operations with High Altitude Platform Systems (HAPS) in the Specific category.
Key elements:
🔸 The guide provides guidance for operators preparing and submitting applications for HAO involving unmanned HAPS platforms.
🔸 It sets out the main information and documentation that should accompany an application for operational authorisation.
🔸 The guidance outlines the safety assessment considerations that operators should address when preparing their applications.
🔸 It describes the airspace coordination processes that may be required depending on the characteristics and risk level of an operation.
🔸 The guidance considers coordination with air navigation service providers where operations require specific assessment of their interaction with other airspace users.
The publication provides operators with a clearer process for preparing HAO applications in Spain and supports the integration of unmanned HAPS operations into the existing aviation system. It also provides a defined process for preparing and submitting applications for operations at higher altitudes as the HAO sector continues to develop.

The UK Civil Aviation Authority (CAA) has updated its Airspace Change Process, following changes to UK Government policy set out in the Air Navigation Directions and Air Navigation Guidance. The revised CAP1616 process will come into effect on 1 October 2026 and introduces changes to how airspace changes are proposed, assessed and approved.
Key elements:
🔸 The revised process introduces a more streamlined approach for lower impact airspace changes.
🔸 The changes are intended to reduce regulatory burden while maintaining appropriate safety oversight.
🔸 The updated process supports the UK’s wider Airspace Modernisation Strategy, including the development and integration of new types of airspace users.
🔸 Consultation remains part of the process, with affected communities continuing to have opportunities to provide feedback on relevant airspace changes.
🔸 The revised CAP1616 process will apply from 1 October 2026.
The update changes how airspace changes will be managed in the UK and is relevant to the development of aviation operations that depend on access to and integration within UK airspace. For UAS and emerging aviation stakeholders, the revised process provides an updated framework for how changes to the airspace environment will be assessed and approved.

The UK Civil Aviation Authority (CAA) has decided not to proceed with changes to the Acceptable Means of Compliance (AMC) and Guidance Material (GM) for UK SORA that were due to enter into force on 1 October 2026. The decision follows further industry feedback on the changes introduced through ORS9 Decision No. 60 and wider work to improve the UK SORA framework.
Key elements:
🔸 The AMC and GM changes scheduled to enter into force on 1 October 2026 will not be implemented.
🔸 ORS9 Decision No. 60 has been revoked and superseded by ORS9 Decision No. 61.
🔸 The versions of the AMC and GM that were in force immediately before 3 July 2026 will continue to apply.
🔸 The decision affects the regulatory material used to support UK SORA applications for operations in the Specific Category.
🔸 The CAA intends to combine future changes into a single UK SORA update, allowing further improvements and industry feedback to be incorporated.
The decision provides clarity for operators preparing UK SORA applications by confirming which AMC and GM remain applicable. It also indicates that future changes to the UK SORA framework are intended to be consolidated rather than introduced through successive updates.

EASA - European Union Aviation Safety Agency has published Opinion No 06/2026, proposing amendments to Regulations (EU) 2019/947 and 2019/945 concerning the security of UAS operations. The Opinion sets out proposed changes to operator registration, remote identification and UAS geographical zones as part of the wider development of the EU regulatory framework for unmanned aircraft.
Key elements:
🔸 Member States would be required to verify the identity of UAS operators as part of the registration process.
🔸 The proposed amendments would lower the threshold for mandatory registration and direct remote identification from 250 g to 100 g.
🔸 The rules concerning UAS geographical zones would be updated to improve the consistency and accessibility of information provided to operators.
🔸 Member States would retain the ability to establish UAS geographical zones based on identified risks and local conditions.
🔸 The proposals would introduce specific provisions for UAS operated within model aircraft clubs and associations.
The proposed amendments would introduce additional requirements concerning operator identification, remote identification and UAS geographical zones. As Opinion No 06/2026 is an EASA Opinion rather than an adopted amendment, the proposed changes do not yet apply and would need to progress through the EU regulatory process before any of the proposed changes become applicable.

As regulatory frameworks continue to develop across Europe and the UK, keeping track of changes to operational requirements, airspace processes and UAS security remains important for operators and other stakeholders across the sector.
Did we miss an important regulatory development? Write to us and we will consider it for our next edition.
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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:
Consulting and advice on Unmanned Aerial Systems (Drones) and other related areas in a wide range of related services.
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
3rd Ed.; 15/04/2026
Chef Executive Office