What Remote ID Still Requires on a Part 107 Flight

I'm Tom Dowell. I fly commercially out of Springdale, Arkansas, for Drones Inbound, and I have held a Part 107 certificate for eight years. This is a law explainer, not legal advice. On a Part 107 flight, Remote ID is still a condition of being in the air. Start with the FAA's Remote Identification of Drones page. Other federal drone rules on this site live at DroneLaws.us /federal.

The rule is 14 CFR Part 89

Remote identification of unmanned aircraft is 14 CFR Part 89. The operating hook is § 89.105. After September 16, 2023, no person may operate an unmanned aircraft in the airspace of the United States unless the operation meets § 89.110 or § 89.115, except as the Administrator authorizes or as § 89.120 provides.

The FAA states the coverage in one sentence: drones that are required to be registered, or that are registered — including those flown for recreation, business, or public safety — must comply with the Remote ID rule. Part 89 does not ask whether the flight feels "commercial enough." It asks whether the aircraft had to be registered, or already is.

The registration trigger is 14 CFR § 48.15

14 CFR § 48.15 is what decides whether that aircraft must be registered. You may operate a small unmanned aircraft without registration only if it is operated exclusively under 49 U.S.C. 44809 and weighs 0.55 pounds or less on takeoff, including everything on board or attached — or if it is an aircraft of the Armed Forces. The FAA restates the civilian line as: all drones must be registered except those that weigh 0.55 pounds or less (less than 250 grams) and are flown under the Exception for Limited Recreational Operations.

Two consequences follow.

First, any Part 107 flight is outside that exception. The same Mini-class airframe used to inspect a roof, map a lot, or film a job is not a recreational flight. Register it as a Part 107 aircraft. Once it is required to be registered, or is registered, Part 89 applies. Second, if a sub-250-gram recreational aircraft is registered anyway, Remote ID attaches to that registration. The exception is for aircraft that stay unregistered and stay inside 44809. It does not follow the airframe onto a Part 107 job.

The FAA registration page says failure to register a drone that requires registration may result in regulatory and criminal penalties. That page does not publish a Remote ID fine schedule, and this post will not invent one.

Part 107 registration is per device

The FAA says recreational drone pilots may register once and apply that registration number to all the devices listed in their inventory. During that registration they must list the serial number of each Standard Remote ID drone and each FAA-accepted broadcast module.

That is not the case for Part 107. The FAA's wording is specific: Part 107 pilots "must register each individual device (Standard Remote ID drone or Remote ID broadcast module) separately within their inventory and each device will be assigned a unique registration number." You do that in FAADroneZone, on the Part 107 dashboard.

The FAA registration page says drones registered under the Exception for Limited Recreational Operations cannot be flown under Part 107, and a registration cannot be transferred between those two operation types.

Three lawful paths

Part 89 gives you three ways to comply. The FAA lists the same three.

1. Standard Remote ID drone

A Standard Remote ID drone is produced with built-in FAA Remote ID broadcast capability. Under § 89.110, from takeoff to shutdown it must broadcast the message elements in § 89.305: the aircraft's identification; its location, altitude, and velocity; the control station's location and altitude; emergency status; and a time mark.

The serial number must appear on an FAA-accepted declaration of compliance, or the aircraft must have a part 21 design or production approval. The equipment must work and must not be disabled. The Certificate of Aircraft Registration must include that serial number. If the broadcast stops, § 89.110 requires landing as soon as practicable.

2. FAA-accepted broadcast module

This is the retrofit path: an FAA-accepted broadcast module on an aircraft that was not built as Standard Remote ID. Under § 89.115(a), from takeoff to shutdown the module broadcasts the § 89.315 elements: the module's serial number; the aircraft's location, altitude, and velocity; the takeoff location and altitude; and a time mark.

A module broadcasts takeoff location, not the live control-station location that Standard Remote ID sends. Two operating limits matter on a job. The person manipulating the controls must be able to see the unmanned aircraft at all times — § 89.115(a)(2)(ii) — so an FAA-accepted broadcast module does not authorize a beyond-visual-line-of-sight operation. Confirm the module is functioning before takeoff, and land as soon as practicable if the broadcast fails. The module serial number must be listed on an FAA-accepted declaration of compliance and on the aircraft's registration.

3. FAA-Recognized Identification Area (FRIA)

A FRIA is a defined geographic area where you may fly without Remote ID equipment. Under § 89.115(b), both the aircraft and the person at the controls must remain inside the FRIA for the entire operation, and the pilot must be able to see the aircraft the entire time. Only FAA-recognized community-based organizations and educational institutions may apply. The FAA publishes approved locations on its UAS Data Delivery System.

A FRIA is a real third path and a rare commercial one. Club fields and school sites are not a roof in Springdale. The FAA also notes that a Standard Remote ID drone or an FAA-accepted broadcast module still has to broadcast inside a FRIA.

The Letter of Authorization is still on the FAA page

The FAA Remote ID page still says some operators may request a Remote ID Letter of Authorization to operate without Remote ID or to deviate from the requirements. The FAA issues those for aeronautical research, to show compliance with regulations, and for some operations such as drone light shows conducted under an FAA-issued waiver. Requests go to RIDAuthorizations@faa.gov. Section 89.120 is the research and compliance-demonstration authority. That is not a substitute for ordinary Part 107 work.

What this looks like before you launch

On a typical Part 107 job I treat Remote ID as part of the preflight. Confirm the aircraft, or the FAA-accepted broadcast module, is on an FAA-accepted declaration of compliance. Confirm the Remote ID serial number is on the Part 107 registration for that device, not on a recreational inventory. Confirm the broadcast is functioning before takeoff. If it dies in flight, land as soon as practicable. If you are on a module, stay visual. The FAA also requires the registration certificate in your possession and the registration number on the aircraft. Those are part 48 duties, but they travel with the same § 48.15 registration that triggers Remote ID.

Part 89 is federal. More federal material on this site is at DroneLaws.us /federal. Remote ID is not the FCC import docket; that walkthrough is How to File an FCC 26-189 Comment.

Primary sources

• FAA, Remote Identification of Drones
• 14 CFR Part 89, including §§ 89.105, 89.110, 89.115, and 89.120
• FAA, How to Register Your Drone
• 14 CFR § 48.15
• FAA, FAA-Recognized Identification Areas
• FAA-accepted Remote ID declarations of compliance

This is general information about federal operating rules, not legal advice. We are not affiliated with the FAA. Verify the primary sources before you fly.