The New Zealand Government has enacted reforms to reshape the regulatory landscape for unmanned and emerging aviation technologies. Building on an industry that contributed nearly half a billion dollars to the country's economy in 2024, the changes are designed to help realise the Government’s ambitious goal of doubling the sector’s size by 2030. 

These new changes create a bespoke regulatory environment that allows rapid iteration and testing of advanced and experimental aviation technology. Specifically, the reforms reduce red tape for specific unmanned aircraft operations and create special use airspace areas where new and developing technologies can be tested and evaluated. This offers an attractive launchpad for investors wanting a safe and secure environment to demonstrate proof of concept, validate performance in real world conditions, and accelerate commercial pathways.

What's changing and why it matters

Research and development certification scheme

Operators can apply for a research and development (R&D) certificate for up to 5 years to allow them to conduct research and development of aviation systems under part 107 of the Civil Aviation Rules. While certificate holders can only operate as specified in the certificate holder's specifications, research and development certificate holders will generally have privileges which will exempt them from complying with specific Civil Aviation Rules, including the rules for product certification, maintenance, unmanned aircraft operator certification, and agricultural aircraft operations. However, the R&D certificate comes with certain operational restrictions on the certificate holder such as the activity must only be conducted for R&D purposes, within specified airspace or geographic areas, and without carrying anyone other than flight crew or dangerous goods, among other restrictions.

Uncrewed aircraft regulatory pathways

New Zealand continues to regulate uncrewed aircraft through two main pathways. Aircraft under 25kg and lower risk operations are regulated under Part 101 of the Cival Aviation Rules whereas aircraft over 25kg and complex operations are regulated under Part 102. While this dual regulatory pathway has not changed, the particulars of these rules have. Specifically:

• Part 101 - low risk operations: agricultural spraying, topdressing, and vertebrate toxic agent application, while such activities were never allowed under Part 101, they are now explicitly prohibited to provide greater clarity. Operators wishing to conduct these operations must obtain a Part 102 certificate. 
• Part 102 - complex operations: amended to give unmanned aircraft operator certificate holders privileges which will exempt them from complying with specific Civil Aviation Rules (unless their exposition says otherwise). Like the privileges for R&D certificate holders, these exemptions are from the Civil Aviation Rules for product certification, maintenance, unmanned aircraft operator certification, and agricultural aircraft operations.

New regulatory tool: Transport instruments for unmanned aircraft

The reforms introduce a new “Transport Instrument” – CATI 101-1 in relation to unmanned aircraft operations which moves most technical details from Part 101 to this new transport instrument. This includes rules concerning right of way, night operations, aircraft mass limits, visual line of sight operation, aerodromes, and controlled airspace and other airspace matters. Transport Instruments are made under section 431 of the Civil Aviation Act 2023 and enables the Civil Aviation Authority (CAA) to outline detailed or technical instruments for certain aviation related requirements. This will enable CAA to be more responsive in updating technical requirements concerning unmanned operations as changes to Transport Instruments can occur more frequently than under standard rules. 

What are the implications of these changes?

These reforms position New Zealand as an increasingly attractive jurisdiction for technology development and deployment. The introduction of the R&D certification scheme provides innovators with up to five years of regulatory flexibility to test and refine cutting-edge aviation systems without being constrained by conventional certification requirements. This creates a compelling value proposition for international companies seeking to establish proof-of-concept operations in a jurisdiction that balances innovation with safety oversight. 

The reforms also align New Zealand with other major aviation jurisdictions, most notably the United States, where the Federal Aviation Administration (FAA) operates a Special Airworthiness Certificate for Experimental R&D. This FAA framework allows aircraft that cannot yet meet standard certification requirements to operate for R&D purposes, including testing new aircraft designs, equipment, installations, operating techniques, and novel uses of aircraft. By implementing a comparable R&D pathway, it enables New Zealand to become globally competitive in the multi-billion-dollar aviation R&D industry. These reforms are further strengthened by the shift of technical unmanned aircraft requirements into Transport Instruments, enabling the regulatory framework to be more responsive to industry innovation rather than lag it.

For investors and technology developers, the combined effect of these changes is the creation of a unique regulatory sandbox that accommodates rapidly evolving technologies while reducing the regulatory risk that often accompanies early-stage aviation technology investment. Combined with the Government's stated ambition to double the sector's economic contribution by 2030, these reforms signal a clear commitment to positioning New Zealand at the forefront of the global unmanned aviation industry, creating opportunities for both domestic innovation and international collaboration. 

This is a position already illustrated by the Government’s partnership with Wisk Aero, on the world‑first trial of a self‑flying, all‑electric air taxi. With the new regulatory settings in place, initiatives like this are expected to become increasingly common, positioning New Zealand as a serious global player in the global aerospace R&D industry.

How we can help

Our dedicated technology and regulatory team advises clients on regulatory compliance for all types of civil aviation operations and any associated commercial contracting.

If you need assistance with any part of your New Zealand aviation operations, do not hesitate to get in touch with any of our experts. 

This article was co-authored by Shane Antia, a Solicitor in our Tax team.