Drone flights over the high seas: CAA proposes a new UK coordination process

The UK Civil Aviation Authority has opened a consultation on how civil UAS operations over the high seas should be coordinated when they take place within areas where the UK provides air traffic services.

The proposal is set out in CAP3312, Consultation: Civil UAS Flights over the High Seas.

It addresses a gap which becomes important when an offshore drone operation goes beyond UK territorial waters. UK domestic UAS rules apply within UK sovereign territory, but they do not simply continue indefinitely out to sea.

The CAA is proposing an interim process under which operators would provide information before flying in the high-seas parts of UK-delegated Flight Information Regions. The CAA, working with NATS and other relevant organisations, would then decide whether any airspace coordination measures are needed.

The consultation opened on 28th September 2026 and closes on 8th November 2026.

What are the high seas?

For this proposal, the important boundary is the edge of UK territorial waters.

The UK's territorial sea generally extends to 12 nautical miles from the relevant baselines around the coast. Within that area, the UK has sovereignty and can apply its domestic aviation law.

Beyond territorial waters, the airspace is no longer UK sovereign airspace simply because it sits inside a Flight Information Region managed by the UK.

That distinction is central to CAP3312.

The UK is responsible for providing air traffic services in large areas extending beyond its territorial waters, including high-seas parts of the London, Scottish and Shanwick Oceanic Flight Information Regions.

A Flight Information Region, usually shortened to FIR, is an area in which a state has responsibility for providing particular air traffic services. It does not give that state sovereignty over the airspace.

So an aircraft can be outside UK sovereign airspace while still flying in an area where the UK has accepted responsibility for air traffic services.

Why a UK Operational Authorisation is not enough

Within the UK, many higher-risk civil drone operations take place in the Specific Category under a CAA Operational Authorisation.

That authorisation is issued under UK domestic law.

CAP3312 explains that UK domestic UAS legislation cannot provide the legal basis for an operation conducted wholly over the high seas. A UK Operational Authorisation is therefore not, by itself, an authorisation to conduct the high-seas part of a flight.

This does not mean an existing Operational Authorisation becomes irrelevant.

The procedures, competence standards, aircraft information and safety evidence behind an existing authorisation may still be useful when considering the wider operation. The legal basis is simply different once the aircraft has left UK sovereign airspace.

For a flight which starts in the UK and continues offshore, the UK Operational Authorisation can still apply to the part of the operation conducted within UK sovereign airspace. The high-seas part then needs to be considered under the applicable international framework and any coordination arrangements in place.

Why there is a gap

Civil UAS are already being used offshore for work such as infrastructure inspection, surveys, environmental monitoring and activity supporting offshore energy.

Some of those operations extend, or may in future extend, beyond UK territorial waters.

The difficulty is that the international aviation framework was largely written around conventional crewed aircraft.

Over the high seas, the Chicago Convention and the International Civil Aviation Organization's Standards and Recommended Practices become particularly important. ICAO Annex 2 contains the Rules of the Air, while Annex 11 deals with Air Traffic Services.

ICAO has recognised that the existing framework does not provide a straightforward route for the types of non-certified UAS that would normally operate in the Open or Specific Category within a state's sovereign airspace.

At the same time, the UK has responsibilities for the safety of civil aviation in the high-seas parts of FIRs where it provides air traffic services.

The CAA says UAS activity is already taking place in those areas, but there is currently no agreed UK process for notifying and coordinating that activity.

CAP3312 is intended to create an interim answer to that problem.

What the CAA is proposing

The proposed process has three main parts.

First, the CAA would treat non-certified UAS activity in the high-seas areas of UK-delegated FIRs as an activity potentially hazardous to civil aircraft for coordination purposes.

That does not mean the operation is considered unsafe. It is the mechanism the CAA proposes to use under the international air traffic services framework so that the activity can be coordinated with other airspace users.

Second, operators planning to fly in these areas would be expected to provide a defined set of information before the operation takes place.

