IAA UAS Operator Registration

Mark Prendergast

New European Commision UAS regulations came into force on the 01st Jan 2021. The regulations require UAS Operators register their operation. UAS Operator registration will therefore become law on the 01st Jan 2021 and is necessary for safety and security reasons. A UAS Operator is the entity managing the UAS operation (recreational pilot, sole trader, limited company etc) and is different from the remote pilot who simply flies for the UAS Operator....although one person could be responsible for both roles!!

Each EU member state is required to designate a competent authority to implement the necessary processes. In Ireland, that competent authority is the Irish Aviation Authority (IAA). To fulfil their new EU regulatory requirement, the IAA have launched a new online portal known as MYSRS (My Safety Regulatory System). Each UAS operator must open an account with MYSRS and within this account, registration can be conducted. You can find the new online portal at https://iaa.mysrs.ie_{Note: See below a step-by-step guide to opening a MYSRS accounting and registering a UAS operation.}

A UAS Operator is a 'natural person' (e.g. recreational pilot, sole trader) or a 'legal person' (e.g. limited company, limited partnership, government organisation) that owns or rents an unmanned aircraft for the purpose of conducting recreational or commercial/aerial work activities.

In accordance with the regulation, the UAS Operator and Remote Pilot are separate entities with different responsibilities. The UAS Operator provides a service and is responsible for ensuring the service is safe, and is properly and legally managed with all the required approvals. A Remote Pilot conducts the actual flying for a UAS operator and is responsible for the unmanned aircraft when it is airborne.

To help with your understanding of this UAS operator vs remote pilot principle, it is useful to think of the UAS operator as you would an airline. An airline operator has all the responsibilities of managing and running the airline including employing, training and rostering pilots to fly the airline's aircraft. The remote pilot is not responsible for running the airline but is responsible for flying the airline's aircraft.

Confusingly, and difficult for new entrants to the UAS industry to appreciate, a 'natural person' registering as an UAS operator may also be a remote pilot. This person will be required to take care of the separately defined UAS operator responsibilities and remote pilots responsibilities. This will often be the case for recreational pilots and sole traders who own their own unmanned aircraft and fly for themselves. Many other remote pilots will work for an UAS operator and this is the case for those remote pilots who work for a limited company or government organisation.

Article 14 of the Regulation (EU) 2019/947 requires all operators of UAS/drones to be registered with an EU member state. Once registered, an UAS Operator is provided with a unique registration number, referred to as an operator ID, and shall affix their Operator ID to each and every unmanned aircraft they use i.e. the same registration number is applied to all the unmanned aircraft operated by UAS Operators.

This operator ID provides details on the operator in the same way a licence plate on a vehicle provides details of the vehicle owner. The requirement to register the UAS operator is a departure from previous Irish regulatory requirements (SI563/2015) where each individual unmanned aircraft had to be registered.
_{Note: If an operator is using a drone designed to be a toy (complying with EC Directive 2009/48/EC) with a max take-off weight below 250g, no registration is required.}

In Ireland, UAS operators can register with the IAA through the online web platform MYSRS (https://iaa.mysrs.ie). See the step-by-step guide below.

A 'natural person' (recreational pilot, sole trader) registering as an UAS operator should do so in their EU country of residence.

A 'legal person' (limited company, legal organisation, Government organisation) registering as an UAS operator should register in the EU country where they have their principal place of business.

A third country operator (non-EU UAS operator) should register in the first EU country they plan to operate in.

UAS operators shall only register in one EU member state. UAS operator databases are shareable among EU members through their respective aviation authorities.

When an UAS operator registers, they will be issued a unique and identifiable Operator ID (registration number). This ID is structured by regulation to identify information such as country of issue.

A UAS Operator must register,

Open Category

If their unmanned aircraft has a Max Take-Off Mass (MTOM) 250g or greater.
If the unmanned aircraft has a Max take-Off Mass (MTOM) less than 250g but,

- Flies fast enough to have a Kinetic Energy in excess of 80J (capable of operating speeds of 90kph)
- Is not a toy but has a sensor capable of capturing personal data (e.g., camera, microphone).

A toy is designated by EU directive to be an article that is designed to be operated by children under the age of 14 years. If you are operating unmanned aircraft and you are reading this text, more than likely your unmanned aircraft is not a toy!!

