EUROCAE publishes draft compliance guide for medium-risk UAS

(02)The draft ED-325 Vol. II guide

EUROCAE published on 27 October 2026 a draft document entitled ED-325 Vol. II, prepared by working group WG-105 SG-4 (Design and Airworthiness). This volume is a guide for developing Means of Compliance (MoC) with EASA's Special Condition Light-UAS – Medium Risk. It is aimed at applicants for voluntary certification (type certificate) for UAS operating in the specific category, at SAIL III and IV levels, as defined by Regulation (EU) 2019/945.

The document refers to ED-279 (Generic FHA for UAS/RPAS) and ED-280 (Guidelines for UAS Safety Analysis) where these are deemed acceptable. It is part of the work carried out by EUROCAE since the early 2000s through its WG-72 group on aeronautical information systems security. Volume II covers subparts B, E, F and G of the Special Condition; proposals for the other subparts are still being drafted.

(03)Scope of the guide and conditions covered

ED-325 Vol. II does not directly define mass, height or distance thresholds. It provides means of compliance to meet the EASA requirements set out in the Special Condition Light-UAS – Medium Risk. The latter sets the UAS classes concerned and the associated risk levels. In practice, the guide enables manufacturers to rely on proven standards – ED-279 and ED-280 – to demonstrate the safety of their design.

Volume I (published as a draft in 2023) covered subparts C, D and H of the same Special Condition. Its consultation ended on 30 January 2024; the final version was published in 2024. Together, the two volumes form a reference corpus for the technical classification and airworthiness documentation of UAS in the specific category. The precise operational conditions – masses, flight heights, distances – remain those of the EASA regulatory framework, which the guide does not modify.

(04)Consultation and publication timetable

The draft ED-325 Vol. II is open for consultation until 8 December 2026. Comments must be submitted on the EUROCAE workspace, accessible to members and non-members via a registration procedure. Once the consultation closes, the WG-105 SG-4 group will analyse the feedback and publish a final version, expected in the first half of 2027. The document may then be proposed by EASA as an acceptable means of compliance.

This consultation follows previous ones. Volume I had been open for comments until 30 January 2024. Earlier, in November 2022, EUROCAE had opened the consultation on ED-311, a draft MOPS for the remote pilot station core layer (RPS Core Layer) intended for the certified category, with comments due by 23 January 2023. This work illustrates the progression of UAS design standards within the organisation.

(05)Uncertainties over EASA recognition

The final status of ED-325 Vol. II has not yet been determined. The guide is designed to serve as a basis for voluntary AMCs (Acceptable Means of Compliance), but there is no guarantee that EASA will take it over as is into a regulatory framework. The Agency could adopt it as a reference or draw on it to develop binding rules. It could also launch a formal Notice of Proposed Amendment procedure to integrate the guide into its corpus.

Moreover, some means of compliance are still being drafted for the subparts not covered by Volume II. The document remains an evolving draft. Manufacturers and operators must follow the next steps: publication of the comments received, release of the final version, then EASA's decision on its official recognition. Other parallel workstreams, such as the ED-329 detect-and-avoid standard or the software development framework for the specific category, will also influence the regulatory ecosystem.