Everyone's Talking About BVLOS. Almost No One is Actually Ready.

Beyond Visual Line of Sight. BVLOS. It's the phrase that gets dropped in every drone industry conversation, conference panel, and vendor pitch deck. It's the holy grail. The thing that will unlock the real commercial potential of this industry. The capability that separates 'drone operators' from 'remote sensing professionals.'

And as of November 4, 2025, Transport Canada has made it officially accessible without an SFOC, at least for lower-risk operations.

So why isn't everyone flying BVLOS yet?

Because there's an enormous gap between 'the regulations now allow it' and 'I can actually execute it safely and professionally.' And almost no one is talking honestly about what that gap actually looks like.

The Certificate Is Not the Capability

The new Level 1 Complex (L1C) certification pathway is a significant step forward. It includes a 20-hour ground school, a new online exam, and a flight review. Training providers are already marketing courses that can get you certified in as little as two weeks.

That's genuinely valuable. But here's what the marketing doesn't tell you: the certificate gets you legal permission to conduct BVLOS. It doesn't give you the operational infrastructure to do it well, or safely, on a real project with real stakes.

Consider what a serious BVLOS operation actually requires:

A Pre-Validated Declaration (PVD) for your aircraft. This isn't just a checkbox. It means your drone manufacturer has submitted safety documentation to Transport Canada demonstrating the system meets Standard 922 technical requirements for BVLOS operations. Without this, your aircraft isn't legal for the operation—regardless of your personal certification.

An RPAS Operator Certificate (RPOC). If you're operating as a business, you need organizational-level certification, not just individual pilot credentials. This means documented policies, procedures, and an accountable executive responsible for regulatory compliance.

Comprehensive safety cases and risk assessments. BVLOS operations require you to demonstrate how you'll manage risks that simply don't exist in visual line of sight flying. How do you detect and avoid other aircraft? What happens when you lose your command-and-control link? What's your contingency volume? What's your ground risk buffer?

Crew resource management protocols. Who's doing what? How do you communicate during the operation? What's your handover procedure if control needs to transfer between pilots? These aren't nice-to-haves; they're the difference between a professional operation and a cowboy outfit waiting for something to go wrong.

The Equipment Problem No One Wants to Discuss

Here's an uncomfortable truth: the self-declaration system that governs which drones are legal for advanced and complex operations has significant gaps.

Transport Canada's Safety Assurance Declaration process allows manufacturers to self-declare that their systems meet the technical requirements in Standard 922. The keyword is 'self-declare.' Manufacturers don't have to submit verification test results with their declaration; they just have to be able to produce them if audited later.

This has been, to put it diplomatically, problematic.

In 2024, Transport Canada conducted oversight audits and found that 110 drone declarations were invalid, affecting nearly 2,000 registered pilots who thought they were flying legal equipment for advanced operations. When TC asked manufacturers to produce their verification test results, the paperwork wasn't there. Autel, a major manufacturer, saw its entire drone lineup removed from the approved list for controlled airspace operations.

Think about what that means for operators. You buy a $15,000 drone specifically because it's on the Transport Canada-approved list. You build your business around it. You win contracts based on having BVLOS-capable equipment. Then one day, you get an email saying your registration certificate has been updated because the manufacturer's declaration was invalidated.

For Level 1 Complex BVLOS operations, the bar is even higher. Operations over sparsely populated areas or within 1km of populated areas require a Pre-Validated Declaration, meaning Transport Canada actually reviews the manufacturer's documentation before accepting the declaration, not just if an audit happens to occur.

The question every operator should be asking: Does my equipment actually have valid declarations for the operations I want to conduct? And is that declaration likely to survive an audit?

The Gap Between 'Legal' and 'Ready'

We've executed complex BVLOS operations. Not the straightforward kind, the 30-day Arctic deployments, the marine mammal monitoring programs, the operations that require months of protocol development before a single prop spins.

Here's what we've learned: the flight itself is maybe 20% of the operation. The other 80% is the infrastructure that makes it possible.

That infrastructure includes:

Documented operating procedures that have been tested and refined through actual operations, not just written to satisfy a checklist.

Emergency procedures that your crew can execute under pressure, not just recite from memory.

Communication protocols that maintain situational awareness when your aircraft is kilometres away, and you can't see it.

Client-facing documentation that demonstrates your capability to organizations with serious safety requirements, resource sector clients, government agencies, and environmental consultancies with regulatory obligations.

A safety management system that actually functions, not just exists on paper.

Most operators pursuing L1C certification haven't thought about most of this. They're focused on passing the exam and getting the certificate. That's understandable; it's the first hurdle. But it's not the only hurdle, and arguably not even the highest one.

What This Means for Clients

If you're a client considering hiring a BVLOS operator, here's what you should be asking:

Have you actually executed BVLOS operations before? Not 'are you certified to'—have you actually done it? How many times? In what conditions? For how long?

Can you show me your RPAS Operator Certificate? This demonstrates organizational capability, not just individual pilot credentials.

What's your safety management system? If they can't articulate it clearly, that tells you something.

What equipment are you using, and can you verify its declaration status? Given the 2024 audit results, this isn't paranoia; it's due diligence.

What's your operational history with this specific type of mission? Pipeline inspection is different from marine mammal monitoring is different from agricultural surveying. Experience in one doesn't automatically transfer to another.

What This Means for Operators

If you're an operator pursuing BVLOS capability, be honest with yourself about where you actually are versus where you want to be.

Getting certified is a necessary step. It's not a sufficient one.

The operators who will build successful BVLOS practices are the ones who invest in operational infrastructure before they bid on complex contracts. Who develops procedures through actual operations - starting with lower-risk scenarios and building complexity gradually. Who understands that professional BVLOS capability takes months or years to develop, not weeks.

The new regulations are a significant opportunity. They remove a major barrier that previously required individual SFOC applications for every BVLOS operation. That's genuinely valuable.

But opportunity and capability are different things. The regulations opening up don't mean everyone is ready to walk through that door.

The Honest Path Forward

We're not writing this to gatekeep BVLOS. We train operators for L1C certification. We want more people in this industry to develop real capability.

But we also believe the industry benefits from honest conversations about what capability actually requires. The alternative is a flood of operators bidding on contracts they can't safely execute, clients getting burned by providers who overpromised, and incidents that give regulators reasons to tighten restrictions again.

The path forward is straightforward, even if it's not fast:

Get certified. The L1C credential is the foundation.

Verify your equipment. Make sure your aircraft actually has valid declarations for the operations you want to conduct.

Build your organizational infrastructure. If you're operating commercially, get your RPOC. Develop your SMS. Document your procedures.

Start with lower-risk operations. Build experience before you bid on complex missions.

Be honest about your capability level. With clients, with yourself, with your team.

BVLOS is coming. It's already here, legally speaking. The question is whether you're actually ready for it, not just permitted to attempt it.

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Aeria Solutions is a full-spectrum remote sensing company and a recognized Level 1 Complex ground school provider. We've executed BVLOS operations from Arctic marine mammal monitoring to resource sector surveys, and we train operators who want to build real BVLOS capability—not just pass an exam.