Greenhouse drone regulations: EASA, BVLOS, and SORA explained

Growers ask us a version of the same question before anything flies: do I need a drone permit for my greenhouse? The honest answer is that it depends almost entirely on one fact, and it is not the fact most people expect. It is not the weight of the drone, the crop, or whether it carries a camera. It is whether the drone ever leaves the enclosed space. A drone that stays inside the glass and a drone that crosses over it live under two different bodies of law, and the gap between them is wide.

This is a guide to those regimes for anyone planning autonomous flight in a controlled-environment operation in the Netherlands or the wider EU. It maps the rules that apply, the rules that do not, and the practical path through each. It does not describe any specific machine, only the regulation around it. For what we actually design and fly, see the autonomous drones we build.

One caveat up front, because it matters for a topic like this: nothing here is legal advice. Rules change, and your operation has details a guide cannot see. Treat this as a map, and confirm your specific case with the Human Environment and Transport Inspectorate (ILT) or a qualified adviser before you fly.

The three EASA drone categories, in ninety seconds

EU drone law runs on one framework across every member state, Regulation (EU) 2019/947. It sorts every operation into one of three categories by risk:

• Open. Low risk, with hard limits baked in. Visual line of sight only, a maximum height of 120 metres above ground, tight rules on distance from people, and a weight ceiling. No permit, no case-by-case approval. You fly within the limits or you leave the category.
• Specific. Medium risk. The moment an operation exceeds an Open limit, and most useful commercial work does, it becomes Specific. This category needs either an authorisation from the national authority or a declaration against a pre-approved scenario.
• Certified. High risk, closest to manned aviation. Type-certified aircraft, certified operators, the sort of thing that carries people or heavy cargo over crowds. Greenhouse work does not reach this category.

The key point for growers is that greenhouse work is almost never Open. Flying beyond direct sight down a long row, flying without a pilot watching the aircraft, flying on a schedule with no one holding a controller: each of those breaks an Open limit on its own. If your ambition is autonomy, you are aiming past Open by definition. So the real question is whether you land in Specific, or whether you step outside this framework altogether.

Regime one: fully enclosed flight (indoor drones)

A drone that flies entirely inside an enclosed structure is not covered by EU aviation law at all. Most growers do not expect that.

EASA is direct about this. In its own guidance, the agency states that there are no EU rules for drone operations conducted fully indoors, and that the UAS regulation applies to outdoor operations. If the aircraft is physically enclosed from takeoff, by a building or even a temporary structure, the flight can be treated as indoor and falls outside the drone rules.

A production greenhouse is an enclosed structure. So is an indoor vertical farm. A drone that takes off, works, and lands without the aircraft ever passing through an open vent or door is, for the purposes of aviation law, not flying in regulated airspace. No operator registration for the flight itself, no SORA, no ILT authorisation.

One nuance matters for glasshouses. In EASA's guidance, what makes a flight indoor is that the likelihood of the aircraft escaping into the outside airspace is very low. A production greenhouse vents through open roof windows for much of the year, so containment has to hold while the vents are open, through insect netting, closed compartments, or limits on where the aircraft can fly. The building alone does not settle the question; the operation has to keep it enclosed.

That sounds like freedom, and in one sense it is. There is a catch.

Escaping aviation law does not mean escaping regulation. It means a different regulator.

What governs an indoor drone instead

An autonomous drone working inside a greenhouse is, in legal terms, a machine operating in a workplace. That puts it under product-safety and occupational-safety law rather than airspace law. And the central piece of product-safety law here is about to change in a way that matters for anyone building or buying autonomous systems.

The EU Machinery Regulation, Regulation (EU) 2023/1230, replaces the old Machinery Directive and applies from 20 January 2027. Unlike the directive it replaces, it was written with autonomous and AI-driven machines in mind. It brings in requirements aimed squarely at machines that make their own decisions: assessment of self-evolving behaviour, protection of safety functions against interference, and cybersecurity duties that run for the life of the product.

