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Permits and Licensing (From the Practice of an Administrative Scrivener)

What permits and approvals do you need to fly a drone for work? The Civil Aeronautics Act and aircraft registration

Watercolor illustration of a stack of application forms on a service counter
浦松 丈二

浦松 丈二

行政書士・宅地建物取引士(四葉行政書士事務所/四葉不動産株式会社)

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To fly a drone (unmanned aircraft) for business, two separate systems apply: aircraft registration (mandatory for anything 100 g or more since 20 June 2022) and flight permits and approvals for certain airspace and methods (Articles 132-85 and 132-86 of the Civil Aeronautics Act). This article organises them from an administrative scrivener's view and shows who handles radio, insurance and accidents.

In short: to fly a drone (unmanned aircraft) for work, keep two systems in mind. One is registration of the aircraft (mandatory for anything weighing 100 grams or more since 20 June 2022); the other is the flight permit and approval you need when flying in defined airspace or by defined methods (Articles 132-85 and 132-86 of the Civil Aeronautics Act). Registration and permit/approval are separate procedures; registering does not remove the need for a permit. Preparing and acting as agent for flight-permit and approval applications and for aircraft registration is handled by the administrative scrivener; radio matters (technical conformity and radio-station licences) are a separate procedure of the Ministry of Internal Affairs and Communications under the Radio Act; liability and disputes after an accident are for a lawyer; and tax on service contracts is for a tax accountant — each handed off separately, on the premise that you contract with each as an independent business. Renting or buying an office or take-off and landing site is handled by Yotsuba Real Estate Co., Ltd., a separate business. This article is general information and does not guarantee whether a given flight plan is subject to a permit or approval, whether it will pass review, or when you may fly. The final judgement on eligibility and the interpretation of law are made by qualified professionals and administrative agencies. Our office receives no referral fee.

When flying a drone for work, what is the difference between registration and permit/approval?

"Registration" and "flight permit/approval" are separate systems with different purposes. Confusing them leads to flying with only one of them done.

Aircraft registration assigns a registration mark to an unmanned aircraft and identifies the owner; it became mandatory on 20 June 2022. At the same time the scope widened from 200 grams or more to 100 grams or more (including the battery). A registered aircraft must display its registration mark and, in principle, carry a function that transmits identification by radio (Remote ID).

The flight permit and approval, on the other hand, is the system for obtaining the Minister of Land, Infrastructure, Transport and Tourism's permit or approval when a flight falls within defined airspace (Article 132-85) or uses a defined flight method (Article 132-86). Registration is the entry procedure that "puts the aircraft on the register"; permit/approval is the procedure for "whether you may fly that way." Their roles differ.

SystemBasisWhat the procedure is for
Aircraft registrationCivil Aeronautics Act (created by the 2020 amendment, in force 20 June 2022)Assigns a registration mark to aircraft of 100 g or more and identifies the owner; Remote ID in principle
Flight permitCivil Aeronautics Act Article 132-85Permit to fly in prohibited airspace
Flight approvalCivil Aeronautics Act Article 132-86Approval to fly other than by the defined methods

Which flights (airspace, method) require a permit or approval?

Article 132-85 defines airspace where you must not fly. Broadly, it is airspace that risks affecting the safety of aircraft navigation (areas such as the approach surfaces around airports, and airspace 150 metres or more above the ground or water surface) and the airspace above densely inhabited districts. Emergency-use airspace set during disasters is also included. Flying in these requires a permit.

Article 132-86 defines flight methods. Basic rules must always be kept: do not fly under the influence of alcohol or the like, check before flight, prevent collisions with other aircraft or objects, and do not fly in a way that troubles others. On top of that, the following methods require approval.

Flight method requiring approvalContent
Night flightFlight outside daytime (sunrise to sunset)
Beyond-visual-line-of-sight flightFlight not constantly monitored by sight
Flight without the required distanceFlight that cannot keep the distance set by ministerial ordinance (30 metres) from people or objects
Flight above an event siteAbove festivals, fairs and other sites where many people gather
Transport of dangerous goodsFlight transporting dangerous goods
Dropping objectsFlight dropping objects

Where a person who holds a pilot competence certificate flies an aircraft that has aircraft certification under certain conditions, part of the permit/approval may be omitted (the Level 4 flight system came into force on 5 December 2022). Whether omission is possible depends on the flight category, so it is checked individually.

How do you use a blanket application versus an individual application?

There are individual applications, which cover a flight at a specific time and place, and blanket applications, which cover flights over a set period and range together. Operators who repeat and continue aerial photography or inspection generally use a blanket application bundling the period or flight routes. A period-based blanket application can cover up to one year.

TypeSuited use
Individual applicationA one-off flight at a specific date and place
Blanket application (period)Similar flights repeated and continued (up to one year)
Blanket application (route)Repeated flights within a set range without specifying the route

Even with a blanket application, high-risk flights such as above event sites, transport of dangerous goods, or dropping objects may not be bundled. Which form can be used depends on the flight content and is not uniform.

What documents and review points matter (flight manual, competence)?

An application shows the aircraft information, the pilot's flight history, knowledge and skill, and the system for ensuring safety (flight manual). Review looks at whether the aircraft meets safety standards, whether the pilot has the necessary flight history and ability, and whether procedures to prevent accidents are set out.

Have a question about your situation?

Tell us about your residency, permit or administrative procedure enquiry.

