By Chris Davies
A pattern shows up regularly in conversations with operators across the uncrewed sector, and the shape of it is worth describing clearly because it points to where the next several years of regulatory and commercial pressure are going to come from.
The pattern is as follows: An operator with strong technical credentials and a growing book of commercial work is moving from Visual Line Of Sight (VLOS) into Beyond Visual Line Of Sight (BVLOS) operations. The platforms are capable. The mission planning is rigorous. The operators are well-qualified at the basic licence level. Yet the operational picture is starting to feel considerably less stable than the technical picture would suggest. Briefings are inconsistent. Handovers between roles miss important details. Decisions are swayed by whomever has the loudest voice in the room, rather than by those with relevant expertise. Near-misses, when they happen, are explained away as one-off circumstances rather than treated as signals of an underlying pattern. The operator senses that something is missing but can’t quite place it.
What is missing, in almost every case, is the Human Performance (HP) and Crew Resource Management (CRM) layer of the operation. The technical infrastructure has scaled. The operational infrastructure has scaled. The people infrastructure has not caught up, because the disciplines required to scale the people infrastructure are still relatively undeveloped in the uncrewed sector. This is the human performance gap, and it is the dominant safety risk in uncrewed aviation at this stage of the sector's development.
The reason the gap exists is structural rather than circumstantial. Most of the training material available to uncrewed operators today is a read-across from crewed aviation and the read-across is partial at best. Crewed CRM was originally developed around a two-pilot flight deck with a defined authority gradient, a shared sensory environment and a relatively stable crew composition. Almost none of those conditions hold in a BVLOS operation. The crew is distributed, the authority gradient is multi-faceted and often ambiguous, the sensory environment is mediated entirely through ground control station interfaces and the crew composition shifts based on the mission profile. The disciplines that worked for the cockpit do not transfer cleanly to this environment and the operators that rely on those disciplines are discovering the gaps the hard way.
The regulatory response is taking shape
The regulatory community has seen this pattern before and the response is already taking shape. The UK CAA has introduced the Remote Pilot Competence (RPC) licensing framework, replacing the General VLOS Certificate (GVC) with a four-tier structure that embeds basic human performance requirements at every level and is likely to introduce CRM requirements at those levels above the VLOS baseline (i.e. L2 and above). The Specific Operation Risk Assessment (SORA) process now treats HP/CRM as an explicit consideration in authorisation decisions, with the Specific Assurance and Integrity Level (SAIL) rating scaling the demonstration burden as operations grow more complex. The Acceptable Means of Compliance (AMC) and Guidance Material (GM) for UAS HP and CRM is being drafted now and once it lands it will give operators and inspectors a clear reference point for what acceptable competence looks like in this domain.
The Baines Simmons UAS team has had extensive involvement with the regulator’s HP/CRM development work and has direct links in to their military counterparts, through Army Reserve commitments and Advisory Panel membership. We have likewise been invited to draft the EUROCAE standard for uncrewed HP/CRM and the conversation we maintain with operators across civil and defence sectors all feed into the position we take in those roles. The output of that work will define the standard to which the market is held. Operators who are not aligned with this direction of travel will find themselves at a significant competitive disadvantage compared to those who are.
What does the regulatory direction actually look like in operational terms? Five themes are clear enough now to plan against.
Five themes to plan against now
The first theme is uncrewed specificity. Generic CRM training will not be sufficient. Training that has been written from the ground up for uncrewed operations, with crew compositions, scenarios and language drawn from BVLOS reality, is likely to be the foundation of any future AMC and GM. Operators who have invested in courses that meet that standard are going to be in a strong position. Operators who have completed read-across content will be asked harder questions.
The second theme is the multi-role crew. The training has to address the actual crew that flies a BVLOS mission, including the Safety Pilot, System Operator, Observer, Team Lead, Datalink Specialist and Payload Specialist. The CRM disciplines that hold this crew together are not the same disciplines that hold a two-pilot cockpit together and the demonstration burden in a SORA submission will reflect that distinction.
The third theme is evidence. Training delivered without a structured evidence base does not satisfy a SORA submission. The operator needs to be able to show what was trained, to whom, against what standard, with what assessment outcome, and how the competence has been sustained since the training event. This is where the safety management software layer becomes essential rather than optional, and where the Centrik 5 platform inside the TrustFlight ecosystem starts to do work that the training alone cannot.
The fourth theme is leadership. The regulatory expectation is moving toward an explicit recognition that safety performance is shaped by leadership and management decisions, not by the operator workforce alone. Leadership training in human performance and safety culture frameworks is moving from optional to necessary, particularly for organisations operating at SAIL III or above.
The fifth theme is continuous improvement. The regulator wants to see that the operator is learning from its own data, adjusting its training, refining its procedures and feeding the lessons back into the operation. This is closer to a maturity model than to a snapshot assessment and operators who treat their safety performance as a system they actively manage will fare significantly better than operators who treat it as a compliance checkpoint.
A three-layer approach to closing the gap
The human performance gap is bridgeable, and the operators who are bridging it now are going to be the ones who define the standard against which the rest of the sector is measured. The window for getting ahead of the regulatory direction is open, but not indefinitely. Once the AMC and GM lands, the standard will be visible to everyone and the differentiation available to early movers will narrow significantly.
We work with operators on closing this gap in three layers. The consultancy work designs the management system and the safety culture that the training plugs into. The training itself, including the uncrewed HP and CRM pathway we are now launching, builds the competence at the individual and crew level. And Centrik 5 sustains the evidence and the continuous improvement loop across time. The integration of the three layers is the difference between an operator who passes regulatory inspection cleanly and an operator who struggles.
The gap is closing one way or another. The question is whether it closes through your investment in these disciplines or through a regulatory finding you would rather have avoided.
Chris Davies leads the uncrewed training portfolio at Baines Simmons and has contributed directly to the UK CAA's drafting work on Acceptable Means of Compliance for UAS Human Performance and CRM. Learn more about the wider UAS safety and compliance work here.