Greek Drone Regulations Explained
The fundamental aspects of drone laws in Greece have been established and subject to change upon the European Commission regulation that will substitute the national ones. In principle, drone regulation affirms that the use of drones must not threaten people, property and generally public safety or violate privacy and environmental issues. Furthermore, it is prohibited to fly over residential areas and individuals without their consent.
The Ministerial Decision 17457/ 2012 concerning the structure and operation of the Hellenic Civil Aviation Authority governs the licensing requirements for commercial/technical operators and their personnel or legal persons . In order to obtain all the necessary permissions, permits and licenses, an applicant needs to submit to the Director of the Hellenic Civil Aviation Authority an application ensuring that all requirements are met, a technical assessment against the necessary standards and identification numbers, a description of the drone, technical and construction characteristics of the intended aircraft and control equipment (in case of remote control aircraft a description is required of the remote control equipment used), the composition of the device and any potential risks, a maintenance schedule, a description of the risk identification process and methods to be activated in case of emergency.
It is noted that legislative updates constitute the international standard on drone regulation and therefore in compliance with the European Regulation, the Greek national legislation on drones will soon be replaced with EC Regulation 2017/ 2372. This regulation will introduce new rules that will apply to the use of drones in the European Union, replacing Member States’ various approaches to drone regulation including the Greek one.
Drone Registration in Greece
As of 2015, all drones in Greece, regardless of the weight, must be registered with the Greek Civil Aviation Authority (GCAA). GCAA Announcement 1869, dated November 2015, states that all drone systems weighing less than 4 kg must be registered. The responsibility for registration and compliance rests with the owner of the drone.
Entities with a valid licensing certificate for unmanned aircraft systems (UAS) do not have to register their drones with the GCAA, but must present their license upon request to the GCAA or any authorized representative. If there has been an ownership change, the new owner must register the drone.
A warning: as per paragraph 1.10 of the GCAA Manual, "Changes that occur in the process of the approval of design, production, operation or maintenance of the UAS, shall be communicated to the GCAA for review and approval prior to being implemented." In practice this means that if you have a license from another country, such as Bulgaria, and import your drone to Greece, you must register it within 30 days from the date of importation, otherwise the GCAA will deem it as a change in the design of the drone and may refuse to register it.
Registration can be completed at the GCAA, and is valid for five years. One document that must be submitted is a Registration Form (i.e., Application Form for Authorization of Helicopter Aircraft Operating Crew – Unmanned Aerial Vehicle – UAV). It is also worth noting that at the same time, the drone operator can apply for the issuance of the required Certificate of Knowledge of the Subject Matter. The new Unified Regulation regarding the operation of Remotely Piloted Aircraft Systems, including the relevant General Operations and Training Manual, however, will abolish the certificate requirement during the first half of 2016.
Operating Procedures for Unmanned Aircraft
The following guidelines apply to the operation of drones in Greece:
• If your drone weighs more than 1 kg, and less than 4 kg in weight, then you must fly your drone within your line of sight at all times.
• Drone pilots must maintain a visual line of sight (VLOS) with their drone while it is in flight.
• Drone flights are prohibited over or near people
• VLOS ranges from 300 metres in some areas to as far as 5.5 km depending on the weight of the drone being used.
There are a number of different places in Greece that are no-fly zones. These include:
• Drones cannot be flown over cities or towns. This is a large geographical area in itself due to the fact that in Greece there are about 2,500 towns, cities and municipalities.
• Airports – Drones cannot be flown within 20km of any airport.
• Restricted Use Areas – There are 72 restricted use areas throughout Greece. Flight is not permitted in any of these areas, without special permission from the Greek Police. In these areas, it is extremely important to check the maps and restrictions that are in place.
• Density areas – There are a few areas in Greece that the density of the citizens is high. Due to the risk factor associated with flying a drone in these areas, pilots cannot do so without special permission from the Greek Police. These areas include large tourist destinations across Greece, such as Santorini.
• Military areas – There are also various military areas throughout Greece. These areas are top-secret, and it is illegal to reveal what is stored within them. Therefore, pilots cannot fly within these areas.
