Spray drone licensing in Australia

The short answer

Two regulators, plus the label

CASA regulates the aircraft: who may fly it, where, and how. It says nothing about which product goes in the tank or where the drift lands. That belongs to your state or territory under its chemical control laws, and to the product label approved by the APVMA. Holding one set of approvals never covers the other.

CASA's own guidance for farmers makes the split clear: operating one drone over your own land needs no extra CASA authorisation to spray, but you still need to check your state's aerial distribution laws, which can add licensing, spray quality and equipment requirements.

Why every Agras is a medium drone

CASA sorts drones by weight: micro (250 g or less), very small (up to 2 kg), small (up to 25 kg) and medium (more than 25 kg, up to 150 kg). Above 150 kg a drone needs additional certification. Every current Agras is over 25 kg with a battery fitted, before anything goes in the tank:

DJI's T100 specification tells Australian operators to keep the maximum take-off weight at 149.9 kg, which keeps it a medium drone. With the aircraft itself weighing about 75 kg, that leaves roughly 75 kg for product. It also means none of the Agras range fits CASA's 2 to 25 kg landholder category, where CASA's free operator accreditation stands in for a RePL.

Spraying your own land

CASA lets you fly a drone of more than 25 kg and up to 150 kg over your own land, for business or as part of your job, without a ReOC. It calls this the landowner or private landholder excluded category, and it applies only if:

• the land is yours. CASA's farming guidance describes it as land owned or leased by the drone's owner, so the drone must belong to the landholder too. Spraying a neighbour's block is not your land, whether or not money changes hands;
• you accept no payment of any kind for the work;
• the pilot holds a RePL for the type and model of drone;
• you fly within the standard operating conditions; and
• you keep the operational records CASA requires.

The standard operating conditions are set by regulation 101.238 of the Civil Aviation Safety Regulations. In short: keep the drone within your visual line of sight, at or below 400 ft (about 120 m), by day; stay at least 30 m from anyone not involved in the job; do not fly over a populous area or within 3 nautical miles of a controlled aerodrome's movement area; keep out of prohibited areas, certain restricted areas and emergency operations; and fly only one drone at a time.

Anything outside those conditions takes you out of the landholder category. CASA lists flying beyond visual line of sight, extended visual line of sight and swarms of more than one drone as needing a ReOC (yours or the business you fly for) and a specific approval. Calling it a hobby does not help either: CASA's recreational rules require an approval to fly any drone over 25 kg for fun.

RePL and type ratings

The RePL is the pilot's licence. CASA says it shows the type and weight category of drone you can fly: less than 7 kg, less than 25 kg, and, for anything heavier, type-specific ratings only. A RePL does not expire, and there is no minimum age. To get one you:

1. get an aviation reference number (ARN) through the myCASA portal;
2. find a CASA-certified RePL training provider;
3. pass the theory component;
4. pass the practical component for the type and category of drone you will fly; and
5. let the provider apply to CASA for your licence.

For an Agras, the practical assessment is done on the model you will fly, and the rating is issued for that model. If you move from one Agras to another, plan on being assessed again, and ask your provider exactly which model your rating will list. Flying in controlled airspace also needs an aeronautical radio operator certificate (AROC).

Through our CASA-certified training partner we book the RePL Sub 25 kg course ($2,990.00), which our DJI Agras type rating ($890.00) flight test asks for first. Pilots who already hold a sub 7 kg RePL can take the 7 kg to 25 kg upgrade ($879.00) instead.

Spraying for payment: the ReOC

A remotely piloted aircraft operator's certificate (ReOC) is what lets a business trade as a drone service provider for hire or reward. It is not a pilot licence: everyone who flies under it still needs a RePL. The holder must write operating procedures and manuals to the Part 101 Manual of Standards, train its pilots on them, keep records, and register its drones.

• Applying. You submit CASA's form with your operations manual and supporting documents, pay the fee CASA estimates, and your chief remote pilot passes an assessment. CASA says this can take up to 70 business days. Approved industry delegates can also issue ReOCs for basic operations with drones up to 150 kg.
• What it lists. The certificate names the type of drone, weight limits, and, for drones over 25 kg, the manufacturer and model.
• Validity. An initial ReOC lasts 12 months and renewals up to three years. An expired ReOC cannot be renewed; you start a new application.
• Adding an aircraft. CASA treats adding or removing types of drone as a significant change that needs the ReOC reissued, while adding another aircraft within the approved scope is a non-significant change you notify within 21 days. Check which applies before you add a new Agras model.
• Spraying procedures. CASA includes aerial distribution and spraying among the complex operations that bring extra training and authorisation requirements, so build them into your operations manual from the start.

Our ReOC service ($3,519.00) prepares the operations manual and your chief remote pilot for the assessment, and the Contractor Kit ($4,880.00) books the RePL, type rating and ReOC together.

Registration and your ARN

CASA requires every drone used for business or as part of your job to be registered, whatever it weighs, and farm spraying counts. Registration lasts 12 months, drones over 500 g carry a $40 levy each, and flying an unregistered drone for business can bring a fine of up to $18,200. Registration is done online, and the ARN your RePL needs comes from the myCASA portal. A RePL or ReOC holder does not also need CASA's operator accreditation.

The chemical label still rules

The APVMA treats a drone as an aircraft for spray drift purposes. That means a drone application must follow the label's directions for aerial application, including buffer zones, spray quality, water volumes and release height. Where a label has no aerial directions, check with your state regulator before using a drone: in Victoria the licence conditions allow drone spraying only where the label or a permit covers aerial or spot spraying.

