BVLOS Drone Compliance Architecture: Part 108 and SORA

Q: Is FAA Part 108 in effect?

Not as of mid-November 2026. FAA published the notice of proposed rulemaking on 7 August 2025 and reopened the comment period in early 2026. The Federal Register shows only proposed-rule notices for the rulemaking and no final rule. Until a final rule is published and takes effect, BVLOS in the United States still requires a Part 107 waiver or an exemption.

Q: What is BVLOS and why does it need special approval?

BVLOS means beyond visual line of sight: the aircraft flies where the pilot cannot see it. Standard small-drone rules assume the pilot sees and avoids other aircraft and people. Remove that and something else must do the job, which is why regulators ask for declared flight volumes, traffic deconfliction, conformance monitoring, detect-and-avoid capability and detailed records.

Q: What is the difference between FAA Part 107 and the proposed Part 108?

Part 107 approves BVLOS case by case through waivers tied to a remote pilot. The proposed Part 108 approves the operator, through a permit or a certificate, and replaces the pilot certificate with an operations supervisor and flight coordinators. It adds population-density categories, required data services for some operations, a flight data recorder and cybersecurity obligations.

Q: How does EASA regulate BVLOS drone flights?

In Europe most BVLOS operations fall in the specific category of Regulation (EU) 2019/947. The operator needs an authorisation from the national aviation authority, normally based on a Specific Operations Risk Assessment or a predefined assessment, or holds a light UAS operator certificate that allows self-approval. In designated U-space airspace, four digital services are also mandatory.

Q: What is an operational intent in drone traffic management?

An operational intent is the declared four-dimensional volume a flight will occupy: polygons with a floor, a ceiling, a start time and an end time. It is shared with other operators through a service provider so conflicting flights can be separated before takeoff. During flight, conformance monitoring compares the aircraft position with that declared volume and flags any departure.

Q: Is Remote ID enough for BVLOS compliance?

No. Remote ID is a broadcast that identifies the aircraft and its location to people nearby. It does not declare where the flight intends to go, does not separate it from other traffic, and is not a durable flight record. BVLOS frameworks additionally expect declared intent, conformance monitoring, detect and avoid where required, and records the regulator can inspect.

Q: What is detect and avoid, and is the technology ready?

Detect and avoid is the ability to sense other aircraft and manoeuvre to prevent a collision. Cooperative traffic that broadcasts position is easy to track with an ADS-B receiver. Non-cooperative traffic needs radar, optical or acoustic sensing, and in 2026 no small onboard suite covers every case reliably. Design it as a replaceable source of tracks so the sensor can change.

Q: When is a BVLOS programme not worth building?

When the site fits inside visual line of sight from one or two positions, when long flights happen only a few times a year, or when a fenced remote site fits a predefined assessment. In those cases an observer, a one-off waiver or a standard scenario is cheaper. A compliance pipeline pays back only on frequent, repeated operations across many sites.

Satyam Kumar

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BVLOS Compliance Is a Data Pipeline, Not a Waiver: Architecting Drone Operations for FAA Part 108 and EASA SORA in 2026

By Satyam KumarNovember 14, 202616 min read

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BVLOS Compliance Is a Data Pipeline, Not a Waiver: Architecting Drone Operations for FAA Part 108 and EASA SORA in 2026

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Satyam Kumar

Founder & AI Architect, AppScale LLP

AI & Cloud Architect. Helping teams build systems that scale to millions.

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BVLOS Compliance Is a Data Pipeline, Not a Waiver: Architecting Drone Operations for FAA Part 108 and EASA SORA in 2026

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