The EU Regulatory Framework
EU Regulation 2019/947 on the rules and procedures for the operation of unmanned aircraft entered into full application on 1 January 2021. It replaced a patchwork of national rules with three operational categories — Open, Specific, and Certified — each defined by risk level, aircraft weight, and proximity to uninvolved persons. Commission Delegated Regulation (EU) 2019/945 complements the framework by establishing the technical and administrative requirements for unmanned aircraft systems placed on the EU market.
The regulation is supplemented by Acceptable Means of Compliance (AMC) and Guidance Material (GM) published by EASA, which provide interpretive guidance for national competent authorities. In Poland, ULC publishes Polish-language interpretations of these materials and has issued supplementary national decisions where the regulation permits discretion — such as additional restricted zones around sensitive infrastructure.
The Three Operational Categories
The Open category covers low-risk operations conducted below 120 m above ground level, within visual line of sight, and away from restricted airspace. No prior authorisation from ULC is required, though operator registration and pilot competency requirements apply depending on subcategory. The Open category is divided into A1, A2, and A3, based primarily on the maximum take-off weight (MTOW) of the unmanned aircraft and the proximity allowed to uninvolved persons.
The Specific category applies to operations that fall outside the Open category parameters — for example, operations beyond visual line of sight (BVLOS), above 120 m, or in populated areas with heavier aircraft. Operators must submit an operational risk assessment to ULC using the SORA (Specific Operations Risk Assessment) methodology developed by JARUS and adopted by EASA. ULC may issue a standard scenario authorisation (STS) for pre-defined operation types or an individual operational authorisation for novel use cases.
The Certified category addresses high-risk operations comparable in risk profile to manned aviation — including carriage of persons or operations over large assemblies. This category requires aircraft certification, air operator certification, and pilot licensing under procedures analogous to those in Part-FCL.
Operator Registration in Poland
Registration as a UAS operator is mandatory for:
- All operators of drones with MTOW above 250 g, regardless of sensor equipment.
- Operators of drones below 250 g that are equipped with a camera, microphone, or any other data capture sensor capable of collecting personal data.
Registration is completed via ULC's DronePortal platform. The process requires a valid email address, PESEL number (for natural persons) or NIP (for legal entities), and payment of the registration fee — currently PLN 20 for a three-year registration period. Upon successful registration, the operator receives a unique registration number (e.g., POL-XXXXXXXXXXXX-XX) that must be affixed to each drone in the fleet.
Pilot Competency Requirements
Open category A1 operations with C0-class aircraft (under 250 g) require only a self-declaration. A1 operations with C1-class aircraft (250 g to 900 g) require the operator to complete the online A1/A3 training module and pass the associated knowledge test via the DronePortal. A2 operations require the A2 Certificate of Competency (A2 CoC), obtained by passing an online theory exam at ULC-approved examination centres. For A3 operations, the A1/A3 certificate suffices.
Certificates of Competency issued by any EU member state authority under Regulation 2019/947 are recognised across the entire European Union. Polish operators with certificates issued by authorities in Germany, France, or other member states are not required to obtain a second Polish certificate.
Airspace Structure and PANSA
Poland's airspace is structured according to ICAO classification with controlled (A, B, C, D, E), advisory (F), and uncontrolled (G) portions. Drone operators are primarily concerned with Class G uncontrolled airspace, typically below 700 ft (213 m) AGL, where Open category operations are permitted subject to applicable restrictions.
PANSA (Polish Air Navigation Services Agency) manages NOTAM publications and the DroneRadar application, which provides real-time visualisation of temporary airspace restrictions (TSA, D areas, CTR zones) affecting drone operations. DroneRadar is the primary pre-flight planning tool for operators in Poland and is available as a mobile application and web interface.
Restricted Zones and CTR Compliance
Operations within airport control zones (CTR) require prior approval from the relevant ATC unit. In practice, this applies to the areas around Warsaw Chopin (EPWA), Kraków Balice (EPKK), Gdańsk Lech Wałęsa (EPGD), and other commercial airports. Approvals for CTR entry may be requested via the ATC unit directly or, in some cases, through automated FIMS (Flight Information Management System) interfaces being progressively introduced under the U-Space framework.
Additional restricted zones in Poland include permanent danger areas (D) over military training ranges, prohibited areas (P) around government buildings and nuclear facilities, and temporary restrictions published via NOTAM for public events, VIP movements, and military exercises. Violations of restricted airspace carry administrative penalties under Polish aviation law and may result in registration suspension by ULC.
U-Space and Future Framework
EU Regulation 2021/664 establishes the U-Space framework — a set of automated digital systems designed to manage drone traffic at scale. Poland is among the EU member states implementing U-Space infrastructure in phases. The initial phase covers U-Space Airspace Designation and the mandatory use of network Remote Identification for operators in designated zones. ULC has published draft U-Space service provider (USSP) authorisation procedures applicable to Polish territory.
Remote ID — the requirement for drones to broadcast identification data during flight — became mandatory in Poland from 1 January 2024 for all C-class aircraft operating in the Open category. Operators of legacy aircraft without built-in Remote ID capability may use add-on modules approved under EASA guidelines.
Insurance Requirements
Under EU Regulation 785/2004, third-party liability insurance is mandatory for all drone operators conducting commercial activities in Polish airspace, with minimum coverage levels dependent on MTOW. For aircraft between 0.5 kg and 200 kg, the minimum coverage is 0.75 million Special Drawing Rights (SDR) per occurrence. Recreational operators in the Open category below 20 kg are covered under national provisions that permit household liability policies as a substitute, subject to individual policy terms.