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SI 2025/1106 Unpacked: UK Drone Class Labels, Remote ID and What Manufacturers Must Do Before January 2028
Last week we published an overview of UK UAS regulation now being in force. That post was for operators who needed to understand the landscape quickly. This one is for the people who have to read the legislation itself: drone manufacturers, conformity assessment teams, and operators managing technical compliance across both the UK and EU markets.
SI 2025/1106, the Unmanned Aircraft (Amendment) Regulations 2025, is an amendment to retained EU law, specifically to Commission Delegated Regulation (EU) 2019/945 and Commission Implementing Regulation (EU) 2019/947 as they were absorbed into UK assimilated law after Brexit. It is not a new regulatory framework built from scratch. It is a targeted set of changes that diverge meaningfully from the EU versions. If you are managing UK and EU compliance in parallel, the divergences are exactly what you need to track.
This article goes through each one.
1. The most visible change: C-class labels become UK-class labels
The structure is the same. The operational logic is the same. But a C2 label issued under EU Regulation 2019/945 is not a UK2 label under SI 2025/1106. They are different certification marks for different regulatory territories.
For manufacturers selling into both markets, this means your conformity assessment and your class identification label must now be jurisdiction-specific. A product bearing a CE-marked C2 label may be compliant in the EU but carries no regulatory status in the UK for operations requiring a UK2-class UAS.
If you are currently going through EU class label certification and plan to sell in the UK, the UK label needs its own route. That process starts before you go to market, not after.
2. The 100g MTOM scope change
Before this amendment, the exclusion from product requirements applied to UAS “intended to be exclusively operated indoors” and, separately, to toys under the Toys (Safety) Regulations 2011. Both exclusions have been replaced with a cleaner two-part scope clause:
The regulations now exclude:
- UAS designed to be exclusively operated in areas which are wholly or mainly enclosed
- UAS with a Maximum Take-Off Mass (MTOM) of less than 100 g
This matters in two directions. First, if your product is under 100 g, the product requirement obligations in the Annex do not apply. That is a lighter compliance burden. Second, the toy-product boundary has been removed. Whether a small drone is or is not a toy is no longer the deciding question for product-regulation scope. MTOM is.
If you manufacture sub-100 g drones, document that MTOM figure clearly. If you manufacture drones that hover near the 100 g threshold, make sure your MTOM declarations are precise, because crossing it activates the full Annex requirements.
3. New manufacturer notification duty
- A statement that this product type is being placed on the UK market for the first time
- The manufacturer’s name
- The unique code the manufacturer has assigned to that product type
- If serial numbers indicate product type or other features, an explanation of the serial number convention
This is a proactive notification, not a response to an audit. It applies on first market placement for each product type. If you have multiple variants, each variant that constitutes a distinct type triggers its own notice.
The practical implication: manufacturers need an internal process for tracking UK market entry events and ensuring the notification is sent before or at point of sale. This is new administrative overhead with no EU equivalent under the current framework.
4. Remote ID: what changes by class and by date
UK0 (C0 equivalent) with a camera: new obligations from January 2028
- Have a unique serial number compliant with ANSI/CTA-2063-A standard
- Have a direct Remote ID system that broadcasts in real time, via an open protocol receivable by standard mobile devices, the following data: UAS operator registration number plus verification code, serial number, time-stamp and GPS position of the aircraft and its height above surface or take-off point, route course and ground speed, GPS position of the remote pilot or take-off point, and emergency status
- Be capable of taking off only if Remote ID is functional and activated
- Have a geo-awareness function that loads restricted area data, provides breach alerts to the pilot, and gives status warnings when positioning or navigation cannot support proper functioning
The camera condition is the key qualifier. A UK0 drone with no camera carries none of these obligations. A UK0 drone with a camera carries all of them from January 2028.
UK1, UK2 and UK3 (C1, C2, C3 equivalent): Remote ID activation lock from January 2028
It is a hardware or firmware-level obligation, not a procedural one. The drone cannot lift off without active Remote ID. Manufacturers need to implement this in the product itself.
