Your ReOC and your documented practices and procedures describe your operation as CASA approved it. When that operation changes, Part 101 draws a hard line between two kinds of change:
Get that line wrong in the upward direction – make a significant change without approval – and you’ve breached the CASR 101 and the Manual of Standards. Get it wrong in the other direction and you bury CASA in notifications you didn’t owe them. This page translates the rules in plain English so you can tell the difference.
Who this applies to: certified RPA operators – ReOC holders, including RePL training organisations. If you operate excluded-category RPA under registration only (no ReOC), the significant-change regime doesn’t apply to you; you simply keep your myCASA details current within 21 days of any change. See the note at the end.
Under section 10.17 of the Part 101 MOS, a certified operator must tell CASA in writing about any change to the information CASA holds for your certification. How and when you tell them depends entirely on whether the change is “significant”:
| Non-significant change | Significant change | |
|---|---|---|
| Timing | Notify within 21 days after the change | Get CASA approval before the change |
| CASA’s role | Notification only | Formal approval required (Chapter 10A) |
| Can you act first? | Yes | No — acting without approval is a breach (s10.17(4A)) |
The definition that governs all of this sits in section 1.04(2) of the MOS. It has three limbs, and they don’t all work the same way – which is exactly where operators trip up.
A change is significant if it falls into any of these three groups.
These are significant regardless of whether safety is affected. If you change any of the following, you need approval first:
This is the limb people misread. A change to any of the procedures below is significant only if it does not maintain or improve – or is not likely to maintain or improve – aviation safety:
In other words: tighten one of these procedures in a way that clearly improves safety, and it’s not significant – make it and notify within 21 days. Loosen it, or change it in a way you can’t demonstrate maintains safety, and it is significant – approval first.
Any change that will likely result in your ReOC being reissued is significant. CASA’s own example: adding a new type or category of RPA to your ReOC, or adding a new kind of operation such as conducting RePL training.
This is the single most misread trigger, so be precise about it. In the MOS, a “type” of RPA is defined by its category (aeroplane, multirotor, single-rotor helicopter, or powered-lift), its size/weight, and its complexity — not by the manufacturer or model. Two different drones that sit in the same category and weight band, and stem from a common basic design, are the same type.
For RPA up to 25 kg MTOW, your ReOC authorises operations by category and weight limit — for example, multirotors up to 25 kg and aeroplanes up to 7 kg. That framing decides which side of the line a fleet change falls on:
Each of these changes the types on your ReOC and will generally require the ReOC to be reissued (Limb C).
A non-significant change is one that still alters the information CASA holds, but doesn’t fall into any limb above. You make the change, then notify CASA within 21 days. Typical examples:
Significant – approval required before the change:
| Change | Why it’s significant |
|---|---|
| Appointing a new Chief Remote Pilot, CEO, maintenance controller or CRI | Change to nominated personnel (Limb A) |
| Restructuring who reports to your CRP | Change to reporting lines / positions (Limb A) |
| Lowering the experience you require of your RP | Change to required qualifications (Limb A) |
| Adding a fixed-wing type to a previously multirotor-only operation | Change to types of RPA (Limb A) and likely ReOC reissue (Limb C) |
| Moving from small RPA into medium or large RPA operations | Type change + ReOC reissue (Limbs A and C) |
| Starting to deliver RePL training | New kind of operation → ReOC reissue (Limb C) |
| Extending your maintenance intervals or reducing pilot recency requirements | Procedure change that doesn’t maintain/improve safety (Limb B) |
| Changing how you amend your documented practices and procedures | Change to your change process (Limb A) |
Non-significant – notify CASA within 21 days after the change:
| Change | Why it’s non-significant |
|---|---|
| Moving your office to a new address | Administrative information only |
| Rebranding under a new trading name | Administrative information only |
| Adding a stricter wind limit to your ops manual | Limb B, but safety is improved |
| Introducing an additional pre-flight inspection step | Limb B, but safety is improved |
| Fixing typos or reformatting your ops manual | No procedure actually changes |
Limb B turns on a judgment: does the change maintain or improve aviation safety? That’s your call to justify, and it’s where the risk sits.
The safe discipline is simple: if you can’t clearly demonstrate that a change to your operational, training, risk, fatigue or maintenance procedures maintains or improves safety, treat it as significant and seek approval first. Making a significant change without CASA’s prior approval is a breach of section 10.17(4A) – the downside of over-notifying is a little paperwork; the downside of under-notifying is a compliance finding against your ReOC.
This also fits a deliberate approach to capability expansion. New operation types and new aircraft almost always sit in Limb A or C – plan them as approvals with lead time, not last-minute notifications.
For a significant change, you apply to CASA using the approved form and wait for written approval before acting (Chapter 10A; applications and approvals are handled under Subparts 11.B and 11.BA of CASR).
CASA may approve the change with or without conditions, but only if it is satisfied that:
Because approval must be in hand before you make the change, build realistic lead time into any plan that touches your people, your structure, your aircraft types, or the safety-critical procedures in your ops manual.
Change is where a well-run operation quietly drifts out of compliance. A new hire, a new drone, a “small tweak” to the maintenance schedule – each feels routine, and each can be a significant change that legally required CASA’s approval before it happened. Knowing which side of the line you’re on, before you act, is a core Chief Remote Pilot responsibility.
If you’d like this mapped against your own ReOC and documented practices and procedures, that’s exactly the kind of thing we help operators with.
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