The practical test is blunt. If your software decides when the machine moves, when it descends, or when a person has come too close to something active, this regulation is written for you. The onboard decision-making it targets is the same edge AI that runs on the drone itself. An autonomous greenhouse drone is exactly that kind of machine. From 2027, placing one on the EU market, or building one for your own operation, means meeting those obligations: a conformity assessment that accounts for the autonomy, documentation held for a decade, and safety cases that cover not just what the machine does today but the states it can reach as it learns.

Alongside the product rules sit the ordinary duties any employer has toward the people on the floor. A machine flying near workers has to be safe to be near. That means risk assessment, safe separation from people, clear behaviour when something fails, and an aircraft that cannot become a hazard if it loses power or signal. None of that is aviation law. All of it is real, and for an indoor operation it is the law that actually binds.

So regime one is not the unregulated zone it first appears to be. It is lighter on paperwork before the first flight, and heavier on engineering the machine to a product-safety and worker-safety standard. For a well-built autonomous system that is the right place for the burden to sit.

Regime two: any outdoor leg (the Specific category)

The moment any part of a flight happens outdoors, EU aviation law applies to the whole operation, even if the mission is mostly indoors. EASA gives the example of a drone that flies only a few metres outdoors between one enclosed space and another: that short outdoor leg pulls the operation back under the drone rules.

For controlled-environment growers this is not a corner case. A drone that hops between adjoining greenhouse compartments across an open path, monitors the outside of a glass roof, or moves between buildings on a site is flying outdoors in the eyes of the regulation. Combine that with the loss of visual line of sight, which autonomy implies, and you are firmly in the Specific category.

Being in Specific does not mean one fixed process. There are three routes through it, from lightest to heaviest, and picking the right one is most of the work.

Route one: a standard scenario (STS)

EASA publishes Standard Scenarios (STS): pre-defined operations for which the risk work is already done. If your operation fits one, you do not run a full risk assessment. You file a declaration with the national authority before you fly.

Two exist today. STS-01 covers visual-line-of-sight flight over a controlled ground area with a drone carrying a C5 class marking. STS-02 covers beyond-visual-line-of-sight flight over a controlled area in a sparsely populated environment with a C6 marked drone, and it requires at least five kilometres of flight visibility. A controlled ground area, one where you keep uninvolved people out, is often achievable on a private growing site. The catch is the class marking: the drone has to carry the right certified class mark, which constrains which aircraft you can use.

Route two: a pre-defined risk assessment (PDRA)

If no standard scenario fits but your operation resembles a common pattern, EASA may have published a Pre-Defined Risk Assessment (PDRA) for it. A PDRA is a risk assessment EASA has already carried out and published as an acceptable means of compliance. Instead of building the assessment from scratch, you complete the PDRA, write your operations manual, and apply to the national authority for an authorisation. It is still an authorisation, but the analysis is largely done for you.

Route three: a full SORA

When nothing pre-packaged fits, you run the Specific Operations Risk Assessment (SORA), the methodology at the centre of the Specific category. SORA weighs the ground risk of a flight, the air risk, and the mitigations you put against each, and produces a level called the SAIL, the Specific Assurance and Integrity Level. The higher the SAIL, the more evidence and rigour the authority expects before it grants an authorisation.

SORA is worth understanding because the framework itself moved recently. SORA version 2.5 became applicable across the EU on 29 September 2025, adopted by EASA as an acceptable means of compliance and since folded into the Easy Access Rules. The revision is meant to reduce room for interpretation between member states and to lower the evidence needed for many lower-risk operations. If you or an adviser worked from an older version, that groundwork should be checked against 2.5 before it goes to an authority, and some member states set their own 2026 cutoffs for accepting only the new version.

Regime three: beyond visual line of sight (BVLOS)

Flights that leave a controlled site and cover open ground carry the most risk and are the hardest to authorise. This is the outdoor beyond-visual-line-of-sight work that most public drone coverage is about. STS-02 covers part of it. Anything past that leans on a full SORA at a higher SAIL, with real scrutiny of how the aircraft detects and avoids other airspace users and what happens when a link drops.

The Netherlands is a useful place to watch this mature, because it is moving faster than most. In June 2024, Breda became the first Dutch municipality permitted to run beyond-visual-line-of-sight flights without a pilot on site, at the Hazeldonk business park near the Belgian border. The flight launched from a fixed drone box over a sparsely populated area, which is exactly the profile that Specific-category BVLOS is built to handle: a controlled or thinly populated ground area, an aircraft flying itself, and a documented case for why it is safe.

