The introduction of the Level 1 Complex pilot certificate marks a significant step forward in enabling routine BVLOS operations in low-risk environments. However, this certificate doesn’t stand alone. To take advantage of these new privileges, operators must hold an RPAS Operator Certificate (RPOC)—a foundational requirement that requires specific operating, maintenance and training manuals, and that places the legal responsibility for safe operations squarely on the shoulders of the person in charge. This individual, designated as the accountable executive, is liable for ensuring compliance with all regulations, procedures, and safety practices. The organization will also need to designate a person responsible for RPAS maintenance, and need provide annual reports and training to maintain compliance. Level 1 Complex will allow for both small (250g-25kg) and medium (25kg-150kg) RPAS to be operated BVLOS, but with slightly different criteria for each weight category. 

Low-risk Level 1 Complex BVLOS operations must follow the requirements for RPAS safety approval and operational risk assessment (ORA) flight planning which considers the airspace (uncontrolled), proximity to aerodromes (>5NM (9.3km)), population density (<25ppl/sq km), distances (>1km*) from populated areas and a detect and avoid (DAA) system. When the criteria can be met, the RPAS can be operated BVLOS. These BVLOS operations can be carried out in whole, or as flight segments using Visual Line of Sight (VLOS) and/or Extended Visual Line of Sight (EVLOS) operations to allow for flight segments where BVLOS flights may be excluded. 

Medium and High complex BVLOS operations will continue to require an SFOC, which will be subject to new permitting fees based on the complexity of the SFOC application. 

As of November 4, 2025, Special Flight Operations Certificates (SFOCs) will no longer be required for routine low-risk BVLOS missions. Instead, using a risk assessment model that considers the RPAS level of safety assurance, airspace and ground risk (a combination of proximity and population density), Level 1 Complex pilots will be able to determine and authorize their own short-range BVLOS operations in accordance with the new regulations.  

This means that in uncontrolled airspace and more than 5NM from aerodromes level 1 complex pilots can fly BVLOS using: 

• Small RPAS (250g-25kg) over an unpopulated (0-5 persons per square km) or sparsely populated area (5-25 persons per square km) and less than 1km from a populated area. 
• Medium RPAS (25kg-150kg) over unpopulated areas, and 1km or more distance from a populated area (>5 persons per square km). 
• For Advanced operations, the existing framework of 100’ (30m), 16.5’ (5m), and overhead (0m) horizontal distances from bystanders remains the same for small RPAS (250g-25kg) and is determined by the manufacturers declared level of safety assurance. 

For medium RPAS (25kg-150kg) a new framework of horizontal distances from unprotected bystanders will require minimum distances of 500’ (152.4m), 100’ (30m), or overhead (0m) depending on the safety assurance level declared by the manufacturer. 

It is worth noting that for medium RPAS, structures that are being used to protect bystanders from the RPAS may need to be significantly stronger to withstand the kinetic energy of an impact from these larger drones and should be considered during flight planning if protection of bystanders is a required element of the operations. 
And yes, these distance rules still apply during takeoff and landing under Visual Line of Sight (VLOS). 
But if you are flying under Level 1 complex BVLOS then ONLY population density applies, not distance from bystanders 

Advanced certificate holders now gain access to EVLOS sheltered operations and mRPAS VLOS operations.

Medium RPAS: 

Advanced pilots will be able to operate mRPAS (25kg-150kg) under Part IX VLOS, at the distances and airspace specified in the RPA’s manufacturer safety assurance declaration. These distances can be up to 500’ (152.4m) horizontally from bystanders, or less if authorized in the safety declaration. 

Sheltered Operations: 

These are operations that are conducted within 200’ (61m) horizontally and 100’ (30m) vertically from a man-made structure that is visible to piloted aircraft, such that they would see and avoid the obstacle. 

The RPAS must be operated from on-site and may not travel more than 2NM (3.7km) from the pilot, control station or Visual Observer (VO), if used, during the flight, and the RPA must remain 100’ (30m) horizontally from bystanders during the operation. 

The VO (if used) must have a basic RPAS certificate or higher and must be able to provide unaided contact with the surrounding airspace in the RPAS operations area to be able to detect and de-conflict traffic hazards. 

A VO is not required by regulation for sheltered operations. 

Extended VLOS Operations (EVLOS): 

EVLOS operations do not require the pilot or VO to have continuous visual line of sight of the RPA but instead uses the VO as the detect and avoid system (DAA) to clear the operational airspace surrounding the RPA and provide traffic detection and deconfliction information to the PIC. 

EVLOS operations can only be conducted in uncontrolled airspace, and the RPA must remain 100’ (30m) horizontally from bystanders during the operations. 

The RPA must remain within 2NM (3.7km) of the PIC/VO during the operation, however multiple VO’s may be used to provide detect and avoid in multiple flight sectors. The PIC must be on-site with the GCS and the RPAS takeoff and landing conducted in VLOS. 

The VO’s must have at least a basic RPAS certificate and maintain effective communication with the PIC during the operations.  

For EVLOS

If you’re certified at the Basic level, there aren’t any new operational permissions included in this regulatory update. That said, your knowledge of CAR 900-series rules remains just as important. One noteworthy opportunity: Basic certificate holders can now serve as Visual Observers in EVLOS missions.

Whether you’re flying a tiny drone for a photo shoot or conducting BVLOS missions with advanced hardware, Canada’s revised RPAS regulations emphasize safety, accountability, and clear operational boundaries. These updates open new possibilities—but only for those prepared to meet the increased responsibilities that come with them.