UK4 (C4 equivalent): Remote ID broadcasting from January 2028
What comes into force on 1 January 2026
The Remote ID activation lock for UK1/UK2/UK3, the full Remote ID suite for UK0 with camera, the Remote ID suite for UK4, and the geo-awareness additions for UK0 with camera are all deferred to 1 January 2028.
This two-stage commencement is significant. Manufacturers have a two-year window to develop and test the 2028 requirements. But “two years” on a firmware development, testing and re-certification cycle is not a long runway. Planning should be active now.
5. Who approves conformity assessment bodies has changed
For manufacturers seeking UK class label certification, this is a structural change in who oversees the approved body performing your conformity assessment. It does not change what the conformity assessment itself covers, but it does change the governance chain above the approved bodies operating in the UK market.
6. Transition: UAS placed on the market before 1 January 2026
If you have existing inventory or existing deployed fleets, the transition provisions are the place to check whether your current operations remain valid without re-certification through the new UK-class framework.
The EU divergence summary: what to track if you operate in both markets
| Topic | EU (2019/945 / 2019/947 current) | UK (post SI 2025/1106) |
| Class label prefix | C0 to C6 | UK0 to UK6 |
| Sub-100 g scope | Excluded (indoor-use clause, toy clause) | Excluded by MTOM threshold |
| Manufacturer notification | Not required on first placement | Required: name, type code, serial number explanation |
| Remote ID activation lock UK1–UK3 | Not yet in EU text | Required from January 2028 |
| Remote ID for C0/UK0 with camera | Not required | Required from January 2028 |
| Conformity assessment body approval | European Union Aviation Safety Agency framework | Market surveillance authority (UK) |
What this means if you are planning UK market entry
First, determine whether your product requires a UK class label or whether your operating model allows MTOM-based or legacy-transition routes.
Second, if a UK class label is required, initiate the conformity assessment with a body approved under the UK framework. EU class label certifications are not transferable. Third, begin your 2028 roadmap for Remote ID activation lock and broadcasting requirements. If your product is UK1, UK2, UK3 or UK4, firmware-level changes are coming. If your product is UK0 with a camera, the full Remote ID suite is coming. Neither of these is optional
No. A C2 label issued under EU Regulation 2019/945 is a CE-marked product certification valid within EU member states. UK operations that require a class-labelled UAS need a UK2 label issued under the UK regulatory framework. The two marks are separate and one does not substitute for the other.
Most of the Remote ID obligations, including the activation lock for UK1, UK2 and UK3, and the full Remote ID suite for UK0 with camera and UK4, come into force on 1 January 2028. The class renaming, the 100 g scope change and the manufacturer notification duty all come into force on 1 January 2026.
Two categories are excluded: UAS designed to be exclusively operated in areas that are wholly or mainly enclosed, and UAS with an MTOM of less than 100 g. The previous exclusion referencing the Toys (Safety) Regulations 2011 has been removed.
When a manufacturer places a product type on the UK market for the first time, they must notify the market surveillance authority. The notification must include the manufacturer’s name, the unique product type code, and an explanation of the serial number convention if serial numbers indicate product type or features. This is a new requirement with no equivalent in the current EU framework.
For UK1, UK2 and UK3 class UAS, the product must be physically or at firmware level incapable of taking off if the Remote ID system is not functional and activated. This is not a pilot procedure requirement: it must be implemented in the UAS itself by the manufacturer, and it applies from 1 January 2028.
The SI transfers the authority to approve conformity assessment bodies from the Secretary of State to the market surveillance authority. Existing approved bodies should confirm their status under the new governance structure. Manufacturers should verify that any body they are working with holds current approval under the amended framework.
Yes, transitional provisions apply. UAS placed on the market before 1 January 2026 can continue to operate under legacy conditions set out in the retained Implementing Regulation, subject to compliance with Part A of the Annex. If you have deployed fleets or existing inventory, you should review the transitional provisions against your specific product and operational context.