Victoria

Agriculture Victoria says that when a drone is spraying agricultural chemicals in Victoria, the pilot must hold an RPA pilot (chemical rating) licence and be operating under an RPA agricultural aircraft operator licence. That applies to your own land as well as a client's: the operator licence can be issued on the strength of a ReOC or, for a landholder, on meeting CASA's own-land exemption.

• Operator licence (RPA AAOL). Needed by the drone's operator (owner, leaseholder, borrower or equivalent) and by anyone employing spray pilots. An individual, partnership or company can hold it. Valid for three years.
• Pilot chemical rating licence (RPA PCRL). Needs the chemical units AHCCHM307 and AHCCHM304 (or earlier equivalents) or the Aerial Application Association of Australia's Pilot Spraysafe accreditation, plus a RePL for the drone. Valid for three years. An owner who also flies needs both licences.
• Applying. Online through Agriculture Victoria Connect, at least four weeks before you need to spray. Fees are set in fee units and change each 1 July.

Both licences carry conditions that matter when you choose and set up an aircraft:

• fly within CASA's standard operating conditions, except up to five drones at once where CASA has approved it;
• no spraying before sunrise or after sunset;
• the drone must be under 150 kg gross weight;
• no autonomous operation, meaning flight the pilot cannot intervene in;
• nozzles equally spaced and inside the arc of the propeller tips; and
• active pump and nozzle shut-off.

The spraying itself must follow the label or permit's aerial or spot spraying directions, including water rates; ultra-low volume or concentrate techniques only where the label directs them for aerial use; and the label's wind limits, or wind between 3 and 13 km/h where the label is silent. The pilot needs live wind information at the target (a windsock, smoke, an automatic weather station, or a radio link to someone measuring it), records must be made within 48 hours and kept for two years, and some areas need a permit for certain chemicals.

Separately, using Schedule 7 products or products containing atrazine, metham sodium, or ester formulations of MCPA, 2,4-D, 2,4-DB or triclopyr needs an agricultural chemical user permit, however you apply them.

Features like night-vision cameras and fully planned routes are part of the aircraft, not permission to use them: in Victoria, drone spraying stops at sunset and the pilot must be able to take over at any moment.

Western Australia

In WA, the Biosecurity and Agriculture Management (Aerial Application) Regulations 2018 set training and record-keeping rules for anyone applying agricultural chemicals from an aircraft, crewed or remotely piloted. Nobody may apply an agricultural chemical product from an aircraft without the prescribed qualifications or an approved equivalent.

• Your own land. A landowner who owns a drone of up to 150 kg and flies it only over their own land, without payment, needs the units AHCCHM303 or AHCCHM307 and AHCCHM304.
• Everyone else. The Aerial Application Association of Australia's Spraysafe pilot accreditation, or equivalent training: AHCCHM303 or AHCCHM307, AHCCHM304, AHCPMG301, AHCPMG302, AHCCHM404 and AHCCHM405.
• Records. For every job: date and time, who applied it, the owner or occupier and location of the land, the area treated, estimated wind speed and direction, the product, rate and concentration per hectare, the equipment and the crop. Complete them within 48 hours and keep them for at least three years.

Paid work can bring a second regulator. WA's Department of Health licenses pest management technicians and registers pest management businesses under the Health (Pesticides) Regulations 2011, and its licensing FAQ says anyone who charges a fee for managing weeds needs a licence. Ask its pesticide licensing team (08 9222 2000) which licence and business registration covers contract drone spraying before you quote your first job.

Queensland, NSW and other states

• Queensland. The Agricultural Chemicals Distribution Control Act 1966 applies in regulated areas. There, Business Queensland says a drone doing aerial distribution must be flown by a pilot holding a pilot chemical rating licence, which for a drone requires a RePL regardless of CASA's own-land exemptions, and the work must be done under a licensed aerial distribution contractor. CASA's farming guidance gives the same example: a RePL and a state pilot chemical rating licence, even over your own land. Check with Biosecurity Queensland whether your property is in a regulated area and which licences apply to you.
• New South Wales. The EPA issues RPA business and RPA pilot licences under the Pesticides Act 1999, with a narrower path for people spraying only land they own or occupy with a drone in CASA's excluded category. The EPA also says a rotary drone cannot be used where a label allows only fixed-wing application. Confirm with the EPA which licences you need.
• South Australia, Tasmania, the NT and the ACT each have their own chemical and aerial spraying rules. Start with PIRSA in South Australia and NRE Tasmania, and ask the relevant regulator before you fly.

Own land vs contract work at a glance

What order to do it in

1. Get your ARN through myCASA.
2. Do your RePL and the rating for your Agras model with a certified provider.
3. Register the drone before its first flight.
4. Complete your state's chemical training and apply for its licences (in Victoria, allow at least four weeks).
5. For paid work, apply for the ReOC (CASA allows up to 70 business days), then the state business licence that depends on it.
6. Arrange insurance, including spray drift and third-party liability, before the first job.

Where we fit in

We book the CASA courses through a certified training partner and prepare ReOC applications; the prices above are current. State chemical licences are applied for by you, with your state regulator, and we will point you at what yours requires. For what the whole setup costs, see the spray drone cost guide, and for choosing an aircraft, the buyer's guide. All our courses are in the training and licensing collection.