Quick answer. If your drone weighs under 25 kg and you can operate it in daylight, below 120 m, within visual line of sight, away from aerodromes, and with consent from everyone below you, you can fly under Part 101 — no CAA certificate, no application, even for commercial work. The moment your operation needs to break any of those limits — night flying, controlled airspace, BVLOS, spraying, flying over people without consent — you must hold a Part 102 Unmanned Aircraft Operator Certificate issued by the Civil Aviation Authority of New Zealand.
Most conversations about “getting a drone licence in New Zealand” get the framework wrong. New Zealand does not license pilots the way many countries do — it certifies operators (organisations or individuals) whose intended operation sits outside the standard ruleset. That distinction changes everything about how you plan a commercial drone programme, what it costs, and how long it takes to get in the air.
This guide is written for operations managers, procurement teams, surveyors, agronomists, energy asset owners, and public-sector buyers who need to decide — quickly and defensibly — which side of the Part 101 / Part 102 line their job sits on.
In this article
- The 30-second decision
- Part 101 vs Part 102 side-by-side
- What Part 101 actually allows
- When you must move to Part 102
- What Part 102 certification involves
- Realistic cost and timeline
- Common misconceptions
- Which path fits your operation
- Frequently asked questions
The 30-second decision
Answer these five questions honestly about your intended operation:
- Will the drone weigh less than 25 kg?
- Can you fly only in daylight, keeping the aircraft in direct visual line of sight at all times?
- Can you stay at or below 120 m (400 ft) above ground level?
- Can you stay at least 4 km clear of any aerodrome — or get authorisation if closer?
- Can you obtain consent from every property owner you fly over, land on, or take off from, and from every person you fly directly above?
If the answer to all five is yes, and you are not spraying, topdressing, or dispersing anything, you can operate under Part 101 today. If the answer to any is no — or if the operation is even occasionally going to require an exception — you need to plan for Part 102.
That is the whole framework. Everything below is the detail.
Part 101 vs Part 102 side-by-side
Criterion Part 101 Part 102 Who it covers Any operator — recreational or commercial Operators whose activity sits outside Part 101 limits CAA certificate required? No Yes — an Unmanned Aircraft Operator Certificate (UAOC) Application to CAA? None Formal application, exposition, Prime Person interview Maximum aircraft weight Under 25 kg (15–25 kg requires airworthiness certification) Determined by your approved exposition; heavier platforms possible Maximum altitude 120 m (400 ft) AGL Whatever your exposition justifies and CAA approves Visual line of sight Required at all times Can be waived for approved BVLOS operations Time of day Daylight only (shielded night ops now possible under CATI 101-1 with training) Night operations approvable Airspace Away from aerodromes (4 km) and clear of controlled airspace unless ATC-cleared or shielded Controlled-airspace operations approvable Flying over people / property Consent required for every person and every property Can be approved without individual consent, subject to risk mitigations Aerial spraying, topdressing, or dispersal of vertebrate toxic agents Prohibited under Part 101 Approvable under Part 102 with agrichemical rating and appropriate procedures Typical use cases Photography, real-estate, basic mapping, roof inspection with consent Agricultural spraying, powerline BVLOS, night search-and-rescue, urban surveillance, heavy-lift, deliveries Time to be operational Same day Typically 4–9 months from application Compliance cost Effectively zero Application fees, exposition development, training, ongoing audit Sources: Civil Aviation Rules Part 101 and Part 102, Civil Aviation Authority of New Zealand, current as of the CAA consolidations of December 2025.
What Part 101 actually allows
Part 101 is New Zealand’s baseline ruleset for all unmanned aircraft under 25 kg, and it makes no distinction between hobby and commercial use. That is a genuinely unusual position internationally — in Australia, the United States, and across the EU, commercial operators must hold some form of remote-pilot licence. In New Zealand, you can legally sell photographs, produce mapping deliverables, or run an inspection service under Part 101 with no CAA certificate whatsoever, provided you stay inside the rules.
The core Part 101 operating limits are:
- Weight — the aircraft must be under 25 kg. Aircraft over 15 kg must additionally be certified as airworthy.
