A proposed threshold can change the direction of regulation before it changes anyone’s legal duties.

Europe’s familiar 250-gram line may be about to become less important for some drone rules—but it has not disappeared, and a new 100-gram rule is not yet in force.

On 18 September 2026, the European Union Aviation Safety Agency published Opinion No 06/2026. EASA says the proposed amendments would lower the mass threshold for mandatory operator registration and direct remote identification from 250 g to 100 g. The package also proposes identity verification before registration and changes to the framework for national UAS geographical zones.

The word that matters is proposed. EASA’s page still labels the official publication status as “Pending.” The Opinion and accompanying draft regulations are inputs to the EU rulemaking process, not a notice that every 100–249 g drone must already comply today.

What the current rule actually says

Under the current version of Commission Implementing Regulation (EU) 2019/947, operator registration in the open category is not controlled by mass alone. Article 14 requires registration when an aircraft has a maximum take-off mass of 250 g or more—or can transfer more than 80 joules on impact—but it also has a separate trigger for an aircraft equipped with a sensor able to capture personal data, unless the aircraft complies with the EU Toy Safety Directive.

This is why a typical 249 g camera drone is not automatically registration-free. EASA’s current registration FAQ says an operator does not need to register only when a sub-250 g drone has no camera or other sensor able to detect personal data, or when the camera-equipped aircraft is a qualifying toy. EASA’s guidance for a 249 g DJI Mini makes the same point: the camera and non-toy status mean the operator must register.

Registration is generally for the operator, not an individual registration for every ordinary open-category drone. One operator number can cover the operator’s aircraft, subject to the applicable display and Remote ID requirements. Certified unmanned aircraft follow a different registration route.

That distinction is easy to lose in headlines. “Drone registration” is often used as shorthand, but the legal duty may attach to the person or organisation operating the aircraft.

Who could notice a new 100 g line most

If the proposal is adopted in its present form, the clearest new group would include operators of non-toy aircraft between 100 g and 249 g that currently avoid registration because they have no personal-data sensor and do not cross the existing mass or energy triggers.

For many consumer camera-drone owners, the practical registration change may be smaller than the headline suggests. A non-toy 249 g camera drone already brings its operator into the current registration system. The proposal does not create that camera rule from nothing.

Direct Remote ID is a separate question. EASA’s Opinion page says the proposed mass threshold for mandatory direct remote identification would also move from 250 g to 100 g. The precise effect will depend on the final implementing and delegated regulations, including which aircraft classes and operations are covered, transition dates, product obligations and any exceptions or alleviations.

A 100 g threshold would therefore not mean that every small flying object immediately needs the same hardware. A product’s class marking, the operation being conducted, whether it is a toy, and the final adopted text all matter. Model-aircraft associations may also receive specified alleviations under the proposal.

An EASA Opinion is not the finish line

EASA develops technical proposals and advice, but an Opinion does not by itself amend the regulations that operators must follow. The European Commission and the wider EU legislative process still have to turn a proposal into final legal text. The adopted act must then be published and its application dates identified.

Those steps can change details. A threshold may survive while scope, dates or exceptions change. A draft requirement may also be phased in differently for new products and existing aircraft.

Until final rules take effect, operators should apply the current regulation and the instructions of their national aviation authority. They should not remove an existing operator number because a proposal has appeared, and they should not assume a newly purchased 120 g aircraft already needs a Remote ID retrofit solely because of the Opinion.

Four checks before buying a very small drone

1. Check whether it has a camera or another personal-data sensor. Under today’s rules, this can trigger operator registration even below 250 g unless the aircraft is a qualifying toy.

2. Check the product’s legal status, not its marketing label. “Mini,” “pocket” or “toy-style” does not prove compliance with the Toy Safety Directive. Look for the manufacturer’s documentation and applicable class identification.

3. Separate registration from pilot competence and operating limits. An operator may need to register even when a particular sub-250 g operation does not require an A1/A3 online training certificate. Registration also does not grant permission to fly over assemblies of people, above the height limit or inside a restricted geographical zone.

4. Watch the effective date, not just the announcement date. If the 100 g proposal becomes law, the final regulation should state when obligations start and how existing aircraft are treated. That is the point to review firmware, Remote ID capability, operator-number entry and national guidance.

Geographical zones may change too

The mass threshold is the most visible part of Opinion No 06/2026, but it is not the whole package. EASA also proposes identity verification before operator registration and national conditions intended to make information about UAS geographical zones more accessible and consistent.

That does not turn a European registration number into universal flight permission. Member States can establish geographical zones and national conditions within the EU framework. Before each flight, a pilot still needs current local information from the competent national authority or its recognised service.

The proposal’s security objective also explains why traceability and identity verification appear together. Lowering a mass threshold is not only a technical judgment about kinetic energy; in this package it is part of a broader attempt to improve identification and enforcement while retaining risk-based safeguards and limited relief for lower-risk activities.

The practical answer for a 249 g owner today

If your 249 g drone has a camera, is not a toy and is operated in an EASA Member State, do not wait for a future 100 g rule to ask about registration. Current EASA guidance already says the operator normally has to register.

If your aircraft is between 100 g and 249 g and has no personal-data sensor, Opinion No 06/2026 is worth watching—but it is not a reason to invent a legal duty before the final regulation exists.

For both groups, the useful habit is the same: identify the current rule, the proposed change and the future effective date as three separate facts. That prevents a regulatory proposal from being mistaken for today’s law—and prevents the familiar 250 g label from hiding obligations that already apply.

Official references checked 28 October 2026

• EASA, Opinion No 06/2026 — Regular update of Regulations (EU) 2019/947 and (EU) 2019/945 — Security, published 18 September 2026.
• EASA FAQ, Do I need to register my drone?
• EUR-Lex, consolidated Commission Implementing Regulation (EU) 2019/947, Article 14.
• EASA, current open-category guidance and class-mark tables.