The UAS Governance Gap: securing European airspace before the next crisis
A regulatory horizon scan on UAS policy convergence across the UK, EU, and US, tracking the procurement clauses, certification regimes, and dual-use lines that will shape European airspace governance over the next 24 months.
Overview
UAS (unmanned aerial systems) sit at the most contested intersection of European policy: defence procurement, civil aviation rules, dual-use export controls, and the operational reality of contested airspace. The regulatory frameworks meant to govern this space were not built for it, and the gap is widening faster than the policy machinery can close it.
This briefing tracks UAS policy convergence (and divergence) across the UK, EU, and US. We map the procurement clauses, certification regimes, and dual-use lines that will determine market access for primes and operators over the next 24 months, and identify the specific decisions where the governance gap is most likely to be tested next.
Where the governance gap shows up.
The briefing is structured around the specific clauses and certifications most likely to move first, and what they mean for primes, operators, and regulators alike.
Specific Category & the SORA pathway
EASA's Specific Category and the SORA risk-assessment framework, and the divergence with FAA Part 108 and CAA AAM rules.
Export-control convergence
Wassenaar, EU dual-use regulation, and the post-2022 tightening of UK and US export-licence regimes.
EDIRPA, EDIP & national fast-tracks
How EU defence-industrial instruments interact with national procurement, and the clauses that quietly redraw market access.
Critical-infrastructure protection
The civil-military overlap on airports, ports, and energy infrastructure, and where authority sits when it isn't clear who owns the airspace.
Onboard autonomy & ITAR exposure
Where onboard AI and autonomous targeting capabilities cross into ITAR-controlled territory, and what that means for European primes.
Lessons from Ukraine
The Ukrainian operational read fed back into European policy, and the policy lessons regulators are still not learning fast enough.
Brief your next decision with the full picture.
Initial conversations are confidential and obligation-free. We respond to every enquiry within one business day.