Testing in Unmanned Aviation

The Estonian defense technology industry, and more specifically, unmanned aviation, has grown at a wild speed in recent years, both in terms of the turnover and profit of existing companies and the addition of many new players. The sector is extremely R&D-intensive and requires extensive product testing—first in a laboratory environment, but sooner or later moving into real airspace.

Key Companies in the Sector

Threod Systems
Krattworks
LendurAI
DefSecIntel
Meridein
Helsing
CAFA Tech
SkyCorp

All of these and other similar companies are involved in the development, manufacturing, and operation of specific category drones. Additionally, there are several companies in Estonia that deal with drone surveillance and/or counter-drone measures (Marduk, Frankenburg, Hextech, etc.), who also test drone-related activities in live airspace, but they do not develop drones themselves.

With the growth of the sector, several legislative challenges have emerged that prevent companies from testing and bringing products to market at the desired speed to meet the highest international competitive standards. This analysis addresses the main legislative obstacles in unmanned aviation and provides an overview of what is being done to resolve them.

Operation of Specific Category Drones

As per the regulations of the European Union, the operation of unmanned aircraft is divided into open and specific categories. The open category includes typical camera drones used for photography and videography, and other hobby vehicles.

Main rules for the open category

The drone must not be flown directly over assemblies of people.
Flights must always take place within the visual line of sight or with the help of an airspace observer. It is not enough to see the drone’s location through the camera.
The drone must weigh less than 25 kg.
The maximum permitted flight altitude is 120 m. Additionally, lower altitude restrictions may apply in some areas.
Dangerous goods must not be transported, and damage to people or property must not be caused.

If even one of the above conditions for the open category is not met, the requirements for the specific category apply. All the aforementioned companies, as well as future unmanned aviation companies operating in similar fields, operate specific category aircraft.

In today’s legislation, there are two direct options for operating specific category drones:

The company applies for an operating authorization for the specific category for itself, a specific drone, and a flight situation, which includes the corresponding risk analyses. The variants of this are defined by European legislation and are divided into 4 categories:

By holding an operating authorization, the owner can apply to the Transport Administration for limited airspace (for flights higher than 120 m) anywhere in open airspace, according to the conditions of their authorization. The notice period for this is generally a few weeks, but also depends on the experience of the operators themselves and the general alignment of circumstances.

2. The alternative option is for a party in Estonia to conduct a risk analysis for a specific land and airspace, setting the flight area there as restricted, thereby creating a “test area” that does not conform to general rules. Legislation already allows this, but it has not yet been used.

This legal solution has not been used in Estonia so far, and no party yet fully knows how to go through the process. This process includes the analysis and mitigation of both ground and air risks for a specific area, including operating procedures, training, drone surveillance, etc. Simply put, the airspace operator, not the aircraft operator, assumes responsibility for what happens in that specific airspace. This, in turn, allows aircraft to be operated in restricted airspace by companies that do not necessarily have the corresponding specific category operating authorization yet. The airspace operator has ensured safety through preliminary risk mitigation measures, thereby allowing riskier aircraft and operators to use their airspace. The airspace operator can activate their predefined “test area” for a period set by them with approx. 24 hours’ notice—during this time, other manned and unmanned air traffic is prohibited in that airspace.

Currently Planned Test Areas

With the increasing popularity of unmanned aircraft, several public sector institutions have developed a need to test aircraft themselves and also want to offer this opportunity to the private sector. The primary need for all institutions, however, is to create a test area to enable their own activities, especially training activities. Offering services to companies is secondary or tertiary, depending on the party.

Estonian Aviation Academy (Eesti Lennuakadeemia)

The Estonian Aviation Academy’s test area, if successful, should meet the expectations of the private sector as closely as possible, enabling companies that do not yet have a specific category operating authorization to fly in the test area. Certain requirements would still apply to the testing companies to ensure safety, but they would not have to go through the full specific category operating authorization process, thereby enabling new products to be tested with a faster development cycle.