Specific Category

All unmanned aircraft

.

A remote pilot is the person responsible for flying the unmanned aircraft. The unmanned aircraft may be flown manually or may be monitored as it operates under auto-pilot. At all times the remote pilot must be ready to intervene.

Remote pilots only need register as an UAS operator if, as stated above, they are also the 'natural person' that owns or rents a drone with the intention of flying for recreational or commercial/aerial work purposes. If as a remote pilot you only fly for an UAS operator, then you do not need to register.

However, pilots will need to record their training competency. This is also conducted through the IAA's MYSRS system. All remote pilots, whether recreational or commercial, need to complete some form of training and will be issued a proof of training certificate. Therefore, remote pilots also need to open an account with MYSRS, even if they never intend to register as an UAS Operator.

The following is a guide to initially setup an account with MYSRS and then within that account register as an UAS Operator.

Step 1. Navigate to https://iaa.mysrs.ie

Step 2. Click ‘Sign Up Now’.

Step 3. Insert your personal email address. Create a password and confirm it.

_{Note, this account is personal to you and so does not need to be a work email. You must scroll to the end of the privacy section before you will be able to tick the box. Also note, to have an account you must be 16 years of age.}

Step 4. Review the IAA Privacy Notice and Terms & Conditions

Step 5. Consent to conditions and click ‘Sign Up’.

You will be sent a confirmation email. Click ‘Confirm Account’ to be brought to the main MYSRS login page.

Once logged in, you will need to verify your details.

Step 6. Start Verification. Under Welcome to MySRS, click ‘Start Application’.

Step 7. Existing IAA Licence. Enter Yes (with details) or No.

Step 8. Proof of Identity – Select your identity type and upload an image.

Very Important:

• Your name must be the same as stated on your ID including middle name.

• Your place of birth must be a county, not a town or hospital.
• If your ID includes an address, your personal details must reflect this address. You can update your current address details later when your account is open if they are different than on your ID. Passports have no address details and are thus an easier document to use.

Step 9. Personal Detail. Enter your details keeping in mind the note at point 7. Any discrepancy or difference will result in your account not verifying.

Step 10. Identity Address. Enter your details keeping in mind the note at point 7. Any discrepancy or difference will result in your account not verifying.

Step 11. Upload your signed document and click ‘Submit'.

Account verification is processed Monday to Friday 9am to 5:30pm. Allow from 3 up to 10 days for the verification process to be completed.

Once your account is verified by the IAA you need to login and setup Two Factor Authentication (2FA).

Step 12. Download onto your mobile device your preferred ‘Authenticator App' from the list provided.

Step 13. Open your Authenticator App and using the QR reader function, capture the QR code presented on MYSRS.

Note: You will be presented with 5 password recovery keys – take a photo and save them somewhere safe – they will no longer be available once your 2FA is set-up but will be required if your ever encounter problems with 2FA.

Your account is now verified and 2FA Security has been established.

Login to your MySRS Account

Step 14. Click on the UAS Panel.

Step 15. Under the MySRS – UAS Services heading click ‘Start Application’ on the ‘Unmanned Aircraft System – Proof of Online Training (A1/A3)’ panel and complete the foundation training course.

You now have the basic remote pilot certificate.

Note: Allow about 30minutes. This short safety course by the IAA introduces remote pilots to some fundamentals of unmanned aircraft operations. The training consists of a 10-minute video and a 40 multiple choice question exam (very easy). It may cost €30! All personnel are required to complete this safety course.

There are two different steps depending on whether you are registering as a 'natural person' (recreational pilot, sole trader) or you are going to register a 'legal person' (limited company, Government agency etc). To register a 'legal person', you must ensure you have the legal right to do so. See next below for registering a 'legal person'.

Natural Person

Step A. Open MYSRS Home Page.

Step B. Click 'Unmanned Aircraft System - Operator Registration'.

Step C. Input your insurance policy number. If you do not need insurance and therefore have no insurance, insert 'Unknown' here.

Select 'Open A1/A3' or 'Open A2' or 'Specific' depending on the EU category of operation you intend to operate under. You may only be presented with 'Open A1/A3' or 'Open A2' options. Your choice here does not matter and truth be told, makes no difference. Registration is required and is independent of the category of operation.

Step D. Click 'Proceed to Payment' and pay (€30 for two years).