- Line of sight — the pilot must be able to see the aircraft with unaided eyes at all times (glasses and contacts are fine; binoculars, telescopes, and FPV goggles are not, unless a trained observer maintains visual contact and is in continuous communication with the pilot).
- Altitude — no higher than 120 m (400 ft) above ground level, unless flying in accordance with the specific conditions in CATI 101-1 (Civil Aviation Transport Instrument 101-1).
- Daylight — daytime only, unless conducting a shielded night operation compliant with CATI 101-1 and appropriate training.
- Airspace — stay at least 4 km from any aerodrome or heliport, and stay clear of controlled airspace unless you have air traffic control clearance from Airways New Zealand, or the operation is a shielded operation.
- People — do not fly over any person without their consent.
- Property — do not fly over any property without the consent of the owner or occupier, including for take-off and landing.
- Prohibited operations — no aerial spraying, no aerial topdressing, and no dispersal of vertebrate toxic agents under Part 101, regardless of the scale.
- Restricted and military airspace — no entry without the administering authority’s permission.
- Weather — do not fly through, above, or behind cloud or fog, or behind objects that break line of sight.
Recent nuance: CATI 101-1, the transport instrument that sits underneath Part 101, now permits several activities that historically required Part 102 — including certain shielded BVLOS operations and shielded night operations — provided the operator meets specific training and equipment requirements. This is important because it means some jobs that used to need a full UAOC can now be done under Part 101 with the right competency, which shifts the value proposition of certification.
Registration: As of 2026, New Zealand still has no mandatory drone-registration system, although CAA has signalled one is coming. In the meantime, registration on the AirShare platform is voluntary but strongly recommended, and it is what commercial procurers will expect to see on your operating profile.
When you must move to Part 102
Part 102 is not a “next tier” of Part 101 — it is a separate certification regime for operators who cannot, or do not want to, comply with Part 101. If any single one of the following applies to your intended operation, Part 101 is off the table:
- Aircraft heavier than 25 kg (heavy-lift platforms, agricultural sprayers, cargo drones).
- Beyond visual line of sight (BVLOS) operations that are not shielded — for example, powerline corridor inspections, long linear infrastructure surveys, over-water pipeline runs.
- Night operations that fall outside the CATI 101-1 shielded-night carve-out.
- Flying over people without individual consent — crowd photography at public events, urban surveillance, security cordons.
- Flying over property where obtaining owner consent is not practical — dense urban operations, motorway inspections, wide-area emergency response.
- Controlled airspace operations that need standing authorisation rather than case-by-case ATC clearance.
- Aerial spraying, topdressing, or dispersal of vertebrate toxic agents — this is a hard prohibition under Part 101 and always requires Part 102 plus the applicable agrichemical rating.
- Operations near or above active aerodromes where 4 km separation is impractical.
- Delivery, passenger, or commercial cargo operations.
- First-of-type, novel, or experimental operations where standard rules do not contemplate the activity.
A key point that surprises many first-time applicants: holding a Part 141-issued pilot qualification is not a Part 102 certificate. Part 141 is the framework for approved training organisations. You (or your organisation) must submit a separate application to CAA for the operator certificate itself.
What Part 102 certification involves
Part 102 is a risk-based, exposition-driven certification. CAA is not simply checking whether you can fly a drone — it is assessing whether your organisation can manage the aviation-safety risks of a specific set of operations, and whether the person nominated as accountable (“Prime Person”) understands those risks and the rules that apply.
The core building blocks are:
1. The exposition
Your exposition is the operations manual for your unmanned-aircraft business. CAA’s own guidance is that it should be written in the tense of “this is what we do,” not as a copy-paste of the rules. A useful test: could a brand-new employee pick up your exposition and know exactly what steps to follow to conduct any of your approved operations?
The exposition typically covers:
- Organisation structure and accountable personnel
- Scope of intended operations (what, where, with which aircraft)
- Aircraft, equipment, and maintenance procedures
- Pilot training, competency, and currency requirements
- Site assessment and pre-flight risk assessment procedures
- Standard operating procedures for each operation type
- Emergency and abnormal procedures
- Incident reporting and safety management
- Change management for adding aircraft, pilots, or operation types
CAA publishes a Sample Exposition for lower-risk operations, which is a legitimate starting point but must be adapted to what your organisation actually does.