For a grower, the milestone shows what this route demands. Beyond-visual-line-of-sight flight over an open area is achievable in the Netherlands, and the way there is a documented risk assessment that satisfies the authority.

[Figure: a decision path from "does the drone ever fly outdoors?" through the three regimes and their routes.]

The Dutch path: RDW and ILT

If your operation lands in the Specific category, the Dutch sequence involves two bodies: the RDW and the ILT.

First, an operator number. Before any declaration or authorisation, you register as a drone operator with the RDW, the Netherlands Vehicle Authority, and put that number on your aircraft. This is the operator, not the pilot, and not the specific flight.

Then, one of two filings with the ILT, depending on your route:

• For a standard scenario, you submit an operational declaration that your operation complies with the STS. The ILT confirms it, and once confirmed you may fly.
• For a PDRA or a full SORA, you apply for an operational authorisation. You submit the risk assessment and your operations manual, and the ILT assesses the case.

Two numbers set expectations. The ILT has a statutory 112 days, about sixteen weeks, to decide on an authorisation, and in practice it can run longer, so this belongs at the start of a project, not the week before a demo. And the cost scales with risk. The fees are set in the Dutch transport-sector tariff regulation: a first authorisation based on a PDRA limited to SAIL II costs 1,505 euro, a full SORA authorisation up to SAIL IV costs 4,514 euro, and one covering SAIL V and VI costs 9,052 euro. A simple, well-scoped case is far cheaper to authorise than an ambitious one.

For an operator that expects to fly often, there is a way to stop asking permission flight by flight. The Light UAS Operator Certificate (LUC), defined in Part C of Regulation (EU) 2019/947, is a voluntary certification of your organisation. Once an authority has assessed that you can evaluate the risk of your own operations, it can grant you the privilege to authorise certain operations yourself, without a separate application each time. It takes effort to earn and it suits a mature, recurring operation rather than a first pilot. For a grower scaling from one trial to routine use, it replaces a fresh application for every new operation with one assessment of the organisation.

Which regime am I in?

The whole guide reduces to one table. Find the row that matches where your drone actually flies, and you have your regime, your rough burden, and your first move.

Where the drone flies	Regime	Governing law	First move
Fully enclosed greenhouse or indoor farm, aircraft never outdoors	Outside EU aviation law	Machinery Regulation 2023/1230 (from 2027), workplace safety	Engineer to product and worker safety; no flight permit
Between or over the glass, any outdoor leg on a controlled site	Specific category	Regulation 2019/947, via STS, PDRA, or SORA	RDW operator number, then ILT declaration or authorisation
Over a wider area, beyond visual line of sight	Specific category, higher SAIL	Regulation 2019/947, full SORA	Scope the SORA early; budget sixteen weeks and the fee

An indoor operation carries a light regulatory burden before the first flight and a real engineering burden in the machine. An outdoor operation adds an aviation-authorisation burden on top. Neither blocks a serious operation, and both reward deciding which regime you are in before you design the operation rather than discovering it after.

Decide early whether your work stays inside the glass or crosses it. That single choice sets everything downstream: the certification the aircraft needs, the paperwork before you fly, and how long it takes to get in the air.

Common questions

Do I need a permit to fly a drone inside my greenhouse? If the drone stays fully enclosed and never flies outdoors, EU aviation law does not apply, so there is no flight permit to obtain. The machine still has to meet product-safety and workplace-safety law, including the Machinery Regulation that applies from 2027.

When does a greenhouse drone need BVLOS approval? As soon as any part of the flight happens outdoors and the drone flies beyond the operator's direct sight. That puts the operation in the Specific category, where beyond-visual-line-of-sight flight is handled through a standard scenario, a PDRA, or a full SORA.

How long does a Dutch drone permit take? The ILT has a statutory 112 days, about sixteen weeks, to decide on an operational authorisation, and in practice it can run longer, so it belongs at the start of a project rather than the week before a flight.

We design for the regime from the start. It is part of how we build autonomous drones end to end, and we are happy to talk through which one a given operation falls into. Reach us through the contact page.