Introduction
Obtaining a pilot certificate (basic, advanced or level 1) and registering your drone with Transport Canada is only the first step. Many believe that is enough to be "legal." The reality is different: the Canadian Aviation Regulations (CARs, Part IX) require every pilot or operator to demonstrate a structured organization of their operations. And with the arrival of the new level 1 complex operations pilot certificate, this obligation is even clearer, since any company that wishes to use it must obtain an ROC (Remotely Piloted Aircraft Systems Operator Certificate)—a certificate that is entirely based on documented operational structure.
1. Basic operations: compliance too often overlooked
Basic operations allow simple flights: visual line of sight (VLOS), away from crowds, in uncontrolled airspace. But even here, the pilot must assess risks before each flight, demonstrate fitness (rest, health, no substances), and keep records (flight log, drone maintenance). Without this kind of procedure, a basic pilot has no way to demonstrate that they meet their legal obligations.
2. Advanced operations: more freedom, but more paperwork
The advanced certificate opens the door to more complex flights (near people, in controlled airspace). But it requires a flight evaluation, a compliant drone, a more complete operations manual, and detailed training and maintenance records. Here, operational structure becomes essential.
3. The new level 1 complex operations pilot certificate
Transport Canada has introduced a new level 1 pilot certificate to govern so-called complex operations (e.g. BVLOS, heavy payloads, flights near crowds). This certificate alone is not enough. To use it, a company must apply for an ROC. And the ROC is not granted lightly: the company must demonstrate a robust operational structure, provide a detailed operations manual, document safety procedures, emergency plans and risk management programs, and designate operational managers (operations manager, maintenance manager, etc.). In short, level 1 marks a shift: compliance no longer rests on the pilot alone, but on the entire organization.
4. The ROC: a certificate built on operational structure
The ROC is the equivalent of an "operating licence" for a drone company. It can only be obtained if the organization proves it operates like a real drone-adapted air carrier—manuals and procedures (operations, maintenance, safety), a risk management system, clear organization (hierarchy, responsibilities), records and traceability of all activities, and ongoing training for pilots and staff. Without this structure, the ROC cannot be obtained, and legally operating a drone in complex operations is impossible.
5. Why operational structure is universal
For basic operations, the structure can be light: simple checklists, flight log, emergency procedures. For advanced, it must be more complete. For level 1, it becomes mandatory for the entire company: without structure, no ROC, therefore no operations possible.
Conclusion
The pilot certificate (basic, advanced or level 1) and drone registration are not enough to be in compliance. They are only the foundation. Even at basic level, an operational structure is needed to prove compliance. At advanced, this structure grows and becomes essential. At level 1, it becomes the keystone that conditions obtaining the ROC and therefore the right to operate. Bottom line: without an operational structure, no pilot or company is truly legal in Canada.
How we can help
We specialize in preparing and writing operational structures for drone operators. Our expertise ensures that your manuals, procedures and compliance systems fully meet Transport Canada requirements. Whether you want to structure your basic operations, strengthen your advanced framework or prepare an ROC application for level 1, we can support you so your company is compliant and ready to operate legally and safely. Contact us — Phone: 450-915-1188 | Email: info@highcloud.ca | Web: www.highcloud.ca