Applications are made in principle through the online Drone Information Platform System (DIPS2.0), submitted at least 10 business days before the planned start of the flight. Preparing the documents and organising where to fill gaps to meet the requirements is a part the administrative scrivener can handle as agent. However, the safety judgement of the flight itself, and the substantive check of whether the aircraft and pilot meet the requirements, are made by the operator and by the Ministry and registered inspection bodies. The administrative scrivener cannot guarantee the feasibility of the flight itself.

Who should you consult about radio, insurance and accident response?

Flying a drone also involves procedures outside the Civil Aeronautics Act. Each is on the premise that you contract separately as an independent business.

  • Technical conformity (technical standards) and radio-station licences for radio equipment used for video transmission and the like → procedures of the Ministry of Internal Affairs and Communications under the Radio Act. This is separate from our office's permit/approval under the Civil Aeronautics Act
  • Liability for damage when an accident occurs, disputes between parties, and disputes over insurance money → a lawyer
  • Income and corporate tax on the service contracts of a drone business → a tax accountant
  • Renting or buying an office, warehouse, or take-off and landing site → a real estate broker (Yotsuba Real Estate Co., Ltd., a separate business)

If, during flight, a person is injured, a third party's object is damaged, or a collision or near-miss with an aircraft occurs, reporting the accident to the Minister is required. What the administrative scrivener handles is preparing and acting as agent for flight-permit and approval applications and aircraft registration, organising the flight manual, and organising materials to pass to each professional. For the flow of engagement, see Engagement Flow; for fees, see Fee Schedule; and for the whole range of work handled, see Services. We also handle consultations in Chinese (traditional and simplified) and English. Our office receives no referral fee.

FAQ

Q. If it is a small drone under 100 grams, do I need neither registration nor a permit?
A. An aircraft under 100 grams is not an unmanned aircraft under the Civil Aeronautics Act, so it is outside registration and the permits/approvals of Articles 132-85 and 132-86. However, other rules such as the Act on Prohibition of Flight of Small Unmanned Aircraft and local ordinances may apply in some places. Check at each place you fly.

Q. Once I make a blanket application, can I fly freely anywhere?
A. No. A blanket application is valid only within the airspace, methods and period it covers. High-risk flights such as above event sites or transporting dangerous goods may not be bundled, and flights outside the range need a separate permit or approval.

Q. If I obtain a qualification (competence certificate), do permits and approvals become unnecessary?
A. Not flatly. There is a mechanism where part of the permit/approval is omitted when a person with a competence certificate flies an aircraft with aircraft certification under certain conditions, but it depends on the flight category and conditions. Whether it can be omitted is checked individually.

Q. What can and cannot an administrative scrivener do?
A. The administrative scrivener prepares and acts as agent for flight-permit and approval applications and aircraft registration, and organises the flight manual. Radio technical conformity and radio-station licences are a separate procedure of the Ministry of Internal Affairs and Communications; liability and disputes after an accident are for a lawyer; and tax is for a tax accountant. The safety judgement of the flight itself and the substantive check of requirements are made by the operator and administrative agencies.

Sources (Primary Information)

  • e-Gov Law Search, "Civil Aeronautics Act" (Act No. 231 of 1952), Article 132-85 (prohibited airspace for unmanned aircraft) and Article 132-86 (methods of flight for unmanned aircraft; the distance set by ministerial ordinance = 30 metres, etc.) (accessed 2026-09-29)
  • Ministry of Land, Infrastructure, Transport and Tourism, "Registration System for Unmanned Aircraft" (registration mandatory, in force 20 June 2022; scope widened from 200 g or more to 100 g or more; display of the registration mark and Remote ID) (accessed 2026-09-29)
  • Ministry of Land, Infrastructure, Transport and Tourism, "Flight Permit and Approval Procedures for Unmanned Aircraft" (prohibited airspace and methods of flight, blanket and individual applications, application at least 10 business days before the planned start, the Drone Information Platform System DIPS2.0) (accessed 2026-09-29)
  • Ministry of Land, Infrastructure, Transport and Tourism, "Aircraft Certification and Type Certification of Unmanned Aircraft, and Unmanned Aircraft Pilot Competence Certificate" (the Level 4 flight system in force 5 December 2022; first-class and second-class competence certificates) (accessed 2026-09-29)

This article is general information and does not guarantee whether a given flight plan is subject to a permit or approval, whether it passes review, when you may fly, or whether requirements are met. Preparing and acting as agent for flight-permit and approval applications and aircraft registration is for an administrative scrivener, radio technical conformity and radio-station licences for the Ministry of Internal Affairs and Communications under the Radio Act, liability and disputes after an accident for a lawyer, tax for a tax accountant, and renting or buying an office or take-off and landing site for a real estate broker, each as an independent business under a separate contract. Consultation on an office or take-off and landing site is handled by Yotsuba Real Estate Co., Ltd., a separate business, and our office receives no referral fee. Individual judgements are made by qualified professionals and administrative agencies after a meeting. Written by Joji Uramatsu, administrative scrivener and licensed real estate broker.

Let's start by sorting out your situation.

Yotsuba Gyoseishoshi Office (Kohinata, Bunkyo-ku; a 5-minute walk from Myogadani Station on the Tokyo Metro Marunouchi Line) supports you from organizing the requirements through document preparation and application.

LINE connects you directly to our representative, Joji Uramatsu. Messages are accepted 24/7 and answered in order.

5 min walk from Myogadani Sta. (Tokyo Metro Marunouchi Line)|Tue & Wed 10:00–19:00 / Mon, Thu–Sun 18:00–19:00