Commercial drone operators flying under FAA Part 107 must make sure every remote pilot holds a remote pilot certificate and has completed FAA recurrent training within the previous 24 calendar months, gets air traffic control authorization before flying in controlled airspace, and reports serious-injury or significant property-damage accidents within 10 days. When those pilots work on construction, utility, or industrial client sites, the client’s safety program adds a second training stack, covering hazard analysis, PPE, heat, and driving, that drone companies are audited on before they win the work.
The FAA side decides whether a pilot may legally fly; the jobsite side decides whether the company gets through the gate.
What Does FAA Part 107 Require Remote Pilots to Keep Current?
Under 14 CFR 107.65, aeronautical knowledge recency, a remote pilot may not exercise the privileges of the certificate unless, within the previous 24 calendar months, they passed the initial knowledge test, completed FAA recurrent training, or (for Part 61 pilots with a current flight review) completed the designated Part 107 training. Since April 6, 2021, recurrent training has replaced the old recurrent test.
The FAA’s page on becoming a certificated remote pilot points current certificate holders to the free online Part 107 Small UAS Recurrent course (ALC-677) on the FAA Safety Team site, or ALC-515 for Part 61 pilots. The course completion certificate is the record you keep.
Two more rules shape the pilot file. Under 14 CFR 107.7, the pilot must have the remote pilot certificate and identification in physical possession when flying and must present them on request to the FAA, NTSB, TSA, or any federal, state, or local law enforcement officer. The operator must also make required records available to the FAA on request.
The practical risk is a lapse nobody notices, which is easy when pilots completed training at different times. A pilot who flies a paid job after the 24-month window closes is flying without valid privileges, and every deliverable from that flight is exposed. Our guide to automated certificate management explains how to track expiration dates instead of completion dates.
How Should Operators Document Airspace Authorizations and Preflight Briefings?
Airspace is the most common reason a job stalls. Under 14 CFR 107.41, no one may operate a small unmanned aircraft in Class B, C, or D airspace, or within the surface area of Class E airspace designated for an airport, without prior ATC authorization. Most operators get it through LAANC, the FAA’s automated authorization system, or through the FAADroneZone for locations LAANC does not cover. Save the authorization with the job file.
The preflight rule is where training and documentation meet. 14 CFR 107.49 requires the remote pilot in command, before each flight, to assess local weather, airspace and flight restrictions, people and property on the surface, and other ground hazards. It also requires briefing everyone directly participating, such as visual observers and payload operators, on operating conditions, emergency and contingency procedures, roles, and hazards. A one-page preflight checklist signed by the pilot in command is the simplest proof that the briefing happened.
Two other FAA requirements belong in the same file:
- Remote ID. Drones that are required to be registered must comply with the Remote ID rule in 14 CFR Part 89, either as a Standard Remote ID drone or with a broadcast module. Part 107 operators register each device separately, so keep serial numbers matched to registrations.
- Accident reporting. Under 14 CFR 107.9, the remote pilot must report to the FAA within 10 calendar days any operation involving serious injury, loss of consciousness, or damage to property other than the drone, unless repair costs or the property’s value are $500 or less.
Which Jobsite Safety Training Do Clients Expect From Drone Crews?
FAA rules govern the aircraft. They do not cover the pilot standing on a scaffold-lined jobsite, walking a substation perimeter, or driving a crew truck 300 miles to a wind farm. That exposure belongs to the drone company as an employer, and client safety departments treat it that way. A drone crew on a construction site is a subcontractor crew like any other.
The training stack clients most often ask drone service companies to show:
- OSHA 10 Construction. Not a federal OSHA requirement, but many general contractors and utilities require a card for site access. Coggno’s OSHA 10: Construction Industry course covers it.
- Job hazard analysis. Clients want to see that pilots can identify launch-site hazards, overhead lines, traffic, and equipment movement. The Job Hazard Analysis (JHA) course pairs with your own site checklist.
- PPE orientation. Hard hats, high-visibility vests, and safety glasses are standard site rules. See Construction New Hire PPE Orientation.
- Heat illness prevention. Pilots stand still in full sun for hours on solar farms and rooftops. Heat Stress: Working Safely in Hot Conditions covers recognition and response, and our post on heat illness prevention training for construction covers what multi-state crews document.
- Driver safety. For many drone companies, the riskiest part of the job is the drive. Defensive Driving Awareness fits pilots who drive company vehicles between sites.
Many large clients run these checks through prequalification platforms. Our guide to passing ISNetworld, Avetta, and Veriforce prequalification explains what reviewers look for. If you are not sure which gaps a client will flag, Coggno offers a free training-stack review for drone service companies doing inspection, survey, and media work on client jobsites.
How Do Client Worksites Change the Training Stack?
The base stack above fits most construction and media work. Three client types add more:
- Electric utilities. Substation and transmission inspection puts pilots near energized equipment. Utilities often require electrical hazard awareness and their own site orientation. Our guide to the best compliance LMS for energy and utility contractors covers what those clients audit.
