Under 14 CFR 107.12, nobody may operate the flight controls of a small UAS under Part 107 unless they hold a remote pilot certificate with a small UAS rating, or they are under the direct supervision of a remote pilot in command who can immediately take direct control. The remote pilot in command must always hold the certificate.
Two roles, two rules
Part 107 separates the person who touches the sticks from the person who is responsible for the flight.
Paragraph (a) covers anyone operating the flight controls. They need one of two things. Either they hold the certificate and meet 107.65, or they fly under direct supervision of a remote pilot in command who can step in immediately.
Paragraph (b) covers the remote pilot in command. That person must hold a remote pilot certificate with a small UAS rating and meet 107.65. No supervision route exists for the role itself.
What direct supervision means in practice
The words in the rule are about control. The supervisor must be able to take direct control of the aircraft immediately. That points to a setup where the certificated pilot is next to the trainee with a way to take over, such as a buddy box or a shared controller, and not a pilot sitting in another room.
For a company, this makes training flights easy to set up legally. A new hire can fly under supervision while the certificated pilot stays responsible. The rule does not say how the supervisor proves the ability to take over, so write your own standard down. Examples are a requirement to stand within arm's reach and a requirement to test the handover before each flight.
The foreign aircraft exception
Paragraph (c) lets the FAA, in line with international standards, allow an airman to operate a civil foreign registered small UAS without an FAA issued remote pilot certificate. It applies to both paragraphs (a) and (b). The text I read does not spell out the conditions, so treat it as something to confirm with the FAA before relying on it.
Operating records for a small team
A short internal policy keeps the rule from drifting in practice:
- Keep a list of certificated pilots and when each certificate was issued.
- Name the remote pilot in command on every flight log.
- Record who flew under supervision, and who supervised.
- Do not let a supervisor leave the site during a supervised flight.
- Review the list before each season or contract.
Where software and data come in
Fleet operators now carry software too: a ground station app, a logging tool, maybe a cloud dashboard. Who can log in and who can fly are separate questions, and your account permissions should mirror the Part 107 split. Give flight planning rights to the people who hold the pilot role, and limit who can edit mission files for the aircraft.
Quick check
Can an uncertificated person ever touch the controls?
Yes, if they are under the direct supervision of a remote pilot in command who can immediately take direct control, per 107.12(a).
Can someone serve as remote pilot in command under supervision?
No. Paragraph (b) requires the remote pilot in command to hold the certificate with a small UAS rating and meet 107.65.
Sources
- 14 CFR 107.12, eCFR: certificate requirement and exceptions.
Last reviewed: 19 October 2026.
