With the rapid evolution of drone technology, users are increasingly adding or modifying payloads—cameras, sensors, delivery systems, etc.—on remotely piloted aircraft (RPAS). But under the Canadian regulatory framework, this raises important safety, compliance and liability issues.
Transport Canada's Information Circular CI No. 922-001, effective April 1, 2025, clarifies the requirements for RPAS system safety assurance under Standard 922 – Safety assurance of remotely piloted aircraft systems of the Canadian Aviation Regulations (CARs).
Here is why, if a payload is not recognized or not explicitly included by the drone manufacturer, you must obtain a construction approval or submit a new declaration.
1. Who is affected?
The circular applies to RPAS manufacturers for advanced operations and level 1 complex operations under Part IX of the CARs.
It governs those who must make a declaration of compliance or a validated declaration in advance (VDA) for the drone (or complete system) to be authorized to operate legally.
2. Declarations and compliance under Standard 922
Standard 922 requires each RPAS to meet specific technical requirements depending on the type of operation—e.g. operations near people, over people, or in controlled airspace.
The manufacturer must declare that the system, in its intended configuration (including supported payloads), meets the requirements of Standard 922.
If a payload modifies the drone so that its characteristics change (weight, inertia, failure behaviour, etc.), that configuration may no longer match the initial declaration—and therefore requires a new declaration.
3. Why unrecognized payloads are a problem
Adding a payload not recognized by the manufacturer leads to:
- different weight or load distribution
- unknown aerodynamic or stability effects
- modified energy consumption
- integration of systems (electronic, mechanical) that introduce new risks
These changes directly affect:
- drone reliability
- failure management
- command and control link performance
- containment capability in case of loss of control
All of these are covered by Standard 922 and assessed by Transport Canada.
4. What the regulations require in practice
- Declaration of compliance: A manufacturer may declare its drone compliant, but only in tested and recognized configurations.
- New declaration or VDA: If an unrecognized payload is added, a new declaration of compliance, or even a Validated Declaration in Advance (VDA) for higher-risk operations, must be submitted.
- Documentation: The Concept of Operations (CONOPS) must be updated; the operations manual must reflect new limits (weight, speed, flight modes, etc.); and compliance with Standard 922 reliability and safety standards must be demonstrated.
5. Conclusion — What this means for you
If you are considering adding or using a payload that does not appear in the manufacturer's documentation or in the declaration already submitted:
⚠️ Do not assume it is acceptable—you could be in violation.
You must obtain either:
- a construction approval, or
- submit a new declaration compliant with Standard 922.
This protects you legally and ensures the safety of your operations, your crews and the public.
Useful references:
- CI No. 922-001 – Safety assurance of remotely piloted aircraft systems
- Standard 922 – RPAS safety assurance
