Regulations
Remote Pilot in Command: Who Is Actually Responsible
Three jobs, one to three people, and one of them carries every consequence.
Key takeaway
The remote pilot in command is directly responsible for and the final authority over the operation, and that responsibility cannot be delegated — including when somebody else is holding the controller.
Part 107 defines three roles. One of them carries the entire legal weight of the operation, and it is not necessarily the person holding the controller.
| Role | Certificate required? | What they do |
|---|---|---|
| Remote pilot in command | Yes | Directly responsible for, and the final authority over, the operation |
| Person manipulating the flight controls | No, if directly supervised | Flies the aircraft |
| Visual observer | No | Watches the aircraft, assists with seeing and avoiding |
A single person can hold all three. On a larger job they are three people. The legal picture does not change either way: the remote PIC is responsible.
What "directly responsible and final authority" means
Section 107.19 gives the remote PIC a set of duties that are worth reading as a list rather than a paragraph:
- Ensure the operation poses no undue hazard to other aircraft, people or property in the event of a loss of control
- Ensure the operation complies with all of Part 107
- Have the ability to direct the small unmanned aircraft to ensure compliance
- Ensure the aircraft is in a condition for safe operation before flight, and discontinue flight if it stops being so
- Ensure any required authorization or waiver is in place before the operation
The phrase that does the most work is final authority. If a client wants a shot that requires flying over a crowd, the remote PIC decides. If a producer says the schedule requires launching in deteriorating visibility, the remote PIC decides. That authority is not a courtesy — it is an obligation, and declining is part of the job description.
Letting somebody else fly
This is the part people get wrong, usually in the direction of assuming it is not allowed.
An uncertificated person may manipulate the flight controls, provided a remote PIC is directly supervising them and the remote PIC has the ability to immediately take direct control.
Two things follow.
"Immediately take direct control" is a physical capability, not an intention. In practice it means a dual-controller setup with a trainer link, or standing close enough to take the single controller instantly. Watching from across a field with no way to intervene does not satisfy it.
The remote PIC remains responsible for everything. If the person flying puts the aircraft into a building, the violation belongs to the remote PIC. Handing over the sticks hands over none of the liability.
This provision is what makes commercial crews, training and client demonstrations workable. It is not a loophole for flying without a certificate.
The visual observer
A visual observer's job is narrow and specific: maintain visual line of sight with the aircraft and be able to communicate with the remote PIC and the person flying, so that all three share the same awareness of where the aircraft is and what is around it.
What a visual observer cannot do:
- Extend visual line of sight. This is the big one. A chain of observers positioned down a pipeline does not make a beyond-visual-line-of-sight operation legal. VLOS is a requirement on the remote PIC and the person flying — the observer supplements it, never substitutes for it.
- Act as remote PIC. Not without holding the certificate and taking on the role explicitly.
- Watch two aircraft. Under 107.35 a person may act as remote PIC or visual observer for only one aircraft at a time.
There is no requirement to have a visual observer at all. Where you use one, they must be able to communicate with you — which in practice means being close enough to talk, or having radios that actually work at the distance involved.
Visual line of sight, precisely
Section 107.31 requires the remote PIC, the person manipulating the controls, and any visual observer to be able to see the aircraft throughout the flight — with vision unaided by any device other than corrective lenses — well enough to:
- Know the aircraft's location
- Determine the aircraft's attitude, altitude and direction of flight
- Observe the airspace for other air traffic or hazards
- Determine that the aircraft does not endanger anyone's life or property
"Corrective lenses" means glasses or contacts. Binoculars do not count. A first-person-view headset does not count. FPV flying is permitted, but only with a visual observer maintaining actual VLOS — the headset never satisfies the requirement by itself.
Brief interruptions are acceptable, which is what makes flying behind a tree or around a chimney workable. Continuous line of sight through the whole flight is not the standard; the ability to see the aircraft throughout the operation is.
One person, one aircraft
Section 107.35 is short and absolute: a person may act as remote PIC or visual observer for only one unmanned aircraft at a time.
No swarms under standard Part 107. No running two aircraft from one station. This is waivable under 107.205, and waivers for multiple aircraft operations do exist, but they are the exception and they are specific.
Where this shows up on the exam
Crew roles sit in Regulations, which is 48 percent of the current test. The questions almost always probe one of four things:
- Who is responsible. The answer is the remote PIC, in every framing of the question.
- Whether an uncertificated person may fly. Yes, under direct supervision with the ability to take immediate control.
- What a visual observer can and cannot do. They cannot extend VLOS.
- What counts as unaided vision. Corrective lenses only.
Frequently asked questions
What is a remote pilot in command?
The remote pilot in command is the certificated person directly responsible for, and the final authority over, a small unmanned aircraft operation under Part 107. The role carries responsibility for compliance, safe operation, and any required authorization, and it cannot be delegated.
Can someone without a Part 107 certificate fly a drone commercially?
They may manipulate the flight controls if a remote pilot in command is directly supervising and has the ability to immediately take direct control. The remote PIC remains fully responsible for the operation, so this is supervision rather than a way around certification.
What does a visual observer do?
A visual observer maintains visual line of sight with the aircraft and communicates with the remote PIC and the person flying, so the crew shares awareness of the aircraft's position and surrounding hazards. No certificate is required.
Can visual observers extend visual line of sight?
No. Visual line of sight is a requirement on the remote pilot in command and the person manipulating the controls. A chain of observers does not make a beyond-visual-line-of-sight operation legal; that requires a waiver of 14 CFR 107.31.
Can I use binoculars or FPV goggles to maintain visual line of sight?
No. Section 107.31 requires vision unaided by any device other than corrective lenses, meaning glasses or contact lenses. First-person-view flying is permitted only with a visual observer maintaining actual unaided visual line of sight.
Can one pilot fly two drones at once?
No. Under 14 CFR 107.35 a person may act as remote pilot in command or visual observer for only one unmanned aircraft at a time. The requirement is waivable under 107.205, but not by default.
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