There are some important things you need to consider when applying for a Part 102 certificate.

3 Nov 2023 update: The Part 102 Certification team has released some additional information related to the XAG P100 Pro aircraft. Please read this in the dropdown below.

The Civil Aviation Authority’s Part 102 Certification team has recently assessed the XAG P100 Pro Agricultural Aircraft for use in New Zealand.  In doing so it became apparent that there are some reasonably significant changes in design between the XAG P100 and the XAG P100 Pro; including folding rotor arms and teeter rotor assemblies.  An industry specialist inspection report suggested that particular attention should be given to the differences these new elements introduce, especially for those operators who have been operating the XAG P100.

It is common practice for the Part 102 team to issue a 'series' approval for certain aircraft types on the Part 102 certificate Operations Specifications document.  This has been the case for the XAG P100 series to date. We have been able to consider this because the series of aircraft have generally remained very similar in form and function.  More significant changes to an aircraft’s airframe design has tended to result in the manufacturer giving the new aircraft a completely new model name. However in this case, XAG has introduced these pronounced design changes but kept the P100 name. 

Because of the differences between the original XAG P100 and their new P100 Pro, the Part 102 Certification team is NOT prepared to approve the XAG P100 Pro as part of an ‘XAG P100 series’ without a small but important amendment to the operational procedures.  This change is needed to ensure appropriate attention to the design changes with the XAG P100 Pro have been included.  The Part 102 Team will amend the wording on the Operations Specification documents going forward to reflect this change.

Your action

We expect any operator wanting to add the XAG P100 or XAG P100 Pro to be aware of this situation and to amend their exposition as outlined below.

The following safety mitigations have been recommended by an industry specialist and accepted by CAA as expected (best) practice for the XAG P100 Pro aircraft:

  1. The exposition procedures include the rotor arm locking mechanism being confirmed to be in the correct and fully locked position prior to flight.
  2. The exposition maintenance program includes that all maintenance touch points (such as pre, post, periodic inspections) inspect the rotor teeter full stop position for any signs of excessive wear, damage, metallic debris or cracking. This stop position is metal on metal in this design.
  3. The exposition, if referring to or re-producing the XAG P100 manufacturers maintenance programme, has been updated to reflect the changes that have been made by the manufacturer at the release of the XAG P100 Pro.

Thank you for your consideration. Any questions can be emailed to

Before getting started, make sure you've read the information on Intro to Part 102 certification for unmanned aircraft.

Top tips from the team

Here are some helpful tips to help you with the application process.

Read the application form [DOCX 68 KB] carefully and fill out each section. Make sure to sign where you need to (this is often missed by applicants).

Reading Advisory Circular (AC) 102-1 Unmanned Aircraft - Operator Certification will provide additional information about what is required for Part 102 certification.

If your exposition writer fills out the form for you, you need to ensure that it’s what you expect and you understand what you're applying for - before signing and submitting it. Your manual content and application form requests need to match.

Make sure your fit and proper person (FPP) questionnaire (CAA24FPP [PDF 1.8 MB]) is completed in full. Also, check that your proof of identification and address for service are signed by your nominated referee.

Note: If you're applying for a renewal, you only need to supply a new declaration (24FPPDec [PDF 1.3 MB]) and updated CV (this is as long as the you've completed a full FPP within the previous five years).

Before submitting your application, double-check that you have included the matrix and manuals that you may need to include.

When you apply, your documentation is checked for completeness and that all initially required documents have been provided; not their quality. So, ensuring your documentation is ready for assessment when we review your application is vital to save you and us as much time as possible. Keep in mind that assessment of manuals incurs an hourly fee, so, the more complete your information, the lower costs you're likely to incur.

If you write your own exposition

CAA is developing a number of Sample Expositions that will illustrate the level of detail you will need to cover for a particular type of operation and organisational complexity. Check out our Sample Expositions section to see if any fit your circumstances.

If your operation is beyond the scope of our Sample Expositions, be aware that without any prior aviation industry and/or technical writing experience, your exposition may require significant corrections or could be rejected if not complete. Time spent by CAA inspectors on your application is chargeable, so it can mean your assessment becomes more costly.  Using OneReg (see below) may help you avoid making errors when writing your exposition. 

If you write your own exposition, even if based on a CAA Sample Exposition, here are some extra tips:

  • Read the rules (Part 101 and Part 102) as well as the Part 102 matrix, and advisory circulars (AC101-1 and AC102-1).
  • There is a list of headings at this link. [DOC 872 KB] These are guidance of what may be included – include only what is relevant to your operation. It does not have to be in that order, this is a start point.
  • An exposition is (mostly) an operational manual, so we suggest writing your manual in the tense of ‘this is what we do’. Have a new employee in mind while writing the manual – what do they need to know about the organisation or how it conducts it's operations? Could they pick up the manual and understand what they need to do to conduct any of the operations that the organisation performs?
  • Avoid simply copying and pasting the various rules into your manual – instead we need you to provide the procedures your organisation will follow to ensure you’ll comply with the rules.
  • After you write your manual, complete the Part 102 matrix [DOC 133 KB] - this need to be completely filled out before being submitted. You need to fill out the matrix, providing instructions on exactly where in the exposition manual the inspector will find the information. If the matrix isn't completed in full, we're likely to reject, or put your assessment on hold, until you do so. If references aren't correct, you will need to resubmit your matrix. We have often found that over time, expositions prepared by an exposition writer change, but the matrix isn't updated to reflect those changes. So, the inspector is directed to the wrong page in the exposition and then has to go hunting for the correct page. This is frustrating and adds time to the assessment, and therefore increases the cost to you, as the applicant.
  • Keep it simple! Expositions for most Part 102 operators should be concise, and shouldn't require a suite of different manuals. It's okay to have more than one document as part of your exposition, but this is not often required.
  • It's also okay to refer to other documents such as manufacturers maintenance manuals in your exposition. We'll ask to see any external documents you reference in your manual, but they do not all need to be contained in your manual.
  • Completing a drone training course can assist you in writing a manual – as it helps you to understand the rules.


