Drone Laws in the UAE

Drones, or unmanned aircraft systems (UAS), have become an integral part of modern life, transforming how we deliver goods, monitor infrastructure, and even capture breathtaking aerial views. From delivering medical supplies to remote areas to enhancing public safety through real-time surveillance, drones offer innovative solutions across industries. However, their rapid proliferation and increasing complexity demand a robust and adaptive legal framework to ensure safety, privacy, and operational efficiency.

In the UAE, where innovation and progress are at the forefront, the need for clear, up-to-date regulations is particularly critical. The introduction of Civil Aviation Regulation (CAR) Airspace Part Uspace by the General Civil Aviation Authority (GCAA) represents a significant step in addressing these challenges, providing a structured approach to managing UAS navigation services while fostering technological advancement.

Enacted pursuant to the authority of Federal Decree-Law No. 28 of 2023 on Civil Aviation, CAR Airspace Part Uspace builds upon the foundational principles established by Federal Law No. 20 of 1991 on the Regulation of Civil Aviation, as amended. The 1991 law, which initially established the GCAA and its mandate to regulate aviation safety and airspace management, continues to provide complementary legal authority for general aviation governance that intersects with UAS operations.

Legal Framework: CAR Airspace Part Uspace

CAR Airspace Part Uspace prescribes a detailed licensing and compliance regime for air navigation service providers (ANSPs) providing navigation services for UAS. The regulation delineates the following core obligations:

•  Certification and Audit Processes: ANSPs must undergo a rigorous certification process, including initial assessments and periodic audits to verify compliance with GCAA safety and operational standards. Certification requirements include submission of operational manuals and safety protocols.
•  Training and Competency Standards: Personnel engaged in UAS navigation services must complete GCAA-approved training programs and demonstrate ongoing competency in airspace management, emergency response, and UAS-specific technologies.
•  Safety Management Systems (SMS): ANSPs are required to implement robust SMS frameworks, incorporating risk assessments, incident reporting, and mitigation strategies to ensure operational safety. The SMS must align with International Civil Aviation Organization (ICAO) standards.
•  Quality Assurance: Continuous quality assurance mechanisms, including performance monitoring and compliance audits, must be established to maintain service reliability.
•  Infrastructure and Scalability: ANSPs must develop plans for scalable infrastructure to support urban air mobility (UAM), including integration with manned aviation air traffic management systems and future vertiport networks.
•  Post-Certification Oversight: The GCAA retains authority to conduct inspections, impose sanctions (including fines up to AED 200,000 for non-compliance), and revoke certifications for violations of regulatory standards.

Comprehensive Legal Framework Governing UAS in the UAE

UAS operations in the UAE are subject to a multifaceted regulatory framework comprising federal legislation, cabinet resolutions, and emirate-specific guidelines. The principal legal instruments include:

•  Federal Decree-Law No. 28 of 2023 on Civil Aviation: Establishes the overarching framework for aviation governance, vesting the GCAA with regulatory authority over UAS and other aviation activities.
•  Federal Law No. 20 of 1991 on the Regulation of Civil Aviation, as amended: Provides foundational authority for the GCAA’s mandate and continues to govern general aviation matters, such as airspace management, that complement UAS-specific regulations.
•  Federal Decree-Law No. 26 of 2022 on the Regulation of Unmanned Aircraft: Prescribes specific requirements for UAS ownership, operation, registration, and airspace access, including restrictions in controlled zones.
•  Cabinet Resolution No. (110) of 2023 on the UAE Scheme for Unmanned Aircraft Systems: Regulates the import, distribution, manufacturing, and certification of UAS, mandating a Certificate of Conformity and requiring compliance within a 180-day grace period from November 6, 2023. The resolution also mandates tracking systems for all UAS to enhance traceability and safety.
•  GCAA CAR Part VIII, Subpart 10: Governs UAS operations, including licensing categories (e.g., open, specific, certified), operational limitations (e.g., altitude restrictions), and safety protocols.
•  Emirate-Level Regulations:
  •  Dubai Civil Aviation Authority (DCAA): Prescribes rules for UAS operations within Dubai, including no-fly zones and permitting processes for commercial operations.
  •  Abu Dhabi Department of Municipalities and Transport (DMT): Issues guidelines for UAS activities in Abu Dhabi, emphasizing safety and integration with urban planning.
•  Ministry of Interior (MOI) Requirements: Mandates registration of all UAS with the MOI and imposes security-related obligations, such as restrictions on operations near sensitive sites.

These instruments collectively regulate UAS ownership, technical specifications, airspace access, permissible uses, and importation, with requirements tailored to specific use cases (e.g., recreational, commercial) and jurisdictional mandates.

Recent Developments: Partial Lifting of Drone Operations Ban

On November 23, 2024, the UAE Ministry of Interior (MOI) announced a significant update to the regulatory landscape for UAS operations, partially lifting a ban on drone operations that had been in place since 2022. The ban, initially imposed due to incidents of misuse, had suspended drone activities for owners, practitioners, and enthusiasts, including light sports aircraft and paragliding, as a measure to safeguard lives, property, and airspace. During this period, the MOI, in coordination with the GCAA, reviewed and updated regulations to address safety and compliance concerns, allowing exemptions only for companies and organizations with contractual or commercial projects, provided they obtained GCAA permissions.

The partial lifting of the ban, effective November 25, 2024, marks the beginning of a phased approach to reintegrate drone operations into UAE airspace. In the initial phase, the policy applies exclusively to companies and government entities, allowing them to resume operations under strict regulatory oversight. This decision was informed by a comprehensive evaluation that highlighted strong compliance with safety protocols among drone operators, as noted by the MOI. To facilitate this transition, the MOI, in collaboration with the National Emergency Crisis and Disasters Management Authority (NCEMA) and the GCAA, launched a unified national platform for drone operations. This platform streamlines registration and operational procedures, accessible via the "UAE Drones" app, ensuring that operators adhere to the highest safety standards.