The Estonian Aviation Academy relies on Commission Implementing Regulation 2019/947 for the creation of the test area, which gives Member States the right to define geographical areas, based on a risk assessment, where the operation of an unmanned aircraft system is exempt from one or more open category requirements. The risk analysis focuses on specific use cases, including flying beyond visual line of sight and higher than 120 m, and flight operations of unmanned aircraft weighing more than 25 kg, outlining the limitations, requirements, and regulations for operation in the test area, as well as the risks associated with the use cases and possible mitigation measures. Consequently, procedures and rules for using the test area are created, and if necessary, additional technical requirements are established, which the operator must follow when operating in the test area.

Location: Tartu County.
Flying allowed both with and without a specific category operating authorization.
Dimensions: Approx. 10 x 30 km, permanent geographical area up to 120 m in height, temporarily activatable airspace with an anticipated maximum height of 2.8 km.
Planned capabilities: BVLOS flying and the dropping, spreading, or spraying of objects or fluids.

STATUS

The Estonian Aviation Academy has submitted an application to the Transport Administration along with a thorough risk analysis, which would allow for flight activities that do not fall under the open category to be conducted in segregated airspace without having the corresponding specific category operating authorization. The risk analysis and the segregation of airspace must then be approved by the Airspace Usage Management Committee established under the Ministry of Climate. Based on the methodology of the risk analysis for the planned test area, there is a plan to create a guide in cooperation with the Transport Administration for creating such areas, as there is currently no widespread understanding in Estonia of how to perform a risk analysis for establishing such an area that would also function as a test area. Additional infrastructure being built to support the flight area is currently in the planning stage. The Aviation Academy’s goal is to complete the official procedures required for the creation of the airspace by the end of 2025.

Estonian Academy of Security Sciences (Sisekaitseakadeemia – SKA)

The Estonian Academy of Security Sciences is developing a new training and exercise complex in Väike-Maarja for the Academy’s training activities, one part of which is unmanned aviation. In addition to training activities and internal security institution training, they want to enable the testing of unmanned aerial vehicles for the private sector.

However, unlike the Aviation Academy’s area, there will be no direct legal opportunity for companies to test there without a specific category operating authorization. SKA sees the possibility in such situations of taking on the role of the operator themselves, meaning they would operate the drone on behalf of the company (SKA has a specific category operating authorization). The flight area is similarly restricted with 24 hours’ notice, meaning no random person can fly there at the same time, but the risk analysis performed for it is one level lower, which is why flying without a specific category authorization is not possible.

Location: South of the SKA training center, starting from Väike-Maarja
Dimensions: 11 x 50 km, altitude 120 m up to 1500 m.
Flying allowed based on an existing specific category operating authorization, obtaining the flight permit would be accelerated as the closure of the segregated area has been pre-coordinated.
The notice period for closing the airspace is 24 hours.
Limitations: There is no runway for take-off and landing, meaning only NATO Class 1 vertical take-off and landing capable aircraft can be flown.
SKA does not initially plan to actively advertise the service to the private sector, but the service is already available by asking directly. SKA’s motivation for operating the service is to thereby fund its Remote Sensing Research and Development Centre.
It does not allow for practicing kinetic activities (e.g., dropping objects or flying drones against a target).
For both training purposes and offering to companies, SKA would like to provide communication jamming functionality, but currently they have no legal possibility to do so without the help of the Defence Forces. Input for a legislative amendment has been given to the Ministry of Justice and Digital Affairs (JDM); more detailed information on this is in the chapter on electronic communication jamming.

STATUS

Infrastructure and buildings will be constructed in Väike-Maarja in 2027-2028, but unmanned aircraft can already be tested there with an existing specific category operating authorization. For example, SKA has signed a cooperation agreement with Threod Systems (one of the two drone-developing companies in Estonia that has SORA at all) so that Threod can test in their area. As of 06.10.2025, a permanent airspace exists in the Väike-Maarja test area, the part above the training center is permanent, and the rest of the flight area can be activated with 24 hours’ notice.