Third, CAA Airspace Regulation would use that information, working with NATS and other relevant parties, to decide what coordination measures are necessary.

The CAA proposes to publish the eventual process in the UK Aeronautical Information Publication, normally called the UK AIP.

What airspace measures could be used?

The proposal does not assume that every offshore UAS operation will need its own block of segregated airspace.

Instead, the CAA would consider what is necessary for the particular operation.

CAP3312 identifies possible measures such as publishing information about the activity, using existing airspace structures or establishing Special Use Airspace through the airspace change process where required.

That could include a Danger Area.

A Danger Area is a defined volume of airspace within which activities dangerous to the flight of aircraft may exist at specified times.

Danger Areas are already used for some UAS operations where the nature of the activity requires other airspace users to be warned or managed appropriately.

The new proposal would provide a more consistent route for deciding what is needed when the UAS itself is operating over the high seas.

This is coordination, not a new offshore Operational Authorisation

One of the most important distinctions in CAP3312 is between regulatory authorisation and airspace coordination.

The CAA is not proposing to extend the UK Specific Category or the Operational Authorisation system beyond UK territorial waters.

Instead, it is proposing a process for coordinating civil UAS activity in high-seas airspace where the UK is responsible for providing air traffic services.

That matters because a UK-delegated FIR should not be treated as if it were simply an extension of UK sovereign airspace.

The CAA would use the information supplied by the operator to decide what needs to happen from an airspace and civil aviation safety perspective.

Responsibility for the aircraft and operation under the international framework can also involve the State of Registry and, where different, the State of the Operator.

What if the drone enters another country's airspace?

CAP3312 concerns high-seas airspace within UK-delegated FIRs.

It does not provide permission to enter another country's sovereign airspace.

If a UAS leaves the high seas and enters the territory or territorial waters of another state, the requirements of that state also need to be considered. International operations may therefore involve several different legal and operational stages during the same flight.

For example, a flight could involve:

1. UK domestic requirements while operating within UK sovereign airspace.
2. High-seas coordination while operating beyond territorial waters in a UK-delegated FIR.
3. The requirements and authorisations of another state if the aircraft enters that state's sovereign airspace.

A single UK Operational Authorisation should not be assumed to cover all three.

Who could be affected?

The proposal is most relevant to operators planning longer-range offshore flights.

The CAA specifically identifies activity including offshore infrastructure inspection, survey work, research and environmental monitoring. Oil and gas and offshore renewable-energy operations are also relevant because the CAA says it is already seeing Operational Authorisations and enquiries connected with those sectors.

For many routine drone operations conducted entirely over land or within UK territorial waters, CAP3312 will have no direct effect.

It becomes important when the planned operating area extends into high-seas airspace.

Does this change the rules now?

No.

CAP3312 is a consultation document. The proposed process has not yet become the final UK arrangement.

The CAA is asking UAS operators, general aviation, air traffic service providers and other interested parties for feedback on whether the approach is effective, proportionate and workable.

The consultation opened on 28th September 2026 and closes on 8th November 2026.

After considering the responses, the CAA will need to decide the final form of the process before the proposed arrangements are reflected in the UK AIP.

Operators planning offshore activity should therefore continue to work from the regulatory and airspace arrangements that apply to their individual operation rather than treating CAP3312 as an approval route already in force.

Why CAP3312 matters

Long-range BVLOS operations are making offshore UAS activity more practical, but the legal framework changes once an aircraft leaves UK sovereign airspace.

CAP3312 is the CAA's proposed way of dealing with one part of that problem: how the UK should coordinate civil UAS flights over the high seas when they take place inside an FIR for which the UK provides air traffic services.

It does not create an offshore version of a UK Operational Authorisation and it does not remove the international rules that apply to aircraft over the high seas.

If adopted, it would give operators a published UK process for notifying planned activity and establishing what airspace coordination is needed before the flight takes place.

The consultation can be read and responded to on the CAA consultation page. The supporting proposal is published as CAP3312.