2. The Part 102 compliance matrix
Alongside the exposition, you submit a completed compliance matrix (form 24102-03) mapping every Part 102 rule to the section of your exposition that addresses it.
3. The Prime Person
CAA nominates and interviews a Prime Person — the individual accountable for the operation. This is not a rubber-stamp interview. The Prime Person is expected to demonstrate genuine, working knowledge of Part 101, Part 102, the exposition, the applicable advisory circulars (AC101-1 and AC102-1), and the risk management approach for the intended operations. First-time applicants often underestimate this stage.
4. Fit and Proper Person assessment
A questionnaire and assessment covering the Prime Person’s background and suitability.
5. Aircraft and pilot approval
Each aircraft and pilot the certificate authorises to operate must be documented, and pilots must meet training standards acceptable to the Director. For higher-risk operations, that generally means training through a Part 141 organisation to a syllabus CAA recognises.
6. Ongoing obligations
Once issued, a UAOC comes with continuing duties: change notifications, exposition amendments as your scope evolves, occurrence reporting, and periodic CAA audit. It is a live certification, not a one-off document.
Realistic cost and timeline
Every Part 102 application is priced against the CAA’s hourly rate for processing and assessment, so total cost depends entirely on the scale and complexity of what you are asking to do. In our experience across the sector, a first-time applicant seeking a lower-risk exposition — for example, standard commercial VLOS work with a couple of exceptions — can expect:
- Exposition development: 4–12 weeks, depending on whether you write it in-house or engage a consultant
- CAA assessment: typically 4–6 months from a complete, clean submission
- Prime Person interview: scheduled once the paperwork clears initial review
- Total elapsed time from decision to first flight: commonly 6–9 months
- Total cost: varies widely; realistic budget for a straightforward first UAOC including CAA fees, external exposition support, and initial Part 141 training is well into five figures
Complex, first-of-type, or novel operations — extended BVLOS, urban delivery, heavy-lift over infrastructure — sit inside CAA’s Emerging Technology pathway and take substantially longer. Do not commit to a customer delivery date until CAA has confirmed the scope of approval.
Common misconceptions
“I need a licence to fly commercially in New Zealand.” No. Part 101 permits commercial operation without any CAA certificate, provided you stay inside the rules. This is one of the most misunderstood features of the New Zealand regime.
“A Part 141 course gives me Part 102.” No. Part 141 is a training-organisation approval. Completing a course at a Part 141 school gives you a qualification; it does not give your organisation an operator certificate. Those are separate CAA processes.
“AirShare registration is mandatory.” Not currently. It is voluntary and strongly recommended, but there is no statutory registration requirement as of 2026.
“If I can’t see the drone, I just need a spotter.” Only if the spotter is a trained observer maintaining unaided visual contact and in continuous direct communication with the pilot. That is not BVLOS — it is still a VLOS operation. True BVLOS requires either a compliant shielded operation under CATI 101-1 or Part 102 approval.
“Consent to fly over a park applies to everyone in it.” No. New Zealand’s consent requirement is per person, not per venue. Landowner consent is separate from consent from the individuals below the drone.
“Once I have a Part 102 certificate, I can do anything.” No. Your UAOC authorises the specific operations described in your exposition and operations specification. Adding new aircraft, new sites, or new operation types generally requires an exposition amendment.
Which path fits your operation
Use this as a starting framework — it is not legal advice, and every operation should be assessed against the current rules and your specific site conditions.
Stay on Part 101 if you are doing:
- Real-estate and property photography with owner consent
- Standard aerial video for tourism, marketing, or events (with per-person consent for anyone in shot)
- Roof, gutter, and small-structure inspection with property-owner consent
- Rural land mapping under 120 m with landowner consent
- Basic construction progress capture on your own site
- Small-scale conservation monitoring on private land
Plan for Part 102 if you are doing:
- Agricultural spraying or seed-spreading — always Part 102, always requires agrichemical rating
- Powerline, pipeline, or rail corridor inspection at any meaningful scale — BVLOS drives this
- Solar-farm thermal inspection at utility scale where flight lines cross site boundaries or require higher altitude
- Quarry and mine volumetric surveys using platforms above 25 kg or beyond VLOS
- Emergency-response and search-and-rescue support to public agencies
- Security and surveillance work where crowds, urban environments, or night operations are in scope
- Government contract work where the procuring agency requires evidence of a UAOC
- Any operation involving a drone above 25 kg
If your operation is a mix — mostly Part 101 with occasional Part 102 needs — the pragmatic answer is often to engage a certificated operator for the exception work rather than pursuing your own UAOC until the volume justifies it. That is one of the reasons the New Zealand Part 102 operator base exists as a services market.