• National parks and archaeological sites – Similarly, drones cannot be flown over national parks or archaeological sites. These areas are protected by the law, as they are considered to be of the greatest importance to Greece.
• Religion – Drone flights will never be permitted during ceremonies at religious sites, or during religious holidays.
Privacy Concerns and Safety Issues
Privacy also plays an important role in the Greek drone regulatory framework, even if it often seems to be a secondary concern when it comes to assessing drone operations. The EASA Basic Regulation provides a legal basis for national legislators to introduce additional requirements for UAS operators with respect to data protection and confidentiality rights. In line with this framework, the Greek authorities have introduced a number of privacy obligations within the applicable legislation.
For example, in accordance with the national law on personal data protection (L. 4624/2019), drone operations can be requalified as "processing" of personal data under the General Data Protection Regulation (GDPR) depending on the UAS characteristics and functionality. Through their commands, the UAS capture and transmit personal data from the areas overflown. That personal data may include identifiable images of individuals, car plates, one’s voice or even mere video, audio and image information, which could allow for easy identification of an individual under certain circumstances . In this context, when using a UAS to identify individuals, data processing is likely to fall within the GDPR regime.
An interesting feature of the Greek legal framework is the separate definition of the term UAS pilot – as opposed to the term UAS operator. The legal schemes provided for in the Civil Aviation Code (Law 4577/2018) refer to the terms UAV pilot and UAV operator. Those terms are not defined in the Greek legislation; however, they appear in the European Regulation 305/2011 as meaning respectively the pilot of a UAV responsible for the safety of the aircraft and the person or organization responsible for operating a UAV. Following this interpretation, a UAS pilot in possession of an appropriate license issued by the competent authorities can safely address any claims concerning his/her actions, even if they have been specifically ordered by the UAS operator. In that regard, it should be noted that even the UAS pilot is not relieved from his personal liability, the imposing of which depends on the specifics of each case.
Consequences of Violating Greece’s Drone Laws
Violations of these regulations can result in serious consequences, both for individual drone operators and for commercial companies. For private drone pilots, particularly those who are flying the equipment as a hobby craft, there can be significant fines, sometimes amounting to thousands of euros. This includes for example fines for exceeding the maximum allowed flight altitude or for flying over people, but even exceeding the maximum weight limit can result in fines up to €1,448. However, it is to be expected that the HCAA will handle cases against private drone pilots more leniently.
Commercial drone operators are subject to much more significant financial punishments, in the realm of tens of thousands of euros, and are placed under investigation by the state. For example, if a commercial operator flies a drone without prior approval or violates the terms of the approval, this will lead to serious consequences.
Using Drones in Tourist Destinations
Although it is possible to operate a drone anywhere in Greece, the Greek authorities have identified some popular tourist destinations and imposed stricter rules on drone flights within their boundaries.
Kalimnos
Until you submit a flight request and obtain clearance, you are prohibited from flying within Kalimnos (except in a limited number of designated spots, as explained below):
A photo or video registration on the port relative to each flight operation must be submitted electronically – through a form provided by the Greek Authorities. The flight plan must be submitted at least 5 days prior to the flight. No flight can take place between 2400 hours and 0700 hours.
In addition, regarding specific tourist sites, drone operation is strictly prohibited within 26 km radii from the respective center of the Aleksandros bond. Exceptions are:
Furthermore , a map is available next to the Department of Civil Aviation Authority (DCA) Kalimnos subdivision office with all drone prohibition zones.
Zante
Flying of drones on Zante is allowed subject to the following restrictions:
Operates duly authorised and organised aircraft operators, must submit photo/video registration pertaining to each flight operation. Flights must be submitted to the Directorate of Civil Aviation (DCA) 48 hours prior to the flight.
Kefalonia
Flying of drones on Kefalonia is allowed subject to the following restrictions:
Operates duly authorised and organised aircraft operators, must submit photo/video registration pertaining to each flight operation. Flights should be submitted to the Directorate of Civil Aviation (DCA) 48 hours prior to the flight.