Companies without a specific category operating authorization cannot officially/legally test in the SKA area. In these situations, SKA works with the company to enable testing in other ways, such as operating the aircraft themselves, but they currently do not plan to create a legal opportunity for testing without a specific category operating authorization, similar to the Aviation Academy.

Primary surveillance systems that can detect drones with remote identification are currently available and operating in Väike-Maarja. In the future, they will also be able to detect drones whose identification is switched off (or non-existent).

Nurmsi Test Centre

The Nurmsi test centre is a training area managed by the Defence League, along with a drone competence centre complex. The primary goal is to conduct unmanned training flights for the Defence Forces and the Defence League, but the test centre is also open to scientific experiments of the Estonian National Defence College and companies involved in scientific cooperation (such as Threod and Krattworks), as well as other companies that express a wish to use the test centre’s facilities for drone flights.

Location: Nurmsi airfield territory, east of Paide.
Dimensions: A circle with an 11 km radius, a temporary no-fly zone.
Flying allowed: Under the military aviation regulations, meaning simplified conditions.
Future goal: To create a UAS/C-UAS competence centre in Nurmsi.

STATUS

Work is underway to find the missing inventory and staff. Airspace management has not been topical yet, but there is a 2.5 km grass airfield in front of the building, which is open for booking. The airfield is currently in active use, but only simple testing is being carried out. Since flying is allowed at Nurmsi and other defence polygons under the military aviation regulations, all drone developers try to get slots there through personal connections. Currently, the cooperation opportunities offered by Nurmsi are not publicly known, and everything is done through personal contacts. The Defence League says it cannot cope with the growing testing demand alone, and therefore awaits other test centre’s to supply this growing demand.

Metrosert – Applied Research Centre (RUK)

The goal of Metrosert’s Applied Research Center (RUK) is to provide phased testing and development service capabilities for drones, covering the needs of the private, security, and military sectors. The center offers testing solutions for product development and necessary R&D support, starting from testing civil oriented products in the open and specific categories, and military products in NATO Class I and II. The long-term vision includes supporting companies in the NATO Class III certification process.

LINES OF ACTIVITY

The unmanned aviation research team develops concepts across different product subsystems and drone types.
The communication and navigation research team focuses on secure communication, various communication technologies, navigation systems, sensors, and data center solutions.
The flight physics research team studies aerodynamics, materials, platform development, new energy carriers and more efficient engines.

Internal Laboratories include a subsystem laboratory, which allows testing corrosion resistance, vibration, the effect of low pressure, performance in different environments (including dust environments), and electronics integration. Planned Laboratories: EMC and radiolocation laboratory for conformity tests, R&D activities, and EW-related testing (emission, immunity, and radar reflections), as well as a large-scale environmental laboratory.

STATUS

The subsystem laboratories are partially in place, with full commissioning planned by the end of 2025. The large climate and EMC laboratory is planned to be opened for customer service in the first quarter of 2027.

The development of field test areas is planned to be launched in the first quarter of 2026, including a small-scale area near Tallinn for operational testing and flight trials of multirotors. The operation of the test area is planned to be organized through a Light UAS Operator Certificate (LUC), which allows for safety, capability, and operational tests. The location of the larger flight area is assumed to be in Western Estonia, where agreements for the use of the flight area are hoped to be reached by the end of 2025.