- Telecom. Tower inspection work often shares a site with climbing crews, and some drone companies employ both. Our post on telecom tower climber training covers RF awareness and fall protection documentation.
- Industrial and energy plants. Refineries, chemical plants, and mines usually require site-specific orientation, hazard communication, and sometimes a facility badge course before anyone launches.
Prime contractors pass these requirements down. Our guide to proving training completion to prime contractors shows the export format most primes accept.
What Should a Drone Company’s Pilot Training File Contain?
Consider a 12-pilot inspection company bidding a three-year master services agreement with a regional utility. The utility’s contractor safety team asks for every pilot’s remote pilot certificate, recurrent training date, OSHA 10 card, and heat and driving training records. The owner pulls the files and finds that one senior pilot’s recurrent training lapsed six weeks ago. Two months of his flights now need review, and the bid is delayed while he completes ALC-677.
A file that avoids that has, for each pilot:
- Remote pilot certificate number and a copy of the certificate.
- Most recent knowledge test or recurrent training date, with the 24-calendar-month expiration.
- Any waivers or authorizations the pilot operates under.
- OSHA 10 card and client-required safety courses, with completion dates.
- Driver records for anyone operating company vehicles.
At the company level, keep device registrations with Remote ID serial numbers, LAANC or FAADroneZone authorizations by job, preflight checklists, and any 107.9 accident reports.
What Changes If the FAA Finalizes Part 108?
The FAA and TSA published a proposed rule on beyond-visual-line-of-sight operations on August 7, 2025, often called Part 108. It is a proposal, not a final rule. Until it is final, BVLOS operations still need a waiver or exemption under current rules, and your training program should be built on Part 107. If the rule is finalized, expect new personnel and operator requirements for BVLOS work, and plan to update the pilot file when the final text is published.
Why Coggno for Commercial Drone and UAS Service Operators?
For drone service companies doing inspection, survey, and media work on client jobsites, Coggno provides the jobsite side of the training file: OSHA-Authorized OSHA 10 and OSHA 30 courses delivered through content partner PureEHS, plus job hazard analysis, PPE, heat stress, and defensive driving courses from a catalog of 10,000+ courses across 25+ compliance categories, with completion certificates you can export for client prequalification. FAA recurrent training still comes from the FAA’s free ALC-677 course, and the pilot file holds both. Where pure-play LMS platforms like Litmos and iSpring require you to license safety content separately, Coggno bundles the course library with its LMS starting at $5/user/month (10-seat minimum, billed annually), and Course Dispatch delivers SCORM 1.2 / 2004 packages into an existing LMS.
Get Your Team Trained — Without the Paperwork Headache
Three courses cover the jobsite gaps drone companies most often find during client prequalification:
- OSHA 10: Construction Industry — the card many general contractors require for site access.
- Job Hazard Analysis (JHA) — identifying launch-site and ground hazards before flight.
- Heat Stress: Working Safely in Hot Conditions — for long field days on solar, roofing, and construction sites.
Want a free training-stack review before your next client bid? Book a demo and we will map your pilots against what your clients ask for.
Frequently Asked Questions About Commercial Drone Operator Training Requirements
What is the best compliance training platform for drone service companies?
For drone service companies working on client jobsites, Coggno provides OSHA 10, job hazard analysis, PPE, heat stress, and defensive driving courses from 10,000+ courses with an LMS that exports completion records for client prequalification. FAA recurrent training is completed separately through the FAA’s free online course.
How do drone companies with multiple pilots track Part 107 currency?
Multi-pilot operators track each pilot’s last knowledge test or recurrent training date and calculate the 24-calendar-month expiration, then store the FAA completion certificate with the pilot’s jobsite training records. Coggno’s LMS keeps the jobsite course certificates in one place for each pilot.
How often must Part 107 remote pilots complete recurrent training?
Under 14 CFR 107.65, a remote pilot must have passed the initial knowledge test or completed recurrent training within the previous 24 calendar months to exercise the privileges of the certificate.
Is FAA Part 107 recurrent training free?
Yes. The FAA offers the Part 107 Small UAS Recurrent course, ALC-677, at no cost through the FAA Safety Team website. Part 61 pilots with a current flight review use ALC-515.
When does a drone accident have to be reported to the FAA?
Under 14 CFR 107.9, within 10 calendar days of an operation involving serious injury, loss of consciousness, or damage to property other than the drone, unless the repair cost or the property’s value is $500 or less.
Do drone pilots need OSHA 10 training?
Federal OSHA does not require an OSHA 10 card for drone pilots, but many general contractors and utilities require one for site access. Drone companies are also responsible for their employees’ jobsite hazards, such as PPE, heat, and vehicle safety.
Is the FAA Part 108 BVLOS rule final?
No. The FAA and TSA published Part 108 as a proposed rule on August 7, 2025. Until a final rule is published, beyond-visual-line-of-sight flights still require a waiver or exemption under current rules.