Step E. Once registered, note the registration number (IRLxxxxxxxxxxxxxx) and write or affix this number to every drone operating under the organisation.

Legal Person
Limited companies, legal organisations, Government agencies and other state bodies etc, should register as a 'legal person'. If you as an individual have the authority to register a 'legal person' then you do so within your own personal MYSRS account.

Note: The MYSRS platform requires a 'legal person' to have a Company Registration Office (CRO) number. If you need to register a Government or state body with no CRO number, you to follow the guidance of UAM 02 notice from the IAA.

Organisation Verification on MYSRS.
The organisation needs to be added to MYSRS with its own account before it can be registered as a UAS Operator.

Step A1. Open MYSRS.

Step A2. On the left side of the page select 'My Organisations'.

Step A3. Under 'Organisation Verification' box click 'Registered in Ireland'

Step A4. Use Organisation/Company CRO number to start the registration.

Step A5. Complete verification steps.

Accountable Manager (Responsible Person)
The organisation needs to indicate and assign some person with the correct authority to oversee the organisation's responsibility. This person is known as the Accountable Manager.

Step A6. Follow steps A1-A2 again.

Step A7. On the 'Organisation Administrator' tab select 'Switch to this Profile'.

Step A8. Click 'Add Key Person' and search for the person who will be the Accountable Manager. You will need their personal IAA MYSRS account number. (On MYSRS top right-hand corner click the icon and note personal MYSRS account number (IAA-202x-xxxxx)).

Step A9. Under 'Select Regulation Area' drop down menu, select 'Drones'.

Step A10. Under 'Select Role' menu select 'Accountable Manager'.

Step A11. Select 'Add Person' and follow further guidance or possible requests from the IAA to prove the selected person has the permission to operate as Accountable Manager.

Step A12 The person who is nominated as Accountable Manager, will need to login to MYSRS. They will then need to continue the application of becoming Accountable Manager. This involves uploading a letter of proof as being permitted to operate as a company’s Accountable Manager.

• Company Director: Create a letter on headed paper stating you are a director of the company and have the authority to operate as the Accountable Manager.

• Company Employee: Have a director of the company write on headed paper stating a director of the company gives employee x the authority to operate as Accountable Manager for the company.

Registering the Organisation
Now the organisation has an account on MYSRS and the Accountable Manager Role has been assigned, the Accountable Manager should login to MYSRS and register the organisation as a UAS Operator.

The following is completed by the nominated Accountable Manager.

Step A12. Follow Steps A1-A2 again.

Step A13. On the 'Accountable Manager' tab select 'Switch to this Profile'.

Step A14. Click the UAS Box (Blue Colour).

Step A15. Under 'Registration' box click 'Start Application' and follow details to register your organisation. (EUR30. Valid 2 years).

Step A16. Once registered, note the registration number (IRLxxxxxxxxxxxxxx) and write or affix this number to every drone operating under the organisation.

Once an UAS Operator is fully registered, they will receive an Operator ID (registration number). This Operator ID identifies the UAS Operator and is valid through-out the EU. Your Operator ID comprises a combination of 16 letters and digits. You should note an additional 3 letters at the end (19 characters total) e.g., IRLtweyg68htyu59 - das. While the 16-character string is required to be displayed on your drone(s), never disclose your 3-letter pin. Treat it like you would your credit card pin.

The Operator ID (registration number) should be affixed to each drone the UAS Operator uses. The same number on each drone. No decal or label will be sent to you from the IAA.

Points to Note.

• You must write the Operator ID directly to the drone or create your own label. It must be clearly readable when the drone is on the ground.

• The label may take the form of a QR code.

• It is acceptable to write or label your Operator ID in the battery compartment of your drone if you cannot find a suitable location elsewhere.

As always, any questions or queries, please contact hello@safedrone.ie or +353870919600.

Blue Skies & Safe Landings.

IAA UAS Operator Registration

New Regulatory Requirement.

Who or What is a UAS Operator?

What is the Registration Process?

Where do you Register?

When does an UAS Operator need to Register?

Do Remote Pilots Need to Register?

Initial Account Setup

Identity Verification

Two Factor Authentication (2FA)!!

Foundation Training!!

Register as an UAS Operator (Natural Person)

Register as an UAS Operator (Legal Person)

Once Registered. What do you do next?

Sign Up & Receive Brochure