Key Expectations from Private Sector for Potential Test Areas

The company should not initially need a specific category operating authorization for conducting flights, as in the early product development phase, it would have to be reapplied for constantly due to changes in the operated drone.
Beyond Visual Line of Sight (BVLOS) flying, the flight corridor should be at least 5 (width) x 50 (length) x 1.5 (height) km.
Flying non-standard and heavier than 25 kg drones.
Enabling special purpose capabilities – e.g., swarming and catching drones from the air.
Communication jamming – companies want to test electronic communication jamming for both counter-drone measures and improving the communication capabilities and shielding of their own drones. More detailed information is in the chapter on electronic communication jamming.
Object dropping – companies want to drop objects from aircraft to test target hitting, as well as flying against a target. More detailed information is in the chapter on the Arms Act.
Flight areas should be accompanied by ground infrastructure to support flight operations (a physical location and support infrastructure for conducting flights).
Quick notice – flight time should be available with 24 hours’ notice.

Electronic Communication Jamming

Several companies as well as educational institutions see a growing need to test electronic communication jamming in connection with unmanned aircraft, for the purposes of counter-drone measures, communication jamming, and ensuring the communication capability and shielding of their own operated drones.

Both Estonian companies and international experts consulted during the preparation of the analysis named electronic communication jamming as potentially the biggest competitive advantage in the test area market in Europe—test areas where flying is permitted are widespread in Europe today, and Estonia is rather lagging behind in this regard.

If Estonia could create an operative and functioning synergy of flight areas and electronic communication jamming testing, it could be a competitive advantage not only for the companies developing solutions here but also for the test areas themselves, and attract international companies to test their products in Estonia.

Today, electronic communication jamming is legally permitted only by the Police and Border Guard Board (PPA) and the Defence Forces (including PPA only in the performance of official duties, which means internal security institutions are not allowed to do it during training). Communication jamming requires a case-by-case procedure and coordination by the Consumer Protection and Technical Regulatory Authority (TTJA) and several different institutions. The Defence Forces are subject to an exception and are allowed to carry out electronic communication jamming during training and exercises, provided they have completed the relevant notification process.

The Ministry of Justice and Digital Affairs is currently preparing an amendment to the Electronic Communications Act, which will expand the permitted possibilities of the law. The planned implementation period for the legislative amendment is spring/summer 2026. Accelerate Estonia and the educational institutions have provided their recommendation to allow electronic communication jamming with the legislative amendment for product development, R&D, and training purposes, and to expand the circle of institutions that have this legal right (by adding the Aviation Academy and the Academy of Security Sciences to the list of institutions). In addition, it is recommended to increase the frequency spectrum within which communication jamming is allowed.

Today, domestic electronic communication jamming has been made very difficult legislatively, even though communication jamming by Estonia’s eastern neighbour has been a constant phenomenon on the eastern border of Estonia for several years.

The topic of electronic communication jamming is a very big change-driving factor in ensuring the protection of critical infrastructure. In connection with this, there are legislative questions about who exactly is allowed to perform counter-drone measures and what means to use for this (including how complicated or simple the accompanying coordination process is).

This affects critical infrastructure managers (e.g., Elering), operators of logistical hubs (e.g., Tallinn Airport), security companies protecting several of the aforementioned objects, and internal security institutions, which are the last and most serious users of force in performing counter-drone measures.

Questions Regarding the Arms Act

Separate questions have arisen for some drone manufacturers regarding the Arms Act and its implementing acts—whether, how, and under what conditions it applies to development activities and testing. More specifically, there has been confusion about when a drone capable of carrying combat ammunition is considered a weapon system and under what conditions the obligation to apply for a corresponding activity license applies. The Ministry of Defence and the Police and Border Guard Board have offered clarification to this question as follows:

On 07.06.2025, the Minister of Defence’s Regulation No. 7 “The detailed list and classification of military weapons, weapon systems, military weapon ammunition and combat ammunition and their parts, including essential parts or components” (hereinafter referred to as the Classification Regulation), established under § 83³ section 3 of the Arms Act, entered into force, which is an important regulation for achieving legal clarity.

