Model aircraft flying in a club: Article 16, association rules and flying sites

Many plane spotters have a remote-controlled model in the basement at some point – a glider, a jet replica or a multicopter. If you fly it regularly, you quickly arrive at the question: is the EU drone license enough, or does it work differently in a club? The answer lies in Article 16 of Implementing Regulation (EU) 2019/947. It opens up a separate route through drone law for model aircraft clubs and associations. This guide explains what Article 16 governs, how Germany implements it in the Air Traffic Regulations (Luftverkehrs-Ordnung, LuftVO), which association rules apply in everyday flying, when you still need a permit and why airports stay off limits even for club pilots.

Three routes for model pilots

Since EU drone law took effect, every remote-controlled model aircraft is legally an unmanned aircraft – no matter whether it is a wooden glider or a quadcopter. EASA has therefore opened up three options for model pilots:

• Open category: You fly like any other drone pilot under subcategories A1 to A3, with the appropriate proof of competency and a maximum altitude of 120 meters. For classic model aircraft there is even a class of its own there, C4 – details are in Drone classes C0 to C6.
• “Specific” category: With an operational authorization or a standard scenario. For hobby pilots this is usually too much effort; what the procedure looks like is explained in Specific category, SORA and standard scenarios.
• Club or association under Article 16: You fly under the conditions the authority has approved for your association. According to EASA, these limits can deviate from those of the open category.

In addition, the regulation also provides for geographical zones under Article 15, in which states can relax or tighten requirements of the open category. As an example, EASA cites slope soaring with unmanned gliders up to 10 kg, which may fly beyond the 120-meter limit above ground there as long as they stay less than 120 meters above the pilot.

What exactly Article 16 governs

Article 16 is short but consequential. At the request of a model aircraft club or association, the competent authority can grant an authorization for flight operations within its framework. The basis is either the relevant national regulations or the club’s own procedures, organizational structure and management system. In the second case, the club must ensure four things:

1. The members know the conditions and limits of the authorization.
2. The members are supported in reaching the minimum competency needed for safe flying.
3. The club steps in when it learns that a member is not following the rules, and informs the authority if necessary.
4. The club provides the authority, on request, with the documents for oversight and monitoring.

The authorization itself sets the conditions under which flying takes place. Important for travelers: it is valid only in the territory of the member state that issued it. In addition, states may allow clubs to register their members in the national operator register. And Article 9 allows states to set a different minimum age for remote pilots within a club – so the regular minimum age of 16 for the open and specific categories does not have to apply there.

According to EASA, EU drone law did not yet fully apply to operations in model aircraft clubs until January 1, 2023. Since then the framework has been fully applicable, and club flying runs under the authorizations pursuant to Article 16.

How Germany implements Article 16

In Germany, two sections of the Air Traffic Regulations (LuftVO) govern the club route:

• § 21g LuftVO describes the authorization. The Federal Ministry of Transport or a federal authority designated by it can grant nationwide air sports associations an authorization under Article 16. It entitles the association to define procedures for model aircraft operation and develop them on a risk basis, as well as to train members and issue certificates.
• § 21f LuftVO governs operations. Members of air sports associations and association-organized clubs may operate model aircraft deviating from the EU requirements of the open category if they comply with the association’s internal procedures. Some basic duties of the remote pilot from the EU annex still apply.

Who holds the authorization is shown by the federal drone portal: according to it, the Federal Aviation Office has granted an operating authorization to the German Model Flyers Association (DMFV) and the Model Aircraft Sports Association Germany (MFSD). The MFSD organizes model aircraft sport within the sphere of the German Aero Club (DAeC). In practice that means: you are a member of a local club affiliated with one of these associations, or an individual member of the association directly – and you fly under its rules.

The association rules in everyday flying

What this looks like in concrete terms is shown by the guideline “Model aircraft operations in the DMFV” (as of May 2024). It summarizes the operating rules in 16 points. The most important ones at a glance, in our own words:

Topic	Rule according to the DMFV guideline
Crowds of people	Do not fly over them, keep at least 50 m lateral distance
People and animals	No approaching and no overflying below 25 m above ground; if you fly lower, keep at least 25 m lateral distance from uninvolved persons
Visual range	Model always within visual range; FPV with goggles up to 30 m above ground counts as visual operation
FPV above 30 m	Only with a second person who points out hazards
Multicopters	Outside designated model flying sites, 120 m above ground at most
Autonomy	No fully autonomous flights; intervention possible at any time, gyros and return-to-home function allowed
Right of way	Manned aircraft always have priority, the model gives way by descending or lands
Purpose	Sport and recreation only, no commercial operation under association rules
Alcohol	No alcohol or other psychoactive substances before or during flying

In addition come data protection for camera models, the duty to report accidents and safety-relevant events to the association through the FIDA database, and the landowner’s consent if you take off from someone else’s land. How the use of goggles works in detail is covered in the article FPV drones.

Proof of knowledge, registration and insurance

Proof of knowledge from 2 kilograms

§ 21f para. 2 LuftVO requires knowledge in three areas for model aircraft with more than 2 kg takeoff mass: safe control of the model, relevant aviation law and local airspace structure. You provide the proof through training by an authorized air sports association, before the first operation. The certificate of participation is valid for five years and has to be with you when flying. The DMFV offers this proof of knowledge online and, according to its guideline, also requires it if you want to fly higher than 120 m above ground. Anyone who wants to fly under the DMFV authorization without association membership or as a member of a foreign association needs the DMFV proof of knowledge, according to the guideline, even for models under 2 kg.

