The Problem with Weight as a Proxy
Brazil's RBAC-E No. 94, introduced in 2017, classified drones primarily by mass. The logic was defensible at the time: heavier aircraft carry more kinetic energy and can cause more damage on impact, and weight thresholds were easy to verify without requiring deep operational analysis. Early commercial drone regulation worldwide defaulted to this shorthand.
The problem is that weight is a poor proxy for risk. A 5 kg delivery drone flying autonomously over a dense urban neighbourhood at night presents an entirely different threat profile from a 5 kg agricultural sprayer operating in rural conditions with the operator in visual contact. The same aircraft, the same weight — dramatically different risk. Under RBAC-E 94, both operations fell into the same primary classification bracket, forcing regulators to layer on case-by-case authorizations that generated bureaucratic friction without producing commensurate safety gains.
By 2025, Brazil's drone registry — the SISANT system — had grown to approximately 125,000 registered aircraft, a 315% increase since those 2017 rules took effect. Applications the original framers never envisioned had proliferated: infrastructure inspection, precision agriculture, urban logistics, search-and-rescue. The regulation had aged out of the sector it was meant to govern.
What RBAC 100 Changes
Published in the Official Gazette on June 16, 2026 and effective immediately, Brazil's new Brazilian Civil Aviation Regulation (RBAC) No. 100 replaces the weight-based default with a three-tier operational risk classification derived from ICAO's internationally harmonised framework for unmanned aircraft systems.
The Open Category covers low-risk operations: visual line-of-sight flights at or below 120 metres, not over uninvolved persons, with no requirement for prior ANAC authorisation if the operator meets applicable requirements. This is the recreational flier, the rural mapping contractor, the journalist drone — permitted to fly without working through an authorisation queue.
The Specific Category applies when any Open Category limit is exceeded. Operators must demonstrate safety using the SORA methodology (Specific Operations Risk Assessment) or standard scenarios pre-approved by ANAC. Rather than prescribing what operators must do, the framework defines the safety outcomes they must achieve. A company developing a new inspection workflow for high-voltage transmission towers is not forced into procedures designed for an entirely different use case.
The Certified Category governs high-complexity operations — those involving dangerous cargo, flights over dense urban areas, or scenarios where ANAC determines standard mitigations cannot adequately contain the risk. These require full certification of the unmanned aircraft system, the operator, and the remote pilot, along with robust agency oversight.
One structural change deserves separate attention: ANAC also adopted ICAO's preferred terminology, replacing "RPA" (Remotely Piloted Aircraft) with "UA" (Unmanned Aircraft). Consistent terminology reduces friction in cross-border operations, equipment certification, and the eventual development of regional frameworks across Latin America.
The SORA Bet and Its Limits
The decision to mandate SORA methodology for Specific Category operations represents Brazil's most consequential regulatory design choice. SORA, developed by JARUS (the Joint Authorities for Rulemaking on Unmanned Systems) and adopted as the backbone of Europe's EASA UAS framework, asks operators to analyse ground risk and air risk before each operation, then propose mitigations proportionate to the scores.
Proponents of weight-based rules argue, not unreasonably, that prescriptive frameworks are easier to audit and less susceptible to gaming — an operator with commercial incentives may understate ground population density in a SORA assessment. Risk-scored frameworks demand regulatory capacity to review and verify those assessments, which is not trivial to build. ANAC will need to expand its evaluation infrastructure in parallel with the transition.
The agency acknowledged the adjustment period: Specific Category operators who cannot slot into a standard scenario have up to two years to obtain necessary operational authorisations. An online pilot exam portal launched the same day as the regulation — all drone pilots must pass a 20-question assessment covering RBAC 100 basics, airspace rules, and risk before operating. The previous system had no equivalent mandatory pilot competency gate.
Strategic Context
The timing — at DroneShow Robotics 2026, Latin America's largest drone trade fair — was deliberate. With over 12,000 visitors from 40 countries attending the June 16-18 edition in São Paulo (a 20% increase over 2025), ANAC's direct presence at the fair, alongside DECEA, the Ministry of Agriculture, and the Ministry of Defence, signalled that the overhaul was designed with commercial deployment in mind, not just aviation safety compliance.
The ICAO alignment also carries export implications. Brazilian operators seeking European operations, and domestic manufacturers like Xmobots pursuing type certification in export markets, benefit from shared vocabulary and conceptual frameworks. A Brazilian framework that mirrors EASA's structure reduces the dual-compliance overhead for global sales — a material advantage as Brazilian industrial drone manufacturing matures.
What Remains Unresolved
Urban beyond-visual-line-of-sight (BVLOS) operations — the prerequisite for drone delivery at scale in Brazilian cities — still require case-by-case ANAC authorisation under the Specific Category rather than a defined standard pathway. RBAC 100's performance-based architecture is the right foundation for eventually accommodating urban BVLOS, but those standard scenarios have not yet been published.
The sub-250g carve-out, which grants simplified regulatory treatment to the lightest consumer drones, also creates a potential gap: operators could source hardware specifically designed to fall under this threshold while running operations that would otherwise require Specific Category scrutiny.
These are manageable implementation questions rather than structural flaws. Brazil's regulatory direction with RBAC 100 is sound: replace static weight thresholds with risk-proportionate analysis, align methodology with global standards, and require basic pilot competence. For a country with 125,000 registered drones and a rapidly professionalising commercial sector, the alternative — continuing to govern a complex industry with rules designed in 2017 for a simpler world — was no longer viable.