Weapon System

A drone could be considered an essential part of a weapon system—a weapon platform—only if a military weapon specified in § 83³ section 1 of the Arms Act (a handheld firearm, a heavy weapon, or another weapon that is not a firearm) is integrated into it, along with the necessary aiming and fire control devices for its functioning (§ 6 section 2 of the Classification Regulation). A drone without the integration of a military weapon is not a weapon system or its essential part. Therefore, the manufacture of a drone without adding a weapon does not require an activity license for the manufacture of a weapon system in the sense of the Arms Act.

IN SHORT

The manufacture of a drone for which the capability to add a military weapon is created, but during the manufacture of which a military weapon is not handled, is not subject to the license obligation specified in the Arms Act.

Combat Ammunition

A drone designed and manufactured for military purposes (e.g., a “loitering munition,” which is capable of remaining on standby for target surveillance and destruction) becomes combat ammunition in the sense of the Arms Act when an essential part of the combat ammunition is installed on it.

According to § 9 section 2 of the Classification Regulation, an essential part of combat ammunition is a charge, a fuse, or another part or component that contains explosive, pyrotechnic substance, igniting substance, or other chemical substance capable of ignition or explosion.

According to § 83³³ section 1 point 6 of the Arms Act, an activity license is required for the manufacture of ammunition or combat ammunition containing explosive material. According to § 83³³ section 1 point 1 of the same paragraph, an activity license is also required for the manufacture of combat ammunition that does not contain explosive material but contains, for example, a pyrotechnic substance, igniting substance, or other chemical substance capable of ignition or explosion.

The obligation for an activity license for the manufacture of combat ammunition containing explosive material and combat ammunition not containing explosive material applies when the undertaking, in the course of its activity, handles an essential part of combat ammunition specified in the Classification Regulation—a charge, a fuse, or another part or component that contains explosive, pyrotechnic substance, igniting substance, or other chemical substance capable of ignition or explosion. If the undertaking’s activity only involves handling parts of combat ammunition specified in the Classification Regulation that are not essential parts, there is no obligation for an activity license.

IN SHORT

The manufacture of a drone for which the capability to add an essential part of combat ammunition is created, but during the manufacture of which this essential part is not handled, is not subject to the license obligation specified in the Arms Act.

Conclusion

Obstacles

Overall, Accelerate Estonia has assessed that there has been three main legislative obstacles in unmanned aviation, the resolution of which would enable the development and testing of drones with higher competitiveness in Estonia:

Questions regarding the interpretation of the Arms Act.
Enabling electronic communication jamming.
The existence of permanent, publicly known, and sector’s expectation meeting test areas.

Solutions

The Ministry of Defence and the PPA have helped to establish legal clarity and interpretations that allow the questions regarding the Arms Act to be resolved, and at the time of the analysis’s compilation, problems should no longer arise in these aspects.
The Electronic Communications Act is being amended, which would allow educational institutions to also start conducting electronic communication jamming in the future and to offer it as a service to companies. This could create a competitive advantage for Estonia, as Estonia is rather lagging behind in the aspect of flight areas.
Test areas are being established by several Estonian institutions or are functioning as initial solutions. Further extensive coordination is needed for the test areas, which the Government Office has taken under its leadership. According to Accelerate Estonia, the next important step for empowering test areas is clear public communication about these opportunities so that the existing or planned testing opportunities are not only available on the basis of personal connections. One of the goals of this analysis is to create more clarity around this.

Accelerate Estonia’s Future Role in Unmanned Aviation

Accelerate Estonia will continue to support institutions carrying out developments in unmanned aviation both in legislation (Electronic Communications Act) and in the establishment and coordination of test areas. The program sees itself in the future unmanned aviation ecosystem as a central communication channel from which information about unmanned aviation testing opportunities can be received, and as a party that can direct companies to the right test areas and also offer a unified contact point for international companies interested to start testing in Estonia. By resolving the obstacles identified in the analysis at the national level, Estonia could first catch up in the competition for unmanned aviation testing and potentially one day achieve a competitive advantage for both our entrepreneurs and the test areas themselves.