The draft Civil Drone (Promotion and Regulation) Bill, 2025 was released on September 16, 2025 for public consultation. Ikigai Law has submitted its comments on the draft Bill. This post provides a broad overview of our comments, and you can read our detailed submissions here.
Summary of our comments and recommendations
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Uncertainty through Delegated Legislation: Section 45 empowers the government to regulate almost every operational aspect — from classification and training to traffic management and economic terms of service — through delegated legislation. This creates unpredictability until rules are framed. We suggest publishing draft rules alongside the Bill to allow meaningful consultation.
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Excessive Criminalization: Several violations are punishable with penalties and imprisonment. The Bill empowers authorities to detain drones on suspicion and extends liability to abettors. In practice, this creates the risk of arbitrary disruption of legitimate drone operations — for instance, drones engaged in healthcare logistics or industrial surveys could be grounded based on suspicion alone. Such powers, without clear thresholds or safeguards, not only heighten compliance risks but also breed uncertainty and fear across the industry. We recommend decriminalizing procedural violations, remove imprisonment penalties, and limit cognizable offences to serious safety breaches and those which pose a serious threat to public order.
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Onerous Type Certification Framework: No drone can be manufactured, sold, transferred, or operated without DGCA-issued type certification. Exemptions for model RPAS, nano drones, and prototypes under the 2021 Rules are absent. This creates a regulatory barrier and slows down innovation. We recommend excluding manufacturing (without sale/operation) from mandatory certification, and add exemptions for model RPAS, nano drones, and R&D prototypes within the bill.
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Loss of R&D Carve-outs: The 2021 Rules contained specific exemptions for R&D, testing, and model drones. These are absent in the Bill. While “prototype UAS” is defined, there is no operational clarity, risking a chilling effect on innovation. We recommend introducing explicit carve-outs for R&D, testing, and training, including temporary UINs.
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Security and Emergency Powers: Broad powers allow the government to suspend operations, requisition drones, or prohibit flights on sovereignty, security, or public order grounds, with limited safeguards. We recommend clarifying proportionality requirements, and ensuring that written reasons, and review mechanisms for the exercise of such powers are also specified in the Bill.
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BVLOS Operations: The Bill references Visual Line of Sight (VLOS) and Beyond Visual Line of Sight (BVLOS) operations in its rule-making powers but provides no enabling framework or roadmap. Given that BVLOS is essential for scaling high-value use cases such as healthcare delivery, logistics, surveys etc., we recommend introducing enabling provisions for BVLOS in the primary law. As detailed in Annexure I, we propose a regulatory sandbox approach — a phased, risk-calibrated pathway where operators progress from pilot projects to commercial BVLOS deployment based on demonstrated safety data.
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Transition Provisions: The Bill provides that the Drone Rules, 2021 remain in force until new rules are notified. This avoids a regulatory vacuum but prolongs uncertainty for businesses awaiting clarity on obligations. We recommend publishing a clear transition roadmap to guide how existing certificates and approvals will migrate smoothly to the new regime.
