Civil Aviation governance has long been regarded as a model regime for international cooperation1. Since the adoption of the 1944 Convention on International Civil Aviation (the Chicago Convention), the International Civil Aviation Organization (ICAO) has played a central role in securing safe, interoperable, and cost-effective mobility across national and international airspace. At present, however, this governance architecture is being tested by rapid advances in drone and autonomous aviation technologies2. These developments are bringing into focus transformations in how airspace is used, potentially ushering in a shift from an environment dominated by pilot-controlled aircraft to one increasingly congested at low altitudes and populated by unmanned aircraft systems (UAS) with varying degrees of autonomous capabilities. This transition also brings into focus a need to recalibrate civil aviation governance, raising questions as to how existing institutions and regulatory frameworks can address the risks and regulatory challenges associated with UAS.
Perhaps the first and most visible challenge is a simple awareness of objects in low altitude airspace. As dramatically illustrated by airport shutdowns across Europe in the autumn of 2025, most civil aviation and law enforcement authorities lack the capacity to identify or track small drones at low altitudes3. In some cases, not only were local authorities not able to identify drones supposedly sighted near airports, but they were unable to establish with certainty whether a drone was even present4. While there is growing concern about how malign actors could exploit drone technology5, it is important to emphasize that civil drone technology is widely accessible and can be misused by a wide array of actors from an individual hobbyist to militaries. As such, there is a growing recognition that drones in low altitude airspace are not just a risk to traditional aviation in the skies but could also serve as a platform that could pose significant risks to critical infrastructure on the ground6.
Moreover, standards and certifications for UAS need to adapt to a widely diverse ecosystem of platforms range from small hobbyist drones to drones capable of carrying significant cargo or human payloads. There are also overlapping debates here about human oversight in AI governance. The International Federation of Airline Dispatchers Associations cautions, “The rapid integration of Artificial Intelligence and automation into flight operations presents significant safety risks due to global disparities in operation control standards and the erosion of human oversight.”7 In addition to fragmentation of standards, there is a more fundamental question about how standards and certifications can shift from hardware systems, which operate with relative stability over time to software intensive systems that could significantly change behavior through autonomous learning.8
There are also a number of transport security problems that states face in dealing with UAS. Institutionally, defense and law enforcement organs are likely to be overstretched, making it necessary for transport operators and civilian security institutions to take part in the detection and tracking of UAS. While such measures are already seen in various areas of transport security, measures against drones will involve particular caveats concerning capabilities and credibility of non-government operators, as well as ensuring smooth coordination among the entities involved.
Another problem is where some states may be limited in their governance and technological capacity. In particular, there is a growing trend where developing states have strong demand for low altitude economies as a means of addressing their shortfalls in transport infrastructures and operations. Vietnam9 and Malaysia10 are among states that have staked out ambitious goals for UAS. The problem, however, is that these same states could be limited in their institutional, financial, and technological ability to deal with threatening systems. Moreover, some states, particularly with authoritarian or fragile contexts, could practice transport security in problematic ways, either by focusing more on regime security than public safety, or through neglect. In addition, there is a geopolitical dimension to UAS governance as China has sought to position itself as at the center of ‘low altitude economy’ supply chains.11
As noted at the outset, the ICAO remains a central hub for civil aviation governance and has sought to facilitate the establishment of common best practices to provide guidance to states on the governance of UAS. On the basis of a review of state best practice, the ICAO published its Model UAS Regulations, which are consistent with ICAO standards and offer states implementable regulatory frameworks.12
While national regulatory fragmentation remains a challenge, there have also been developments at the regional level. Civil aviation authorities from the Asia-Pacific region unveiled extensive Reference Materials for Regulators to Facilitate the Regulation of Advanced Air Mobility (AAM) Operations at their 2nd Meeting of Asia-Pacific Regulators on AAM in Singapore held in 2025. The Reference Materials were jointly developed by 24 regional states and civil aviation administrations. The aim was to provide guidance on certifications to industry so as to facilitate the safe adoption of UAS.13
In Europe, the European Union Aviation Safety Agency (EASA), opened for consultation its first regulatory proposal on AI for aviation in November 202514. EASA has also established standards and certifications for UAS in collaboration with European national aviation authorities, manufacturers and operators.15
Yet, at a global level, the effectiveness of the measures to mitigate risks associated with UAS pivots on implementation and operationalization by states. The capacity and institutional differences across countries could undermine international governance and consequently create exploitable loopholes for illicit activities, and also safety and security risks.
UAS are becoming increasingly central to mobility and require a reimagining of how we access the skies is transforming global connectivity. Illustrative of this is the ICAO, the United Nations Department of Operational Support (UN DOS), and the World Food Programme’s launching of the UN Unmanned Aviation Forum, which saw the adoption of the Declaration by the Organizations of the United Nations System on the Development of Harmonized Unmanned Aviation Frameworks in Support of their Respective Mandates, Missions, and Objectives, which noted that coordination harmonization of UAS governance frameworks would assist the UN system in carrying out mandates, missions, and objectives.16
While not capturing international headlines, the ICAO and UN declaration on harmonizing frameworks within the UN system underscores the importance of aligning UAS governance across states. While some states are institutionally and technologically better positioned to take on the civil aviation safety and security challenges posed by UAS and are developing airspace management systems that can manage UAS flights at low altitudes17. When it comes to the global proliferation of a growing UAS ecosystem, cooperation and capacity building will be necessitated to harness the potential benefits afforded by these systems and to address potential risks.
