FAA Part 108 Is Coming. Here's What It Means for Enterprise Drone Security Programs.
- 1 day ago
- 8 min read
The FAA's Part 107 waiver process was never designed to support enterprise drone security programs operating at scale. It was designed to let individual remote pilots request exceptions to the rules that govern small UAS operations, one mission at a time. For a research flight over a flood zone or a bridge inspection, the waiver model works fine. For an autonomous security program running nightly patrols across a 50-acre industrial facility, it's a structural barrier.
FAA Part 108 is the proposed solution. Published as a Notice of Proposed Rulemaking on August 7, 2025, it replaces the per-flight waiver system with a standardized, scalable framework for routine beyond visual line of sight operations. The final rule hasn't been published yet. As of July 2026, the rule is under review at the Office of Information and Regulatory Affairs, which is the last substantive review stop before publication in the Federal Register.
The timing matters. Enterprise security programs evaluating autonomous drone deployment need to understand what Part 108 proposes, what it changes for BVLOS operations specifically, and what operators who already hold BVLOS authorizations bring to the table right now, before the new rule lands.
What FAA Part 108 Actually Proposes
The core premise of FAA Part 108 is that the waiver-by-waiver model for BVLOS authorization is not a long-term approach to a mature industry.
In 2024, the FAA approved 203 BVLOS waivers under Part 107. That sounds like progress, but the approval rate was 19 percent. Most applications were denied. For those that were approved, each authorization covered a specific operation or operational scope, not a persistent program. An operator running nightly security patrols at the same facility still had to manage waiver currency, reapplication timelines, and the risk that a scope change would require starting the process over.
Part 108 proposes replacing that system with two approval pathways, built around the concept of operational area authorization rather than per-flight authorization.
The first pathway is Permitted Operations, designed for lower-risk environments with smaller aircraft and more limited scope. It's a streamlined pathway, analogous to how crewed general aviation handles lower-risk flight operations. The second pathway is the Operational Certificate, which covers higher-risk and larger-scale programs. An Operational Certificate can authorize multi-drone networks of up to 100 aircraft per authorization, operating across a defined geographic area under a persistent approval structure.
For enterprise drone security programs, the Operational Certificate pathway is the relevant one. Security programs running autonomous patrols across large facilities, multiple campuses, or complex outdoor environments are higher-risk in the regulatory sense because they operate in areas closer to populated zones, require sustained operational continuity, and involve larger aircraft or multi-aircraft deployments. The Operational Certificate framework is built to accommodate exactly that profile.
Both pathways are calibrated to five population density categories, based on data from Oak Ridge National Laboratory's LandScan USA database. The categories run from Category 1 (more than one statute mile from any cell of ten people or more) up to Category 5 (dense urban environments). An operator whose facilities fall into lower population density categories has a more accessible path to Part 108 approval than one operating in dense urban cores.
Why the Current Waiver System Hits a Wall at Enterprise Scale
The Part 107 BVLOS waiver process takes approximately 90 days from application to decision. For a one-time operation, 90 days is manageable planning time. For an enterprise security program that needs to run consistent coverage across a facility 365 nights per year, the waiver model creates operational fragility.
Waivers are scoped. A waiver issued for a specific facility at a specific altitude covering a specific operational area doesn't extend to adjacent properties, altitude changes required by airspace conditions, or scope expansions when the facility adds buildings or expands its perimeter. A security program that expands often needs a new or amended waiver, which means another 90-day cycle before the expansion zone has legal BVLOS coverage.
The DOT Office of Inspector General's BVLOS Final Report, published June 30, 2025, confirmed the systemic problem directly. Even as approval volumes increased in 2024, the process remained labor-intensive for both applicants and the FAA, with inconsistent requirements across similar missions and no clear pathway for operators building repeatable, long-term programs.
Part 108 addresses this structurally. The Operational Certificate framework grants operational area authorization, not per-flight authorization. An operator approved under Part 108 for a defined geographic area and operational profile can run routine BVLOS security operations within that authorization without going back to the FAA for each flight or each patrol cycle. The approval covers the program, not the individual mission.
The New Personnel Roles Part 108 Introduces
One of the more significant structural changes in Part 108 is the introduction of new personnel designations that don't exist under Part 107.
Part 107 centers the regulatory compliance framework on the individual remote pilot. The remote pilot in command holds the certification, bears the safety responsibility, and is the legal nexus of every flight. That model doesn't scale to enterprise programs running multi-drone networks across complex facilities with remote operations center oversight.
Part 108 introduces two new roles: the Operations Supervisor and the Flight Coordinator. The Operations Supervisor is responsible for the overall safety and compliance of the drone program operating under the Operational Certificate. They hold accountability at the program level, not the individual flight level. The Flight Coordinator manages the execution of operations within the program, coordinating aircraft, personnel, and the airspace management functions required for multi-drone BVLOS operations.
This role structure is explicitly designed for enterprise programs. It mirrors how crewed aviation manages flight operations at the organizational level, with a safety management system, designated personnel accountabilities, and documented procedures that cover the program rather than addressing each flight as a standalone event. Under Part 108, an Operational Certificate holder is required to maintain a Safety Management System, which is the structured organizational process for identifying, assessing, and mitigating safety risk across the operation as a whole.