Registration as an operator

According to the DMFV guideline, EU registration is required for model aircraft above 250 grams or with a camera. The association can handle the registration for its members with the Federal Aviation Office – exactly this option is provided for by Article 16. You attach the registration number (e-ID) to the model, and you update your data yourself when needed. How registration works without an association is covered in Registering a drone with the LBA.

Liability

For model aircraft, there is in principle a statutory owner liability insurance requirement. Associations offer group insurance for this; the DMFV requires certain plans for models above 1,000 g that fly outside model airfields. Members of other associations who fly under the DMFV authorization must show equivalent coverage. What a policy has to cover in general is explained in Drone insurance.

When you still need a permit

The club route does not replace every official permit. § 21f para. 3 LuftVO names four cases in which you need a permit:

The aviation authority of the German state where the site is located is responsible. The application is made by the association member themselves or – for a club – by a person authorized to represent it. The authority can additionally require the landowner’s consent, an expert opinion on the suitability of the site and airspace, as well as assessments on nature conservation and noise protection, if that is necessary in the individual case. Nature conservation and emission control law expressly remain unaffected.

The model flying site

Most club pilots take off from a fixed site: a mown strip, a pilots’ line, a fence to the spectator area, often a small clubhouse. For operations requiring a permit – such as heavy large-scale models or combustion engines when residential areas are closer than 1.5 km – the state aviation authority issues the permit for exactly this site. The club usually sets out the flying sector, pilot position and operating hours in site rules.

For all other airspace users, the sites are visible: authorized association sites are entered on the federal dipul map. The portal points out that the displayed radius does not show the actual flying sector and that model flying is to be expected around the marked area. How to read the map is explained in Geo-zones and the dipul map. If you prefer to look for small airfields on aeronautical charts, you will find tips in Finding small airfields on maps.

According to dipul, model flying generally takes place in Class G airspace. In control zones or with special operating arrangements, the upper limit can differ. What the individual airspace classes mean is covered in Airspace classes A to G.

Airports, airfields and control zones

For plane spotters this is the most interesting point – and the answer is clear. The DMFV guideline requires observing the geographical zones under § 21h para. 3 LuftVO without exception, just as in operations in the open category. Among other things, this means:

• Airports: 1,000 meters laterally around the airport boundary as well as a corridor of 1,000 meters on either side of the runway centerline, each extended 5 kilometers in the approach and departure direction. Operation there is permitted only in the “specific” category.
• Other airfields: 1.5 kilometers around the boundary, only with the consent of the air supervision, flight operations management or the operator – or in the “specific” category.
• Control zones: only with clearance from air traffic control.

A model in the approach corridor is just as dangerous for an airliner as a camera drone. How seriously airports take this is shown by the articles Drones near airports and Drone sightings at airports. That a model flying site can nevertheless be located near an airfield is not a contradiction: such sites operate with arrangements and defined limits that apply to the site – not to spontaneous flights at the fence.

Club or open category?

Both routes have their place. You can usually fly a small camera drone for vacation pictures without complications in the open category. If, on the other hand, you build gliders, powered models or jets and fly regularly at one site, you benefit from a club.

How to find a suitable club and what to expect as a new member is described in Joining an air sports club. Many air sports clubs have a model aircraft section alongside gliding or powered flight – and if you later want to get into a real cockpit yourself, the glider pilot license (SPL) is the next step.

On vacation: the authorization stays at home

Because Article 16 limits the authorization to the issuing state, you don’t take your club rules across the border. Abroad, you fly either in the open category of the host country – with EU proof of competency and observing the geo-zones there – or under the rules of a club authorized there, provided it admits guests. The basics are summarized in Taking your drone on vacation; country specifics can be found in Flying a drone in Austria and Flying a drone in Switzerland.

Model flying and plane spotting

Model flying and spotting are closer together than they seem. Both thrive on a close eye for silhouettes, wind and light. If you build a scale model of an airliner, you study photos of landing gear, antennas and livery – exactly the knowledge that also helps you identify a type at the fence. A nice introduction to the history is offered by the German Gliding Museum with model flying on the Wasserkuppe, which shows a large model aircraft collection alongside gliders. And if you prefer to put models on a shelf, you will find the right entry point in Collecting aircraft models.

At airfield festivals, both worlds often meet. Photography is usually expressly welcome there – but the drone or your own model stays on the ground unless the organizer rules otherwise.

Common mistakes

• Mistaking club rules for a free pass: Article 16 relaxes the requirements of the open category, but does not lift geo-zones, control zones and airport areas.
• Underestimating weight: A large glider with a battery quickly exceeds 2 kg – then you need the proof of knowledge, and above 12 kg additionally a permit.
• Spontaneous night flying: A lit model in the evening sky looks great, but any operation at night requires a permit under § 21f LuftVO.
• Applying association rules on vacation: The authorization ends at the national border.
• Not reporting accidents: The DMFV requires reports of safety-relevant events; in case of injury to persons or high property damage, you must additionally inform the police according to the guideline.

Conclusion

Article 16 of the EU drone regulation gives organized model aircraft flying a framework of its own. In Germany, it runs through the air sports associations: § 21g LuftVO allows them to define procedures and train, § 21f governs what their members may do. From 2 kg you need proof of knowledge; heavy models, rockets, combustion engines near residential areas and night flights still require a permit. The authorization is valid only in your own country – and it changes nothing about the zones around airports.