[1] Baldev Raj Nayar, ‘Regimes, power, and international aviation’ International Organization 19(1), Winter 1995, pp. 139-70.
[2] Eugene Tan interview. S12E3: Do You Know What’s in Your Skies? Age of AI podcast, 9 November 2025. https://www.ageofaipodcast.com/1727342/episodes/18159487-s12e3-do-you-know-what-s-in-your-skies
[3] Tamsin Paternoster & Nao Schumann, ‘Fact-checking Europe’s ‘drone problem’: Why are airports closing over drone sightings?’ EuroNews, 20 November 2025. https://www.euronews.com/my-europe/2025/11/20/fact-checking-europes-drone-problem-why-are-airports-shuttering-over-drone-sightings
[4] ‘Norway police end Oslo airport drone probe, citing lack of evidence’ Reuters, 6 November 2025. https://www.reuters.com/world/norway-police-end-oslo-airport-drone-probe-citing-lack-evidence-2025-11-06/
[5] Stefan Wolff, ‘Russia now has a strategy for a permanent state of hybrid war’ The Conversation, 16 October 2025.
[6] James Peterson, ‘High-tech drones are changing warfare – terrorists may soon follow the same playbook’ The Conversation, 12 August 2025. https://theconversation.com/high-tech-drones-are-changing-warfare-terrorists-may-soon-follow-the-same-playbook-262626
[7] Agenda Item 24: Aviation Safety and Air Navigation Priority Initiatives, Global standardization of operational control in the era of AI and automated flight planning. International Civil Aviation Organization Working Paper A42-WP/621, 2025. https://www.icao.int/sites/default/files/Meetings/a42/Documents/WP/wp_621_en.pdf
[8] Hymalai Bello et al. ‘Towards certifiable AI in aviation: landscape, challenges, and opportunities, arXiv, 13 September 2024. https://arxiv.org/html/2409.08666v1?utm_source=chatgpt.com
[9] ‘Viet Nam’s low-altitude economy to hit US$10 billion by 2035’ Socialist Republic of Viet Nam Government News, 17 December 2025. https://en.baochinhphu.vn/viet-nams-low-altitude-economy-to-hit-us10-billion-by-2035-111251115091625929.htm
[10] CAAM & Futurise to Launch Advanced Air Mobility Concept of Operations by 1st Quarter of 2026, Civil Aviation Authority of Malaysia, 11 September 2025. https://www.caam.gov.my/wp-content/uploads/2025/09/NR-CAAM-Futurise-To-Launch-AAM-Concept-of-Operations-by-Q1-2026.pdf
[11] ‘China’s “low-altitude economy” is taking off,’ The Economist, 12 June 2025.
[12] ‘ICAO Model UAS Regulations.’ https://www.icao.int/UA/icao-model-uas-regulations
[13] ‘Asia-Pacific Region Adopts Reference Materials for the Regulation of Air Taxis and Drones,’ Civil Aviation Authority of Singapore, 17 July 2025. https://www.caas.gov.sg/who-we-are/newsroom/Detail/asia-pacific-region-adopts-reference-materials-for-the-regulation-of-air-taxis-and-drones
[14] ‘EASA’s first regulatory proposal on Artificial Intelligence for Aviation is now open for Consultation,’ European Union Aviation Safety Agency, 10 November 2025. https://www.easa.europa.eu/en/domains/civil-drones/news
[15] ‘Drones & Air Mobility Landscape,’ European Union Aviation Safety Agency, 2025. https://www.easa.europa.eu/en/domains/drones-air-mobility/drones-air-mobility-landscape
[16] Declaration by the Organizations of the United Nations System on the Development of Harmonized Unmanned Aviation Frameworks in Support of their Respective Mandates, Missions, and Objectives, International Civil Aviation Organization. 30 April 2025. https://www.icao.int/sites/default/files/safety/UA/Documents/Declaration-UN-Unmanned-Aviation-Forum_04August2025.pdf
[17] Unmanned Aircraft System Traffic Management (UTM), Federal Aviation Administration, 2025. https://www.faa.gov/uas/advanced_operations/traffic_management; Easy Access Rules for U-space (Regulation (EU) 2021/664), European Union Aviation Safety Agency. https://www.easa.europa.eu/en/document-library/easy-access-rules/easy-access-rules-u-space-regulation-eu-2021664
*Ryo Hinata-Yamaguchi is an Associate Professor at the Institute for International Strategy, Tokyo International University; Senior Non-Resident Fellow at the Atlantic Council Scowcroft Center for Strategy and Security Indo-Pacific Security Initiative; and Adjunct Senior Fellow at the Pacific Forum. Ryo specialises in issues relating to defence, security, and transport governance in the Indo-Pacific.
**This commentary was supported by a Japan Society for the Promotion of Science (JSPS) Grant-in-Aid for Scientific Research ‘Global Governance of Civil Aviation in the Indo-Pacific,’ (2025-2028). Project Number 25K04983. https://kaken.nii.ac.jp/grant/KAKENHI-PROJECT-25K04983/
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