Social icon Social icon Social icon

Key Personnel

Understanding Who Holds Responsibility in a Professional RPAS Operation

Responsibility in a ReOC Operation Sits Across Three Levels

A Remote Operator Certificate (ReOC) is built around defined responsibility and operational control.

This means a professional RPAS operation is not just about aircraft and pilots. It also depends on clearly identified people who are responsible for corporate oversight, operational control, maintenance control, and specialist advice where required.

The most common mistake CRP candidates make is treating everyone involved in an operation as “key personnel.” In reality, responsibility inside a ReOC is organised across three distinct levels, and the difference between them matters for compliance:

  • Key personnel — the CEO, Chief Remote Pilot and Maintenance Controller. These positions must be filled at all times.
  • Nominated personnel — Type Specialists, where the operation requires them.
  • Other operational roles — Senior Remote Pilots, Remote Pilots, camera operators, spotters, observers and ground crew.

Each level carries different obligations for who must fill it, whether the ReOC can operate without it, and whether the position must appear in the Operations Manual. Understanding those differences is central to a strong CRP assessment.

Level One: Key Personnel

The key personnel positions are:

  • Chief Executive Officer (CEO)
  • Chief Remote Pilot (CRP)
  • Maintenance Controller (MC)

These three positions must be filled by individuals appointed by the operator, and they form the core management structure of the ReOC.

A ReOC cannot be used if one or more of the key personnel positions — CEO, CRP or MC — is vacant. If any of these positions is unfilled, the operation cannot be conducted. This is the defining feature of a key personnel position: the certificate depends on it being occupied.

These are the positions that must be addressed in the Operations Manual and that define how the ReOC is managed.

Level Two: Nominated Personnel (Type Specialist)

A Type Specialist is nominated personnel, not key personnel. This is an important distinction, and it changes both what happens when the position is vacant and how changes to it are managed.

A Type Specialist is used when the operator conducts operations involving a type that requires specialist knowledge beyond that of the CRP. The Type Specialist is a Remote Pilot who holds a superior RePL rating compared to the CRP for the type concerned, and who provides advice to the CRP on aspects of flight operations relating to that specialist type.

The way a Type Specialist affects the ReOC is different from a key personnel position:

  • Type Specialists must be listed in the Operations Manual.
  • The ReOC can still function even if a Type Specialist position is vacant. The operation simply cannot conduct activities involving any type for which the CRP does not personally hold the required rating.
  • If a Type Specialist position becomes vacant, or the person occupying the role changes, CASA must be notified.

In other words, a vacant Type Specialist position does not ground the whole operation the way a vacant key personnel position does. It only restricts the operation to types the CRP is rated to manage.

Level Three: Other Operational Roles

The operation also relies on a range of other roles, including Senior Remote Pilots, Remote Pilots, camera operators, spotters, observers and ground crew. These roles are important to the conduct of RPAS activities, but they sit at a different level again.

People filling these other operational roles do not need to be listed in the Operations Manual.

These roles include:

  • Senior Remote Pilot (SRP): delegated authority for certain operational matters
  • Remote Pilot (RP): direct responsibility for the safe conduct of the flight
  • Camera operators, spotters, observers and other crew: support personnel who must follow the operator’s procedures and lawful directions

They should be defined operationally, but they are not part of the personnel structure that must be named in the Operations Manual, and they should not be confused with the key personnel or nominated personnel positions above.

Assessment of Key Personnel

For ReOC operations using RPA with an MTOW under 150 kg, only the Chief Remote Pilot is assessed.

That is an important distinction for candidates preparing for a CRP assessment. While the CEO and MC have clearly defined responsibilities within the operation, the role that is formally assessed for these operations is the CRP.

For ReOCs operating an RPA over 150 kg MTOW, the assessed position is not limited to the CRP. In that case, the CEO, Chief Remote Pilot and Maintenance Controller are all assessed.

This is one of the reasons the CRP assessment focuses so strongly on operational judgement, regulatory knowledge, oversight of pilots and operations, and a practical understanding of how a ReOC functions.

Responsibilities of Key and Nominated Personnel

Each key personnel position, and the Type Specialist, have defined responsibilities within the operation. These responsibilities are set out below.

Chief Executive Officer (CEO)

The CEO holds ultimate responsibility for the safety and corporate compliance of the RPAS operation.

The RPAS Operations Manual states that the CEO is responsible for the safety and corporate compliance of RPA operations and must ensure that operations are conducted in accordance with the ReOC and civil aviation legislation. It also notes the CEO must ensure the organisation is suitably structured, adequately financed and properly resourced.

In practical terms, the CEO should ensure:

  • the operation is properly resourced
  • suitably qualified personnel are in place
  • the management structure is appropriate
  • safety performance is reviewed
  • approved procedures are maintained and improved
  • CASA is notified of relevant changes to the operator

The CEO is not there to replace the CRP or the MC. The CEO’s role is to ensure the organisation is structured and supported so that those positions can function effectively.

Chief Remote Pilot (CRP)

The Chief Remote Pilot is the person responsible for safely managing the RPAS operation.

The RPAS Operations Manual makes the CRP responsible for ensuring that operations are conducted in accordance with the ReOC and relevant civil aviation legislation, and for ensuring that pilots and crew are suitably qualified, experienced, and monitored. It also identifies responsibilities such as internal audit, corrective action, fatigue oversight and ensuring pilots and crew have access to the manuals and documents necessary to operate safely.