OneReg(external link) is an independent company that has developed an exposition creation and management portal which has been customised for Part 102 applications with the aim of making it easier for participants to meet their regulatory requirements. This includes making submissions or applications to participating regulators. In a non-exclusive arrangement, the Authority will allow participants to submit their expositions via OneReg if they choose to do so. There is extra cost when you use this service but it may reduce the time spent (and cost) assessing your application. Using OneReg doesn’t give you preferential placement in the application queue.

If you hire an exposition writer

If you hire an exposition writer, it's more likely to be a smoother assessment process, however each manual must be tailored to reflect your organisation's specific way of operating, so some changes may still be required during the assessment process.

When working with an exposition writer, you're not required to adapt your application to their standard exposition template. You need to make it clear to the writer about the type of operations you'll be conducting, and have the writer modify the exposition to reflect exactly how you'll be operating. We're seeing some applications where the writer is adapting applications to fit their standard exposition version; whereas the exposition writer should be altering each manual to fit the specific circumstances for each applicant.

Remember that if you have someone else write your exposition, you still need to understand it completely - this is very important.

In this section you'll find sample expositions and explanatory notes that describe the use cases that can be used under the sample expositions.

102SE001 Operations Manual [DOCX 172 KB] (sample exposition for real estate type operations using commercial off the shelf UA)

102SE001 Explanatory Note [PDF 200 KB] (provides more detail of the type of operations that can be used under this sample exposition)

102SE001 Annex A Fit to Fly [DOCX 579 KB]

102SE001 Annex B Planning and Operational Risk Assessment [PDF 1.1 MB]

102SE001 Annex C Property Owner/Occupier Notification Form [DOCX 30 KB]

Before you purchase high value aircraft or equipment, be aware that if they are new to New Zealand (e.g. unique, first of type, or first of use), more assessment will be required. We cannot say if we'll accept the craft(s) for the use you intend until we assess your application.

Also, keep in mind that as we're experiencing a high number of applications, there could be several months delay. So please take this into consideration before committing to purchasing or financing aircraft and equipment.

The Prime Person in your organisation must be able to demonstrate they have sufficient knowledge and understanding of their exposition and the rules. You'll be interviewed by an inspector to determine whether or not you have the required knowledge and experience to hold this important role. A Part 102 training course with an approved training provider can assist. Consider the timing of that training so it can still be fresh in your mind. Also consider that most training organisations offer tailored training on request.

The CAA Good Aviation Practice booklet How to be a senior person [PDF 787 KB] will assist further.

If what you're applying to do is new to New Zealand, unique, first of type, or first of use case, there will be more work to do. As the scale, complexity, air, or ground risk increases so too does the assessment process, the requirements on the applicant, and the time and cost involved.

CAA is in the early stages of setting up an Emerging Technology Programme to help guide applicants with these sorts of applications. The aim is to ensure that information sent for Certification is sufficiently mature and that applicants have a firm understanding of how the aviation system and approval processes work. Having a firm idea of your trialling and development timelines, goals, milestones and necessary enablers will greatly assist CAA in providing this guidance. If you think that your application may benefit from such engagement, please mention this at your first interaction with the 102 Cert Team.

Not only is your manual assessed, but the combination of craft(s) you intend to use, where, for what purpose and when you intend to use them. That's why no two applications are the same.

If you're using an exposition writer, they'll likely provide some guidance as to the complexity of what you're applying for.

You may have heard that the CAA asks for a JARUS SORA (specific operations risk assessment) for complex operations. This is the case for some very complex applications - like BVLOS and large drones. At this time it is by request once we start on your application, so you don’t need to do it unless you're asked for it.

Read more about JARUS SORA(external link)

If you have been told by CAA that you need to complete a formal risk assessment with your application and you are going to use JARUS SORA, then this spreadsheet is designed to assist you through the JARUS SORA steps. The spreadsheet is an additional tool, it does not replace creating your JARUS SORA assessment document (sometimes called a SORA Safety Portfolio) and it should be provided alongside your SORA document(s) if you use it. There are instructions for the spreadsheet on the first tab within it. This tool is designed to assist the applicant to be clear on their intentions and claims at each SORA step and to give the applicant a place to capture references to where in their documentation each SORA requirement is evidenced. This assists the applicant to ensure they have provided all required evidence in their SORA document. This also greatly assists the CAA assessor(s) to navigate your SORA document(s).

24102-04 - Part 102 SORA assessment workbook (for use with JARUS SORA Risk Assessment only) [XLSX 247 KB]

You must supply all documents at the time of application, but due to delays in your application being processed, we understand that some things can change during that time. This could even just be your contact information - do let the team know if your contact details change while you're waiting.

We'll contact you when we start on your assessment. One question we'll ask is "has anything changed since you submitted your application?" If something has changed, we'll work with you to incorporate those changes before assessing what you've provided.

So, purchasing the new model craft, or getting two craft instead of one, having a different pilot, etc, are all ok, and will not put you back in the application queue.

Once we start assessing your application, please be ready to take the time to provide information promptly when asked, and work with the team.

Stopping and starting the assessment can lead to additional time and therefore additional cost.

If you aren't ready to proceed when your application is assigned to an inspector for assessment, please let us know, so your application can be placed on hold without it going to the back of the queue. We'd much prefer not to start your assessment, then have to stop part-way through because you have other commitments.

Ask us about certification

If you have any questions about this topic, email