Critical Comparative Analysis of UAS Legislative Developments

Abstract. High growth and subsequent additional risks of the UAS sector have attracted the interest of various researchers and state legislation makers across the world. This article aims to review the most important, recent developments in UAS regulations of three major countries (USA, Japan, Australia) and of European Union Aviation Safety Agency (EASA). A comparative analysis and critical thinking of six (6) factors (UAS classification, Flights over people-Crowds of people, Registration systems, UAS geographical zones, Private Data-Privacy, Law Enforcement System) are conducted, in order to define areas of improvement in the fields of UAS flight risks and safety. Our studies show that although major steps have been done forward by these regulatory frameworks, there are still deficiencies that should be overcome. Finally, we advocate some proposals that could be used in the prospective legislative amendments.