Nothing has changed in law yet. EASA published the Opinion on 18 September and lists it as Pending. It is a proposal to amend Implementing Regulation (EU) 2019/947 and Delegated Regulation (EU) 2019/945, not a rule already in force.
The 100 g line changes more than registration
The draft would require an operator in the Open category to register when flying an aircraft with a take-off mass of 100 g or more, with an exception for tethered aircraft below 1 kg. Specific-category operators would remain subject to registration regardless of aircraft mass.
The same 100 g threshold appears in the proposed operating rules. An Open-category aircraft at or above 100 g would generally need an active direct Remote ID function with the operator registration number loaded into it. The draft also makes the online theoretical training and examination applicable from 100 g in A1, subject to the detailed exceptions in the text.
That is a material change for the 100-249 g segment. The current rules give many sub-250 g aircraft a deliberately light regulatory footprint. EASA's existing FAQ, for example, says an operator does not need to register when the aircraft is below 250 g and has no camera or other personal-data sensor, or when a sub-250 g camera-equipped aircraft qualifies as a toy. Opinion 06/2026 would replace that collection of Open-category registration criteria with a much clearer mass boundary.
Remote ID becomes part of the arming path
For builders, the interesting engineering requirement is the proposed consistency check.
The draft's treatment of privately built aircraft in A1 says that a 100-249 g build would need direct Remote ID and would not be permitted to take off if the consistency check defined in the product rules is not passed. Similar language appears for privately built aircraft in A3.
This is a different design assumption from attaching a transmitter that merely broadcasts identity in parallel with the flight controller. If adopted as drafted, compliance for affected new designs becomes part of the aircraft's startup logic. The system needs a path from operator identity to the Remote ID function and from that validation state to take-off permission.
For an integrated consumer aircraft, a manufacturer can control that whole chain. A privately built multirotor or fixed-wing aircraft is assembled from independent flight controllers, receivers, GPS units, radios and firmware. Making Remote ID a prerequisite for take-off therefore raises practical integration questions: where the consistency check lives, how its state reaches the autopilot, what happens when the module fails, and how an operator diagnoses a refusal to arm.
Those implementation details matter more to DIY builders than the mass threshold alone.
The proposal does not simply obsolete every existing mini drone
The transition provisions are easy to miss.
The draft would preserve operation of legacy aircraft placed on the market before 1 January 2024 under the existing Article 20 structure: below 250 g in A1 and below 25 kg in A3, subject to the stated conditions. It also creates a transition for products placed on the market before a point 12 months after the future regulation enters into force when they lack the newly required Remote ID, consistency-check or serial-number provisions.
There is another important dividing line at 900 g. The draft says that, after 48 months from entry into force, aircraft exceeding 900 g would need a compliant direct Remote ID add-on unless another listed transition provision applies. In the Open-category operating rule, aircraft of 900 g or less that meet the specified transition conditions are exempted from the new 100 g Remote ID operating requirement.
So the useful question for an existing aircraft is not simply, "Is it over 100 g?" Its market date, class/legacy status, mass and operating category all matter.
No calendar date for these future obligations can be stated yet because the proposal has not been adopted. The draft expresses the key transitions relative to the eventual entry-into-force date.
Model aircraft clubs retain a route to different treatment
The proposal explicitly recognizes model-aircraft clubs and associations. EASA says Member States would retain flexibility to allow alleviations for operations conducted under the Article 16 framework, based on the local operating environment and the club's organization and safety arrangements.
The draft lets a competent authority decide in an Article 16 authorization whether aircraft in that framework must carry direct Remote ID and enforce the associated consistency check.
That distinction is important for traditional model aviation. A blanket interpretation that every 100 g model would automatically need identical hardware in every operating context would miss the discretion built into the proposal.
Geographical zones become more machine-readable
Opinion 06/2026 also changes how pilots and software would consume operating restrictions.
The draft introduces the concept of "national conditions" alongside geographical zones. Member States could use them for requirements that apply across their territory. Relevant information would have to be available through a single access point in both human-readable and digital forms and at least in English. Geographical-zone data would include geometry, temporal validity, restrictions and relevant authority information in a common digital format defined by EASA.
For flight-planning and ground-control software, this is potentially as useful as the headline Remote ID change. A restriction that exists only on a government web page is difficult to integrate reliably into mission planning. Structured geometry and time validity can be consumed by software, compared with a route and presented before launch.
It does not mean geofencing becomes a universal automated permission system. Member States retain discretion over zones, and the proposal requires measures addressing safety, privacy, data protection or environmental risks to be necessary and proportionate. But the data plumbing would become more consistent.
What a builder should do now
There is no reason to retrofit a 120 g aircraft this week because of Opinion 06/2026. It is not current law, and the final Commission text may differ.
There is, however, a reason to avoid designing new hardware as if Remote ID will always remain an isolated accessory. For a new European-oriented flight controller, autopilot or integrated aircraft, it is sensible to preserve an interface through which a Remote ID subsystem can expose a valid/invalid state to the flight stack. Builders working near 100 g should also keep realistic mass margin for a GNSS-capable identification module, its antenna, wiring and power budget if the final rules require it for their operating case.
Software developers have a second opportunity: treat geographical-zone information as structured operational data rather than a map image. The draft points toward restrictions that can be consumed directly by planning tools.
For pilots buying a small camera drone, waiting for the legislative process is more rational than making a purchase decision from the 100 g headline. Existing and newly marketed products do not all receive the same transitional treatment.
Why the proposal matters even if the final text changes
The 250 g threshold shaped a generation of products. Manufacturers optimized aircraft such as compact camera drones around it because staying below the line materially simplified operation for customers.
EASA's new proposal suggests that the next design boundary may be less about avoiding regulation through mass and more about making identity and compliance cheap enough to integrate into small aircraft.
That changes the engineering incentive. Below 100 g, extreme weight optimization remains valuable. Above it, if the proposal survives, manufacturers may have less reason to fight for every gram merely to stay below 250 g. Instead, they will need clean Remote ID integration, reliable operator-number handling and understandable failure behavior when the identity check does not pass.
For DIY aircraft, that is the part worth watching. A regulation that connects identity to take-off changes an accessory into a flight-system dependency.