UA.I.E.K15: Means of Compliance (MoC).

ACS Area I — Regulations Task E: Operations Over People References: 14 CFRCode of Federal RegulationsCloseThe federal rulebook where Part 107, Part 89, Part 48, and other aviation rules live. parts 89 and 107; ACAdvisory CircularCloseFAA guidance that explains acceptable ways to comply with rules or understand FAA procedures. 107-2; FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-H-8083-25; FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-G-8082-22

Key Concepts

What “Means of Compliance” (MoC) Covers for Operations Over People

Under §107.155, MoC is the technical pathway a manufacturer or applicant uses to show a small UASSmall Unmanned Aircraft SystemCloseA small drone plus the control and communication links used to operate it. meets the performance-based requirements that enable Category 2 or Category 3 operations over people. The MoC must be based on test, analysis, or inspection, and the applicant must submit detailed procedures and an explanation of how the MoC demonstrates the aircraft satisfies §107.120(a) (Category 2) or §107.130(a) (Category 3). The FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes. may accept the MoC, but it remains subject to ongoing review and can be rescinded, with notice published in the Federal Register. This puts a premium on using current, FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-accepted MoC when declaring eligibility for operations over people.^[1]

A small UASSmall Unmanned Aircraft SystemCloseA small drone plus the control and communication links used to operate it. can be eligible for more than one category if designed accordingly, but the system must prevent the remote PICRemote Pilot in CommandCloseThe certificated remote pilot responsible for the Part 107 operation. from inadvertently switching between modes/configurations that establish eligibility. In other words, the “category-defining” configuration cannot be accidentally changed in flight or during operations.^[2]

Category Eligibility Tied to Design, Labeling, and Instructions

• Category 1 overview: limited to a maximum weight of 0.55 pounds and must not have exposed rotating parts that would lacerate human skin. Category 4 uses an airworthiness certificate under part 21. Category-based operations over people are permitted only if conducted within the four subpart D categories, with §107.39 otherwise prohibiting flight over persons not under safe cover; direct participants include the remote PICRemote Pilot in CommandCloseThe certificated remote pilot responsible for the Part 107 operation., anyone manipulating the controls, a VOVisual ObserverCloseA person who helps the remote PIC see and avoid hazards during a drone operation., or necessary crewmembers.^[4]

• Category 2 design performance: to qualify, the small UASSmall Unmanned Aircraft SystemCloseA small drone plus the control and communication links used to operate it. must be designed/produced/modified so it will not cause injury equivalent to or greater than 11 foot-pounds of kinetic energy upon impact with a rigid object, has no exposed rotating parts that would lacerate human skin, and contains no safety defects.^[3] Practically, this is what the MoC must prove via test/analysis/inspection.

• Category 2 labeling and instructions: the applicant for a declaration of compliance must display a label indicating eligibility to conduct Category 2 operations and provide remote pilot operating instructions that, at minimum, include a system description (required components, limitations, and declared category/categories), permissible modifications that do not alter eligibility, and instructions for verifying and changing the mode/configuration.^[3] These instructions help the remote PICRemote Pilot in CommandCloseThe certificated remote pilot responsible for the Part 107 operation. configure the aircraft to remain within the declared category during flight.

• Remote pilot operating instructions: they must enable a pilot to clearly understand how to configure the sUASSmall Unmanned Aircraft SystemCloseA small drone plus the control and communication links used to operate it. to comply with the applicable category requirements. While helpful, the remote PICRemote Pilot in CommandCloseThe certificated remote pilot responsible for the Part 107 operation. remains responsible for safe operation and must be able to discern which set of instructions is current. Sample instructions may specify eligibility in Category 2 and 3 when the pilot follows stated modification/configuration steps.^[6]

Operational Implications for Remote PICs and Manufacturers

• For manufacturers/applicants: select or develop an MoC (test/analysis/inspection) that demonstrates compliance with §107.120(a) or §107.130(a), submit procedures and a compliance explanation, and maintain vigilance because acceptance can be rescinded.^[1] Chapter 8 of ACAdvisory CircularCloseFAA guidance that explains acceptable ways to comply with rules or understand FAA procedures. 107-2A also points to FAAFederal Aviation AdministrationCloseThe U.S. aviation regulator responsible for Part 107 rules, airspace, and pilot certification processes.-Provided MoC and Voluntary Consensus Standards Body MoC pathways, along with Declarations of Compliance.^[8]

• For remote pilots: before operating over people in Category 2 (or 3), verify the aircraft’s permanent Category label and follow the provided operating instructions to ensure the aircraft is in the correct mode/configuration. Ensure no inadvertent switching between category modes can occur, consistent with §107.150.^[2][3][6]

• Over open-air assemblies: sustained flight restrictions vary by category. Category 1 and 2 operations are prohibited from sustained flight over open-air assemblies unless the operation meets Remote IDRemote IdentificationCloseRemote ID broadcast requirements for most drones operating in U.S. airspace. provisions in §89.110 or §89.115(a) (this prohibition is waivable). Category 3 must not operate over open-air assemblies. Know these limits when planning operations that rely on Category eligibility proven by an MoC.^[5]

Remote ID MoC Context (Separate but Related)

Remote IDRemote IdentificationCloseRemote ID broadcast requirements for most drones operating in U.S. airspace. has its own MoC framework under part 89 subpart E. Any person may submit an MoC for Remote IDRemote IdentificationCloseRemote ID broadcast requirements for most drones operating in U.S. airspace. acceptance, including contact information, a detailed description, an explanation addressing all minimum performance requirements of subpart D, and any substantiating material. The submission must include testing and validation procedures showing, through analysis, ground test, or flight test (as appropriate), how the design meets the Remote IDRemote IdentificationCloseRemote ID broadcast requirements for most drones operating in U.S. airspace. requirements. This is a different MoC domain than §107.155 but often intersects with operations over open-air assemblies.^[7]