Twelve nautical miles from the UK coast, the legal question changes. A domestic drone authorisation that matters inside UK sovereign airspace does not simply stretch across the line into the high seas. Yet aircraft still share the sky there, and the UK remains responsible for providing air traffic services in parts of the North Atlantic.

That mismatch is the subject of a current UK Civil Aviation Authority consultation. In CAP3312, published on 28 September 2026, the CAA proposes an interim process for coordinating civil unmanned aircraft system activity over the high-seas portions of the London, Scottish and Shanwick Oceanic Flight Information Regions. The consultation is open until 8 November 2026.

The proposal is narrow but important. It is not a new offshore drone licence, and it is not a claim that the UK can extend its domestic rules indefinitely over the ocean. It is an attempt to make non-certified drone activity visible to air traffic authorities so that hazards can be assessed and, where necessary, coordinated with other airspace users.

Why the 12-nautical-mile line matters

For this consultation, the CAA defines the high seas as waters beyond 12 nautical miles from the nearest shoreline. Inside that boundary, UK domestic law provides the familiar open, specific and certified-category framework. Beyond it, the CAA says UK operational authorisations issued under domestic UAS legislation are neither required nor legally effective for operations conducted wholly over the high seas.

That does not mean the airspace is unmanaged or that an operator can ignore aviation safety. A Flight Information Region, or FIR, identifies an area in which a state has accepted responsibility for air traffic services; it is not the same thing as national territory. NATS describes Shanwick Oceanic as a roughly 700,000-square-mile FIR over the North East Atlantic, illustrating how far an air traffic service responsibility can extend beyond the coastline.

The CAA’s full CAP3312 consultation document says the UK cannot apply its domestic UAS regime beyond sovereign airspace, but it has obligations under the Chicago Convention and ICAO Annex 11 to coordinate activities that may be hazardous to civil aircraft within the FIRs for which it provides air traffic services.

The key distinction: sovereignty answers who can make domestic rules; an FIR answers who provides air traffic services. Crossing the territorial boundary changes the first answer without erasing the second.

The activity is no longer theoretical

The CAA says drones are already used, or proposed for use, in offshore infrastructure inspection, survey, research and environmental monitoring. It cites UK operational authorisations held by organisations working for offshore oil, gas and renewable-energy companies, as well as enquiries from UK and foreign operators about high-seas flights.

These missions can involve long routes, beyond-visual-line-of-sight operations and flight profiles that are very different from a small recreational flight near the coast. The policy problem is not simply whether the aircraft can make the journey. Air traffic service units need to know where the activity will occur, at what altitude, for how long and what happens if control, communications or recovery does not proceed as planned.

At present, the CAA says there is no agreed UK process for notifying and coordinating this kind of non-certified UAS activity in high-seas portions of UK-delegated FIRs. The authority also says ICAO has not yet provided a practical authorisation pathway for operations broadly equivalent to the open or specific category over the high seas.

What the CAA is actually proposing

The proposed interim model has three parts:

1. Treat the activity as a potential aviation hazard for coordination purposes. All UAS activity in the relevant high-seas portions of UK-delegated FIRs would be regarded as “potentially hazardous to civil aircraft” under the Annex 11 coordination framework.
2. Ask operators for information in advance. Operators would provide a defined set of operational details before the flight.
3. Choose proportionate airspace measures. The CAA, working with NATS and other relevant parties, would decide whether the activity needs only promulgated information, coordination through existing structures or a more formal airspace measure.

The CAA says the process would be described in a new section of the UK Aeronautical Information Publication. Depending on the operation, possible measures could include a Notice to Aviation, use of existing airspace structures or the establishment of a danger area through the airspace-change process.

That language matters. The proposal does not say every offshore drone flight will create restricted airspace. It says the information supplied should support a hazard assessment from which a proportionate response can be selected.

A notification would need more than a map pin

CAP3312 lists the kinds of information likely to matter: the nature of the activity, geographical area, altitudes or flight profile, planned dates and times, and how the aircraft will be controlled and recovered. The consultation also points to communications arrangements, contingency procedures, duration and other operational details.