Frequently asked questions
Do I need a CAA licence to fly a drone commercially in New Zealand?
No — not if your operation fits within Part 101. New Zealand permits commercial drone work under Part 101 without any CAA certificate, provided you comply with all Part 101 rules. You only need Part 102 certification if your operation exceeds those limits.
What is the maximum drone weight under Part 101?
Under 25 kg. Aircraft weighing between 15 kg and 25 kg additionally require airworthiness certification. Anything above 25 kg requires Part 102 approval.
Can I fly BVLOS under Part 101?
Only in the narrow case of a shielded BVLOS operation conducted in accordance with CATI 101-1. Any other beyond-visual-line-of-sight operation requires Part 102 certification.
Can I fly at night under Part 101?
Only shielded night operations conducted in accordance with CATI 101-1 and by an operator who has completed training acceptable to the Director. All other night operations require Part 102.
How long does Part 102 certification take?
For a first-time applicant with a straightforward scope, budget 6 to 9 months from decision to first approved flight. Novel or high-risk operations take longer and may be routed through CAA’s Emerging Technology Programme.
How much does Part 102 certification cost?
There is no fixed fee. CAA assesses applications on time incurred at the published hourly rate, and total cost depends on the complexity of your exposition and the risk profile of your operations. Realistic first-time budgets — including exposition development, CAA fees, and initial training — commonly reach five figures.
Does Part 102 override Part 101?
No. Part 102 grants specific exemptions from Part 101 rules, as detailed in your exposition and operations specification. Everything outside those specific exemptions still runs under Part 101.
Do I need Part 102 for agricultural spraying?
Yes. Aerial spraying, topdressing, and dispersal of vertebrate toxic agents are prohibited under Part 101 regardless of scale. All agricultural spraying by drone in New Zealand requires Part 102 plus the applicable agrichemical rating.
Is drone registration mandatory in New Zealand?
Not as of 2026. CAA has indicated a registration system is planned but no date has been announced. Voluntary registration through AirShare is strongly recommended, particularly for commercial operators.
Does Part 102 mean I can fly anywhere in New Zealand?
No. Your UAOC authorises the specific operations, aircraft, and (in many cases) geographical areas described in your exposition and operations specification. Adding scope generally requires an exposition amendment.
Next steps
Deciding between Part 101 and Part 102 is a procurement decision as much as a compliance decision. If you are scoping a drone programme — for a farm, an energy asset, a construction portfolio, a council contract, or a public-safety agency — the cleanest path is usually to define the operation first, then work backwards to the ruleset it requires.
Cybotix designs and manufactures purpose-built drone platforms in New Zealand and supports commercial and public-sector clients across surveying, agriculture, infrastructure inspection, energy, conservation, defence, and search-and-rescue. Whether your operation fits inside Part 101 or needs a Part 102 certificate, we can help you scope the platform, the sensors, and the operating framework around it.
- Explore the Cybotix Drone Division →
- Learn about our Custom Drone Development & OEM Manufacturing →
- Review our BVLOS & Secure Comms capability →
- See our Drone Pilot Training & Support →
- Or contact us → to discuss a specific operation.
Authoritative sources:
- Civil Aviation Authority of New Zealand — Part 101 rules for drones
- Civil Aviation Authority of New Zealand — Part 102 Unmanned Aircraft Operator Certification
- Civil Aviation Rules Part 102 Consolidation, 22 December 2025
- Advisory Circulars AC101-1 and AC102-1
- CATI 101-1 — Civil Aviation Transport Instrument for Part 101
This article is general information for operational planning and procurement, not legal or aviation-safety advice. Always confirm current rules with CAA and, for high-consequence operations, engage a qualified aviation-safety consultant or certificated Part 102 operator.
Last updated: 2 September 2026.