The CRP is responsible for:

  • operational control of RPAS activities
  • ensuring operations are conducted lawfully and safely
  • overseeing pilot and crew competency
  • monitoring standards and compliance
  • reviewing operational issues and taking corrective action
  • ensuring operational documents are available and used
  • advising the CEO on operational matters relevant to safety and compliance

For operators using RPA with an MTOW under 150 kg, this is the only key position formally assessed. Candidates preparing for a CRP assessment should therefore be able to explain not only what the CRP does, but how the role functions in practice across planning, approval, supervision and continuous improvement.

Maintenance Controller (MC)

The Maintenance Controller is responsible for ensuring RPAS are correctly maintained and serviceable.

The Operations Manual states that the MC controls scheduled and unscheduled maintenance, maintains records of those authorised to perform maintenance, develops and monitors maintenance standards, records defects and unserviceability, and ensures equipment essential to the operation of each aircraft is serviceable before release to service.

The MC should ensure:

  • maintenance is controlled properly
  • defects and unserviceability are tracked
  • maintenance standards are documented and applied
  • only appropriately trained personnel perform maintenance
  • aircraft are serviceable before operations commence
  • defect trends and component failures are monitored

The MC plays a critical role in maintaining airworthiness and operational reliability, but for RPA under 150 kg MTOW the MC is not the assessed position. It remains, however, a key management function that must be defined in the Operations Manual.

Type Specialist

A Type Specialist is used when the operator conducts operations involving a type that requires specialist knowledge beyond that of the CRP. As noted above, a Type Specialist is nominated personnel rather than key personnel.

A Type Specialist is a Remote Pilot with a superior RePL rating compared to the CRP for the type concerned, who provides advice to the CRP on aspects of flight operations relating to that specialist type. A Type Specialist may assist with planning within type restrictions, countersign flight authorisations for specified types, support internal instruction, and provide technical information relevant to the aircraft type.

The role of the Type Specialist is to:

  • advise the CRP on specialist-type operations
  • help ensure operations are planned within type limitations
  • support technical and operational understanding of the aircraft type
  • assist with internal familiarisation and induction for that type

Type Specialists must be listed in the Operations Manual. If a Type Specialist position becomes vacant, or the person filling it changes, CASA must be notified. A vacancy does not stop the ReOC from operating; it simply means the operation cannot conduct activities involving any type for which the CRP does not hold the relevant rating.

Even where a Type Specialist is appointed, all broader operational oversight remains with the CRP. The Type Specialist supports operations within a defined specialist area; the CRP still retains overall operational responsibility.

Why This Matters for CRP Candidates

Many CRP candidates mistakenly think “key personnel” simply means everyone involved in the operation.

It does not.

For CRP assessment preparation, you should clearly understand:

  • which positions are key personnel (CEO, CRP and MC) and why a vacancy in any of them means the ReOC cannot be used
  • that a Type Specialist is nominated personnel — listed in the Operations Manual, notifiable to CASA on change, but not a position whose vacancy grounds the whole operation
  • that other operational roles do not need to be listed in the Operations Manual at all
  • which position is actually assessed
  • how the CRP interacts with the CEO, MC and any Type Specialist

This is particularly important because the CRP must operate within a management structure rather than in isolation.

A Practical Way to Remember It

For most ReOC operators, the structure can be understood as three levels:

Key personnel — must be filled or the ReOC cannot be used:

  • CEO = corporate accountability
  • CRP = operational control
  • MC = maintenance control

Nominated personnel — listed in the Operations Manual, CASA notified on change:

  • Type Specialist = specialist technical/operational advice where required (a vacancy only limits which types can be flown)

Other operational roles — not required in the Operations Manual:

  • Senior Remote Pilots, Remote Pilots, camera operators, spotters, observers and ground crew support the operation but do not form part of the named management structure.

How Uncrewed Approvals Can Help

Uncrewed Approvals provides resources to help candidates prepare for the CRP assessment, including study resources and the CRP Prep Exam available through the Learning Management System.

If you are preparing for a Chief Remote Pilot assessment, you should be comfortable explaining:

  • the role of each key person
  • where responsibility sits across the three levels
  • how those roles interact inside a ReOC operation
  • why the CRP remains the central assessed position for operations using RPA under 150 kg MTOW

Frequently Asked Questions

Who are the key personnel in a ReOC operation?

The key personnel are the CEO, Chief Remote Pilot and Maintenance Controller. These three positions must be filled and must be addressed in the Operations Manual. A Type Specialist, where required, is nominated personnel rather than key personnel.

Is a Type Specialist a key personnel position?

No. A Type Specialist is nominated personnel. Type Specialists must be listed in the Operations Manual and CASA must be notified if the position becomes vacant or the person changes, but the ReOC can still operate without a Type Specialist — it simply cannot conduct operations involving any type the CRP is not rated for.

What happens if a key personnel position is vacant?

The ReOC cannot be used. If the CEO, CRP or MC position is vacant, operations cannot be conducted until the position is filled.

Do other operational roles need to be listed in the Operations Manual?

No. People filling other operational roles — such as Senior Remote Pilots, Remote Pilots, camera operators, spotters and observers — do not need to be listed in the Operations Manual. These roles should be defined operationally but are not part of the named personnel structure.

Is the Senior Remote Pilot a key personnel position?

No. A Senior Remote Pilot may hold delegated operational authority, but it is not one of the key personnel positions, and it does not need to be listed in the Operations Manual.

Which key personnel position is assessed for operations under 150 kg MTOW?

Only the Chief Remote Pilot is assessed.

Does a Type Specialist replace the CRP?

No. A Type Specialist advises on specialist type operations, but the CRP remains responsible for overall operational oversight.

Drone in flight

Build a Clear Understanding of Operational Responsibility

A strong CRP candidate understands not just the rules, but also the structure of responsibility inside a ReOC operation.
That understanding is central to safe, compliant and scalable operations.