For enterprise security buyers, this matters because it establishes a compliance structure they can audit. A managed drone security provider operating under a Part 108 Operational Certificate will have documented SMS procedures, designated personnel accountabilities, and operational area authorizations that a security director or compliance team can evaluate as part of a vendor qualification process.
What Part 108 Requires Technically
The technical requirements Part 108 proposes add to the current BVLOS authorization landscape rather than replacing its safety foundations.
Detect-and-avoid capability is a core technical requirement. Aircraft operating under Part 108 must have systems capable of detecting other aircraft or obstacles and avoiding them without relying on a pilot with visual contact. This is the safety foundation that makes BVLOS operations at scale viable. Current Part 107 BVLOS waivers sometimes require visual observers stationed along the flight path as a substitute for automated detect-and-avoid capability. Part 108 moves away from that model toward certified technical systems.
Remote ID is required. This is already the law under the Remote ID rule, but Part 108 builds on it as a baseline rather than an add-on. Continuous position tracking and UTM integration, meaning integration with UAS Traffic Management systems that coordinate drone traffic much as air traffic control coordinates crewed aviation, are also part of the technical framework.
TSA personnel vetting is a new layer specific to Part 108. Key personnel in a Part 108 operation are subject to TSA security review. For enterprise security programs, this aligns the regulatory framework with the security-sensitive environments where these programs operate. An autonomous drone security provider whose key operational personnel have cleared TSA vetting brings a different compliance posture than one whose team has not.
What Changes for Enterprise Security Programs When Part 108 Arrives
The practical impact of Part 108 on enterprise drone security programs is a function of who is ready for the new framework when it goes into effect and who isn't.
Operators who have built BVLOS programs under the current Part 107 waiver structure, and who have accumulated documented flight histories, safety records, and operational procedures, are positioned to convert that track record into Part 108 qualifications. The Operational Certificate pathway is designed for operators who can demonstrate that their program meets the safety and procedural standards the rule establishes. The demonstration is easier when you have 100,000 documented BVLOS flights behind you than when you're starting from a hardware deployment and a plan.
For enterprise buyers, Part 108's arrival will clarify the market in a way the current waiver structure doesn't. Right now, any operator with a Part 107 certification can theoretically claim to offer BVLOS drone security. In practice, the difference between an operator holding active BVLOS authorizations built through years of documented flight operations and one claiming BVLOS capability without that authorization history is significant. After Part 108, the Operational Certificate framework creates a clear dividing line. Either the provider holds a Part 108 Operational Certificate or they don't.
The population density calibration of Part 108 also matters for security program planning. Most enterprise security facilities, industrial sites, data centers, utility substations, distribution centers, and campus properties, fall into the lower population density categories where Part 108 approval pathways are most accessible. The facilities that most need autonomous drone security coverage are often the same facilities whose geographic profiles make them well-suited to Part 108 Operational Certificate approval.
Multi-drone operations deserve specific attention. Part 108 authorizes networks of up to 100 aircraft per Operational Certificate. The current waiver model doesn't contemplate multi-drone network operations at that scale. For enterprise buyers evaluating comprehensive perimeter coverage across large or multi-site facilities, the Part 108 framework eventually enables a degree of aerial security coverage that the per-flight waiver model can't support at any practical price point.
Where Part 108 Stands Right Now and What to Do Before It Finalizes
Part 108 is still a proposed rule. As of July 2026, the rule advanced to OIRA for final review. OIRA can take up to 90 days for significant rules. Once OIRA review concludes, the rule publishes in the Federal Register with a typical 30- to 60-day effective date, followed by staggered compliance dates for operational implementation. A realistic estimate for the final rule's effective date places it in late 2026 or into 2027, with full implementation requirements following that.
That timeline matters for enterprise drone security programs in two ways.
First, Part 107 BVLOS waivers remain valid and operational under the current framework. Operators holding active BVLOS authorizations are running legal, documented operations today. The transition to Part 108 doesn't invalidate current programs. It gives them a pathway to scale. An enterprise security program that deploys a managed BVLOS drone security program now is building the operational history that supports Part 108 qualification when the rule finalizes, not waiting for regulatory clarity before investing in coverage.
Second, the operator selection decision an enterprise buyer makes today has long-term implications. A managed drone security provider who is already operating under active BVLOS authorizations, has documented flight history in the hundreds of thousands of missions, holds established FAA safety relationships, and has the organizational structure to support SMS compliance under Part 108 is a fundamentally different partner than a provider planning to pursue BVLOS capability after Part 108 passes.
The regulatory landscape for enterprise drone security is shifting toward a framework that rewards established operators with documented safety records. That shift is underway now, before the final rule publishes. The operators with the track record to qualify for Part 108 Operational Certificates are the ones running programs today.
LandSkyAI has completed more than 100,000 BVLOS drone flights under FAA authorization, across industrial facilities, large private estates, and major public events. Our fully managed program covers everything from site survey and patrol planning to remote piloting, FAA waiver management, preventative maintenance, and analytics. If you're evaluating autonomous drone security for an enterprise facility and want to understand how the Part 108 transition applies to your program, we can walk through what it looks like on your specific footprint.
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What's most useful to understand about FAA Part 108?
What Part 108 requires to qualify for a certificate
How Part 108 changes multi-drone operational approvals
What the OIRA review means for the rule's timeline
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