Future phases of this initiative are planned to expand access, including services for amateur enthusiasts, with further details to be announced. Unauthorized drone operations during this phased rollout remain subject to legal accountability under Federal Decree-Law No. 31 of 2021 (UAE Penal Code), specifically Article 176, which prescribes imprisonment from six months to five years, fines of at least AED 100,000, or both, for violations such as airspace breaches. Attempted violations are also punishable, underscoring the UAE’s commitment to balancing innovation with public safety.

Ancillary Legal Provisions

UAS operations are further governed by ancillary UAE legislation addressing criminal and cybersecurity concerns:

•  Federal Decree-Law No. 31 of 2021 (UAE Penal Code): Imposes penalties, including imprisonment and fines, for unauthorized UAS use, such as trespassing, endangering public safety, or violating restricted airspace.
•  Federal Decree-Law No. 34 of 2021 (UAE Cybercrime Law): Addresses UAS-related offenses involving unauthorized surveillance, photography, data breaches, or disruption of public order, with penalties including imprisonment for up to seven years.

Practical Applications of UAS in the UAE

UAS are integral to various sectors in the UAE, with applications governed by the regulatory framework:

1.  Logistics and Delivery:
   • Pilot programs facilitate the delivery of e-commerce goods, food, and medical supplies, subject to GCAA and DCAA approvals.
   • In 2024, the Dubai government initiated a regulated UAS delivery program, requiring operators to comply with CAR Part VIII and CAR Airspace Part Uspace.
2.  Public Safety and Emergency Response:
   • UAS are deployed for police surveillance, civil defense operations, and crowd monitoring, with operations coordinated through GCAA-approved ANSPs.
3.  Construction and Infrastructure:
   • UAS conduct aerial inspections, site monitoring, and geospatial mapping, subject to airspace access permits.
4.  Agriculture and Environmental Management:
   • UAS support precision agriculture through crop spraying, irrigation analysis, and environmental monitoring, including desertification and wildlife tracking, with operators required to register with the MOI.
5.  Entertainment and Events:
   • UAS are utilized for choreographed light displays during public festivals, requiring DCAA permits for operations in urban airspace.
6.  Tourism, Real Estate, and Marketing:
   • High-resolution aerial imagery supports promotional campaigns and property visualization, subject to privacy restrictions under the Cybercrime Law.
7.  Media and Journalism:
   • UAS enable advanced cinematography for live broadcasts and documentary production, with operators required to obtain GCAA filming permits.

UAS Ecosystem and Infrastructure Development

The UAE’s UAS ecosystem is expanding, with over 24,000 registered drones, as reported by the GCAA. To accommodate this growth, the UAE has implemented several initiatives:

•  Urban Drone Network: In 2024, Dubai announced plans for a dedicated UAS network, including aerial corridors and a specialized UAS vertiport, targeted for completion by 2026. The network will operate under CAR Airspace Part Uspace oversight.
•  Operational Trials: Pilot programs are testing UAS connectivity between Dubai International Airport, Downtown Dubai, and other strategic locations, with airspace managed by GCAA-certified ANSPs.
•  Stakeholder Collaboration: The Roads and Transport Authority (RTA), DCAA, and GCAA collaborate to develop UAS infrastructure, ensuring compliance with Federal Decree-Law No. 28 of 2023 and Federal Law No. 20 of 1991 for shared airspace governance.
•  UAE Drone Strategy 2023–2030: This strategic plan aims to establish the UAE as a hub for UAS technology, emphasizing regulatory harmonization, infrastructure investment, and technological innovation.

The GCAA projects a significant increase in UAS operations, driven by commercial demand and government-backed initiatives.

Regulatory Obligations for Stakeholders

Stakeholders in the UAS sector, including operators, manufacturers, and ANSPs, face the following obligations:

•  ANSP Licensing: Entities providing UAS navigation services must obtain a GCAA license under CAR Airspace Part Uspace, subject to ongoing compliance audits and submission of annual safety reports.
•  Operational Coordination: UAS operators in controlled or congested airspace must coordinate with certified ANSPs to ensure safe integration, as mandated by CAR Part VIII.
•  Advanced Operations: Beyond Visual Line of Sight (BVLOS) and autonomous operations require specific GCAA approvals, including risk assessments and compliance with CAR Airspace Part Uspace standards.
•  Import and Manufacturing Compliance: Importers and manufacturers must secure a Certificate of Conformity under Cabinet Resolution No. (110) of 2023, with mandatory tracking systems for all UAS. Non-compliance may result in fines up to AED 100,000.
•  Incident Reporting: Operators and ANSPs are obligated to report safety incidents to the GCAA within 72 hours, with non-compliance potentially resulting in fines or license revocation.

Conclusion

The promulgation of CAR Airspace Part Uspace, pursuant to Federal Decree-Law No. 28 of 2023 and supported by the foundational authority of Federal Law No. 20 of 1991, reflects the UAE’s strategic approach to regulating its UAS sector. Complemented by Cabinet Resolution No. (110) of 2023 and Federal Decree-Law No. 26 of 2022, this regulatory framework balances the imperatives of public safety, operational efficiency, and technological advancement.

For expert legal counsel on UAS registration, licensing, compliance, or commercial deployment in the UAE, contact HPL Yamalova & Plewka FZCO at www.lylawyers.com.