This blog is co-authored by Eric Geldenhuys, candidate attorney.

The Department of Transport’s Draft Airfreight Strategy, 2025 puts drones at the centre of a more efficient, and inclusive logistics system and signals concrete regulatory reforms that will reshape how unmanned aircrafts operate. The draft strategy maps the next phase of South Africa’s drone law evolution and its alignment with risk‑based, corridor‑driven operations. Existing legal duties under Part 101 of the Civil Aviation Regulations, 2011 remain in force.

What the Draft Aircraft Strategy proposes

The draft strategy reframes low‑altitude drone activity into dedicated unmanned traffic management. The draft strategy contemplates segregated, low‑level “UTM” corridors, coordinated with standard air traffic management, where drones would meet minimum communication and detect‑and‑avoid capabilities and remain visible to the Air Navigation Service Provider. Air Traffic and Navigation Services Company has been tasked by the National Airspace Committee to define drone innovation corridors as a testbed.

The draft strategy adopts a risk‑based operating model aligned with the Joint Authorities for Rulemaking on Unmanned Systems (JARUS), including the JARUS Specific Operations Risk Assessment Methodology under Action 21 through the recategorisation of drone operations. JARUS is an international group of aviation experts from regulatory bodies globally which develops harmonised technical, safety, and operational standards for drones to facilitate the integration of drones into global airspace. The alignment with JARUS would shift the regulatory framework from case-by-case exemptions and blanket prohibitions on certain operations towards predefined risk categories with matching mitigations, documentation, training, and oversight. Action 21 forms the foundation of Action 22 (creating integrated corridor operations within South African airspace) and Action 23 (for establishing a national registry, raising levies, and tracking drone operations).

The draft strategy endorses categorisation into Category A “open,” Category B “specific” and Category C “certified.” The strategy prioritises Category B delivery operations at low altitudes within the Unmanned Aircraft System Traffic Management (UTM). The implementation of these categories would include re-categorising operations to enable Beyond Visual Line of Sight (BVLOS), operations over people and carriage of objects.

The draft strategy proposes a full drone ecosystem. It envisages an electronic register for all Remotely Powered Aircraft Systems (RPAS) distributed or sold in South Africa, mandatory remote identification / tracking for non‑recreational unmanned aircraft, and a levy structure for commercial drones, with the Civil Aviation Authority (CAA) to design and maintain the register and the Department of Trade to promulgate fees and penalties.

The draft strategy points to cross‑sector updates, including spectrum allocation and type approval for command‑and‑control links, qualification alignment, and cargo security enhancements including “green channels.”

Interaction between the Strategy and current aviation law

The legal framework remains unchanged for now. Commercial, corporate, and non‑profit operations require an Unmanned Aircraft System Operating Certificate, and, for commercial operations, an air services licence. Airspace remains restricted by the relevant restrictions and BVLOS remain approval‑based and technically demanding. Pilots must carry and use air‑band radios outside Restricted Line of Sight (R‑VLOS) and comply with the Air Traffic Services Unit instructions.

Two 2025 technical refinements align with the Draft Airfreight Strategy’s operational vision. First, the Draft Comprehensive Civil Aviation Policy mandates an Airfreight Strategy and a proactive posture on emerging technology, including RPAS. Second, the proposed amendment to South African Civil Aviation Technical Standards (SA‑CATS) 175 adds a G‑series NOTAM (Notice to Airmen) for Unmanned Aerial Vehicles, RPAS, and model aircraft, improving filing and situational awareness for low‑level operations.

Practical Implications

For operators, the near‑term message is compliance continuity plus readiness.

(1) Maintain strict adherence to South African Civil Aviation Regulations Part 101 and SA‑CATS, particularly BVLOS and controlled‑airspace rules.

(2) Prepare to structure safety cases using a JARUS‑style approach for Category B approvals as Action 21 is implemented.

(3) Anticipate corridor operations and ensure equipment and procedures are compatible with UTM concepts, radio communications and detect‑and‑avoid.

Pending the implementation of the Draft Airfreight Strategy and potential corresponding amendments to aviation legislation, operators must comply with Part 101 and SA‑CATS, and plan for JARUS‑aligned, corridor‑based operations, remote identification, and a unified register.