The UK Just Turned Repeat BVLOS Approvals Into a Screening Job

A new annex, and what it is for

The UK Civil Aviation Authority published the fourth edition of CAP3040, its policy concept for beyond visual line of sight operations in an atypical air environment, on 29 September 2026. The addition that matters is Annex G, a pathway that lets an experienced operator run equivalent operations at several locations under one operational authorisation instead of proving the same operation again for every new location. Anyone flying long linear assets should read that annex closely. An atypical air environment approval rests on the argument that permanent infrastructure reduces the likelihood of a mid-air conflict. The argument does not change when a corridor crosses into the next county, but the paperwork used to.

What equivalence has to mean Annex G is narrow on purpose.

The CAA will consider an equivalent operation at a different site only where the proposal does not increase the overall risk profile, does not require an existing mitigation to be modified, does not need new mitigations, and leaves the assumptions behind the approved safety case untouched. Where a proposal goes further than that, the major variation route or a fresh risk assessment application still applies. Sites also have to belong to the same specialism. The policy concept expects additional locations to be equivalent in nature and to fall within the organisation's operational specialism, and its examples keep railway work with railway infrastructure and powerline work with powerline infrastructure or similar asset types.

The phased route, in order

The pathway assumes history. An operator starts with an initial authorisation, then expands to additional sites through a variation with full CAA assessment, and only after building operational experience and organisational capability talks to the authority about an equivalent operations condition. Plan against that sequence rather than against a date, because the middle stage is where the evidence is actually built.

What each new site still needs

The multiple-site condition is not a geographical permission. Every location still needs a suitable and sufficient risk assessment, the supporting documentation that includes location files, and a completed airspace assessment checklist submitted through the CAA's system alongside the NOTAM request. Notification is expected no less than five working days before the NOTAM publication date. The bigger change is what happens after submission. Site paperwork is kept for audit rather than read on arrival, and it is not itemised inside the authorisation as a separate line. Responsibility for deciding whether a site still sits inside the approved safety case moves to the operator, and the authority checks that judgement by sampling and targeted assessment rather than by reading every file. That is a different kind of obligation. It rewards a repeatable site-screening process and punishes a folder of PDFs with no owner. Tooling built for commercial drone operations, including Aerosyne's, is starting to treat the equivalence decision and the site record as one artifact, which is the right shape for this model.

Independence and competence are named

The criteria list asks for named safety-critical roles and evidence of organisational competence. One line catches people out: the person who conducts the risk assessment for an operation cannot also be accountable for signing it off. A safety management system is not mandated below SAIL 4, but a documented organisational structure with named responsibilities is described as the usual expectation.

Two policy documents in one month CAP3040 is not the only piece of BVLOS policy the authority refreshed in September. Version 2 of its detect and avoid policy concept landed on 22 September with more clarity on assurance requirements, testing approaches and the evidence expected for DAA enabled operations.

Read together, the two documents describe what an operator has to prove, and how many times.

Takeaway

If you run repeat inspection flights in the UK, make the equivalence test a pre-flight decision rather than a filing task. Before each new site, write down which approved assumption would change if that site were different, and stop the process if the honest answer is not none.