This is more than administrative detail. A coordination measure is only as useful as the assumptions beneath it. If an operator supplies an incomplete route, an unrealistic altitude band or a contingency plan that does not match the actual system, the airspace picture can be misleading even though a notification exists.

The CAA therefore raises a harder question: how authorities can have reasonable confidence that submitted information reflects what will happen in practice. It suggests that operator engagement, clarification and learning after an activity may all be necessary, while stopping short of proposing a new offshore approval and oversight regime.

Operational inference: teams considering high-seas work should treat the data package as part of the safety case, not as a form to complete after the mission has already been designed. Route geometry, altitude, communications, recovery and contingencies need to agree with one another.

What an existing UK authorisation can—and cannot—do

The consultation draws another useful line. A UK operational authorisation for similar work in sovereign airspace may provide evidence about an operator’s systems, procedures and competence. The CAA could consider that evidence when assessing a potential hazard.

But the authorisation would not itself extend offshore or become an approval for the high-seas segment. In other words, evidence can travel farther than the legal effect of the document.

This is easy to misunderstand because “UK-delegated FIR” sounds like “UK airspace”. It is safer to separate three questions:

• Which state’s domestic UAS rules apply to the aircraft and operator?
• Who is responsible for air traffic services in the FIR?
• What coordination is needed to protect other aircraft during this operation?

CAP3312 mainly addresses the third question. It does not settle every issue of aircraft registration, operator oversight, insurance, radio licensing, maritime access or the rules that may apply to a launch or recovery point.

This is a consultation, not a rule already in force

As of 14 October 2026, the CAA is asking for views; it has not presented the proposed process as an implemented authorisation system. The consultation asks whether respondents agree that high-seas UAS activity should be treated as potentially hazardous for coordination, whether operators should provide basic information in advance, and what further views stakeholders have on the approach.

That status should guide practical decisions. Operators should not invent a submission route based on a proposal, assume that a future AIP section already exists or describe coordination as permission. They should use current official channels for a planned operation and obtain competent legal and operational advice for the jurisdictions, aircraft registration and mission involved.

What offshore operators should prepare now

Even before the consultation closes, CAP3312 offers a useful checklist for mission design:

1. Mark the jurisdictional boundary. Identify launch, recovery and every route segment relative to territorial waters; do not treat the whole mission as one undifferentiated legal area.
2. Build an exact operating volume. Record coordinates, altitude bands, dates, times and duration, including credible deviations and contingency areas.
3. Explain command, communications and recovery. State how the aircraft is controlled, how contact is maintained and what happens after a lost link, navigation problem or aborted recovery.
4. Map the air traffic interfaces. Identify the relevant FIR and air traffic service parties rather than assuming that distance from land means distance from aviation traffic.
5. Keep evidence and legal effect separate. Use an existing authorisation or safety case as supporting evidence where relevant, but do not claim that it approves a segment outside its jurisdiction.
6. Recheck the final policy. The consultation may lead to revised details, AIP text or guidance. A plan based on the September proposal will need another review before execution.

The larger lesson: coordination is not permission

The CAA’s proposal exposes a recurring problem in drone regulation: one document rarely answers every operational question. An aircraft may be registered in one state, launch from another legal jurisdiction, enter a delegated FIR and rely on an air traffic service provided by a third party under international arrangements.

For high-seas operations, the UK proposal tries to address the airspace-coordination piece without pretending to create sovereignty where it does not exist. Its value will depend on whether the final process is clear enough for operators to use, detailed enough for a credible hazard assessment and proportionate enough not to turn every mission into a bespoke airspace project.

Those are the questions the consultation leaves open. The important point for operators today is simpler: beyond 12 nautical miles, “I have a UK operational authorisation” is not the end of the analysis.

Scope note: This article reports and interprets the UK CAA’s CAP3312 consultation, rechecked on 14 October 2026. It is not legal advice, does not claim the proposal is already in force and does not report any flight testing or operational experience.