Remote pilot in command: authority and responsibilities under Part 107

The remote pilot in command is the single person Part 107 holds answerable for a flight. Every commercial drone operation in the United States runs under that designation, whether the crew is one person with a controller or six people on a substation job. The rule is short, and its brevity is deceptive: five clauses assign a body of responsibility that most programs never fully write down, then discover during an incident review when someone asks who was in command.

This article covers what the rule says the remote pilot in command must be and do, how the designation is made and moved between people, what the role obligates on the ground before and after the flight, and why the designation belongs in the record of every flight rather than in the crew's collective memory.

What the rule assigns to the person in command

The core provision is compact. Under 14 CFR 107.19, a remote pilot in command must be designated before or during the flight, is directly responsible for and the final authority as to the operation, must ensure the aircraft poses no undue hazard to people, aircraft, or property in the event of a loss of control, must ensure the operation complies with every applicable regulation, and must have the ability to direct the aircraft to keep it compliant. Five clauses, and the second one carries the weight.

Final authority means the decision to launch, continue, or stop belongs to that person and nobody above them in a company. A client asking for one more pass, a manager watching a deadline, and a subcontractor with a schedule all have interests, and none of them holds the authority the rule assigns. The corollary is that the person in command has to be in a position to exercise it, which is why the rule requires the ability to direct the aircraft rather than merely the title.

Designation, supervision, and handing over command

The designation is not paperwork the FAA collects. It is a decision the crew makes, and the rule allows it before or during flight, which matters on longer operations. A certificated remote pilot may also supervise an uncertificated person on the controls, provided the pilot in command can immediately take direct control. That arrangement is legitimate and common on training days, and it does not shift responsibility: the person in command still answers for the flight even though someone else is flying it.

Command can also move between certificated pilots mid-operation, which the FAA's guidance contemplates for long duration work. The practical requirement is that both people can maintain visual line of sight through the handover without losing control, and that everyone on the crew knows the moment it happened. Programs that run scoped access keep the surrounding job context tidy the way FlybyOps describes in its piece on fitting each pilot's view to the jobs they are assigned, so a handover changes who is in command without opening the whole workspace to either of them.

The duties that sit either side of the flight

Before launch, the person in command owns the preflight assessment: weather, airspace and restrictions, the location of people and property on the surface, and other ground hazards. The same person briefs everyone directly participating on conditions, emergency and contingency procedures, roles, and hazards, confirms the control links work, confirms power is adequate for the intended flight time, and confirms anything attached to the aircraft is secure. If a visual observer is used, the pilot in command is responsible for making sure that observer can see the aircraft as the rule requires.

After the flight, two obligations follow the same person. If the operation involved serious injury, any loss of consciousness, or property damage above the rule's threshold, the report to the FAA is due within ten calendar days and it belongs to the remote pilot in command. If the pilot deviated from a rule to meet an in flight emergency, a written report of that deviation goes to the FAA on request. Neither obligation transfers to the company, the client, or whoever happens to handle paperwork.

Command is a fact about a flight, so record it like one

Every flight has exactly one person in command at any moment, and that fact is either written down or reconstructed later from memory. Reconstruction goes badly. Crews rotate, jobs blur together, and six months after a job the question of who held command during the third sortie has three plausible answers and no evidence. The flight record should carry the name, the certificate behind it, and, on operations where command moved, the time it moved and who took it.

This is also where currency quietly matters. The privileges of a remote pilot in command lapse unless the person has completed initial or recurrent aeronautical knowledge requirements within the previous twenty four calendar months, and the certificate itself gives no hint of the date. A program that records the person in command per flight but cannot show that person was current on that date has documented the problem rather than solved it. The two records belong together, pulled from the same roster.

Common mistakes in assigning the remote pilot in command

Treating the title as a formality. Crews sometimes name whoever holds a certificate and move on. The designation carries preflight duties, in flight authority, and post flight reporting, so it should go to the person genuinely positioned to exercise all three.

Letting commercial pressure override the call. A client or manager pushing for a flight the pilot in command judges unsafe is asking someone to act against the authority the rule assigns them. Programs need an escalation path that does not run through the launch decision.

Assuming supervision transfers responsibility. When an uncertificated person flies under direct supervision, the person in command still answers for the flight and must be able to take control immediately. Supervision is a permission, not a handoff.

Forgetting currency behind the designation. Privileges lapse after twenty four calendar months without initial or recurrent knowledge requirements met, even though the certificate does not expire. Naming a lapsed pilot as commander invalidates the basis of the flight.

Leaving handovers undocumented. On long operations where command moves, an undated handover means nobody can say who was answerable at the moment something happened. Record the time and the names.

FAQ

Does the remote pilot in command have to be the person flying?

No. A certificated remote pilot may supervise an uncertificated person on the controls, as long as the pilot in command can immediately take direct control. Responsibility for the flight stays with the person in command throughout.

Can two people share command of one flight?

No. One person holds the designation at any given moment, though command may pass between certificated pilots during a long operation. Sharing it simultaneously would defeat the rule's assignment of final authority to a single person.

Who reports a drone accident, the pilot or the company?

The remote pilot in command carries the reporting duty under Part 107, with the report due to the FAA within ten calendar days. Companies usually manage the filing, but the obligation attaches to the person, not the employer.

Does the designation have to be made before takeoff?

Not strictly. The rule allows the designation before or during the flight, which accommodates handovers on longer operations. In practice most crews name the person in command during the preflight brief and record it then.

Closing thought

Part 107 spends five clauses on the remote pilot in command because everything else in the rule needs somewhere to land. Airspace authorizations, operating limits, preflight assessments, and reporting duties all resolve to one person who was answerable for one flight. Programs that treat the designation as a live operational fact, recorded per flight alongside the certificate and currency behind it, can answer that question instantly. Programs that treat it as understood are relying on memory to survive an inquiry.

If you are deciding who holds command on each drone flight, FlybyOps was built for the operational record problem at the center of regulated drone work. A pilot registry tracking certification and currency, flight records that attribute every sortie, a project and job hierarchy that ties flights to the work they served, and an append-only audit log are all part of how the platform keeps the name behind every flight attached to the job, the aircraft, and the date it happened.