UAS safety occurrence reporting

NATS welcomes the opportunity to comment on the proposed amendment to EU Regulation (EU) 2015/1018 laying down a list classifying occurrences in civil aviation to be mandatorily reported. NATS is the United Kingdoms main air navigation service provider (ANSP). We provide en-route air traffic services in UK airspace and by delegation from EEA ANSPs also in adjacent airspace volumes within the EEA.

Annex VI remark 2 states "This Annex contains the occurrences and other safety-related information to be reported in the operation of UAS for which a certificate or declaration for design is required pursuant to Article 56(1) and (5) of Regulation (EU) 2018/1139".

Regulation (EU) 2015/1018 contains a list of safety-related occurrences to be reported in different areas of civil aviation, but does not sufficiently address unmanned aircraft systems (UAS). This initiative amends that list to include UAS-specific safety occurrences that must be reported.

Filed in Italian · English published by the European Commission

The German Helicopter Association welcomes the opportunity to comment on the draft amendment to the Implementing Regulation (EU) 2015/1018 - Ares(2026)4542797 - 04/05/2026. We are affected by the provisions on UAS because helicopters and UAS use the same airspace in many cases. We consider the addition of the points on information security incidents in aviation to be necessary, sensible and expedient.

The Romanian Air Traffic Services Administration (ROMATSA), the certified Air Navigation Service Provider (ANSP) designated by Romania for the provision of air traffic services within the Bucharest Flight Information Region (FIR București), welcomes the initiative to update Implementing Regulation (EU) 2015/1018 in order to better reflect UAS, U-space and information security-related safety occurrences.

We welcome the fact that UAS and U-space are to be included in the regulation. However, we would like to highlight a few points that require revision. Annex V, Chapter 1.7, 2.6, 3.6: (3) Encounter of unmanned aircraft while transiting in U-space airspace. It is unclear how the word encounter is to be understood in this context.

1. Structural and Cross-Annex Consistency Several comments highlighted discrepancies in how information is presented across different sections of the regulation: Grouping vs. Separation: Discrepancies in how occurrences are listed across annexes (e.g., grouping all incursions or landing types into a single phrase for UAS/Annex IV, but separating them in Annex I).

UAP Coalition Netherlands welcomes the European Commission's initiative to modernize the mandatory safety occurrence reporting framework under Draft Implementing Regulation Ares(2026)4542797. While the inclusion of comprehensive Unmanned Aircraft Systems (UAS) and U-space criteria is a major step forward for modern airspace management, our institutional and technical analysis indicates an important safety gap…

I respond as a contributor to EUROCAE WG118, Flight Recorder Systems. WG118 has recently published the Minimum Aviation System Specification ED350 for AAM (advanced air mobility) recording systems. 1. We welcome the creation of a dedicated UAS occurrence-reporting annex and the risk-based limitation to higher-risk UAS operations.

Today, when issuing operational authorisations to UAS operators based on Art. 12 of Regulation 2019/947 several competent authorities list occurrences subject to mandatory reporting, case by case, because in fact there is a gap in Regulation 2015/1018.