Drone Visual Observer Requirements Under FAA Part 107

Drone visual observer requirements under 14 CFR Part 107 kick in whenever the remote pilot in command cannot personally keep the aircraft within unaided sight. In routine flights where the pilot watches the drone throughout, no observer is needed. Put on FPV goggles, fly under most beyond-visual-line-of-sight arrangements, or otherwise lose direct view of the aircraft, and a visual observer (VO) becomes mandatory.¹

The FAA defines a visual observer as a person the remote pilot designates to help see and avoid other air traffic and objects on the ground and in the air.² The VO does not fly the drone. Their entire job is watching the sky and the operating area, then relaying what they see to the pilot.

When a Visual Observer Is Required

Section 107.31 gives you two ways to satisfy the visual line of sight rule: the pilot (or the person at the controls) keeps eyes on the drone, or a VO does it instead.¹ If the pilot can comfortably see the aircraft the whole flight, an observer is optional. The instant that continuous unaided view breaks, one is required.

First-Person View Flights

If you fly with FPV goggles or a similar immersive display, a VO is always required. The FAA is explicit: when using first-person view technology, someone else must keep the drone within unaided sight at all times.³ The pilot wearing goggles obviously cannot, so the observer carries the visual line of sight duty for the entire operation.

Beyond Visual Line of Sight Operations

To fly past the range where the pilot or an observer can see the drone, you need a waiver under 14 CFR 107.200 authorizing a deviation from §107.31. Many approved BVLOS operations still station visual observers along the flight path as a safety measure, even when the waiver itself relaxes the standard line-of-sight rule. The FAA reviews each application on its facts and expects you to describe crew training, competency verification, and how your arrangement addresses operational risk.⁴

Who Can Serve as a Visual Observer

A common misconception is that VOs need FAA certification. They do not. Unlike the remote pilot in command, who must pass a knowledge test and hold a Remote Pilot Certificate, an observer has no formal certification or testing requirement under Part 107. Section 107.33 addresses the role in terms of duties, not credentials.⁵

What the rules do require is the physical ability to see the drone throughout its flight path using unaided vision. Corrective lenses like glasses and contacts are permitted.¹ Part 107 sets no minimum age for observers, unlike the sixteen-year minimum for remote pilots. The remote pilot in command is nonetheless responsible for making sure the person they designate can actually do the job. Choosing someone who cannot reliably track the aircraft or report hazards defeats the purpose and exposes the pilot to enforcement.

What the Observer Must Be Able to See

The drone must remain visible to the VO through natural eyesight throughout the flight. Section 107.31 spells out what that means: the observer must be able to determine the drone’s location, altitude, attitude, and direction of flight, and must be able to spot other air traffic or hazards in the surrounding airspace.¹ Knowing the drone is “somewhere over there” does not satisfy the rule.

Binoculars, telescopes, and other vision-enhancing devices are prohibited for tracking the aircraft. Corrective lenses are the only permitted aid.¹ A monitor showing the drone’s camera feed does not count either. The whole point is that a person can look up and see the aircraft with their own eyes. Positioning matters for the same reason. If the observer sets up behind a tree line or building that blocks part of the flight path, the visual line of sight requirement fails for that portion of the flight.

The Observer’s Job in the Air

The core duty is scanning the airspace for potential collision hazards and maintaining awareness of the drone’s position through direct visual observation.⁵ This ties directly into the broader Part 107 rule that every small drone must yield the right of way to all manned aircraft, airborne vehicles, and launch and reentry vehicles.⁶

Ground hazards are part of the job too. Power lines, cranes, and people entering the operating area all fall within the observer’s scan. When something matters, the report needs to be actionable: not “plane coming,” but the direction, relative altitude, and closure, so the pilot can react without asking follow-up questions.

Communication Between Pilot and Observer

The remote pilot in command, anyone manipulating the flight controls, and the visual observer must maintain effective communication with each other at all times during the flight. This is 14 CFR 107.33(a).⁵ The rule says “effective communication” without prescribing a method, so crews can pick what fits. Direct voice works when pilot and observer stand together. Radios or headsets are common when the observer is farther away.

Whatever you choose has to work reliably. A radio with a dead battery or a phone in a dead zone does not meet the standard. If the link breaks during a flight, the compliant response is to land the aircraft until it is restored. Continuing without effective communication between crew members violates the regulation directly.

Experienced crews set expectations before takeoff. A pre-flight briefing typically covers the planned flight path, altitude limits, emergency procedures, and the specific words the observer will use to report hazards. Agreeing on phrases like “abort” or “stop” in advance keeps either person from hesitating in a moment that will not wait.

One Aircraft at a Time

A visual observer cannot serve on more than one drone operation at once. Under 14 CFR 107.35, no person may operate or act as a remote pilot in command or visual observer for more than one unmanned aircraft at the same time.³ The practical effect for commercial operators is that a multi-drone job requires a separate crew for each aircraft. One observer watching three patches of sky does not comply.

Night Operations

Since April 2021, Part 107 has allowed night flying without a waiver as long as the remote pilot has completed the required training and the drone carries anti-collision lighting visible for at least three statute miles.⁷ The regulation does not create a separate observer standard for nighttime. If a VO is used, they still need to see the drone and scan for hazards with unaided vision plus corrective lenses.

In practice night flying makes the job harder. The anti-collision light helps track the drone, but spotting unlighted obstacles or low-flying manned aircraft in the dark is genuinely difficult. Pilots who regularly fly after sunset often keep the observer closer to the flight path and shrink the operating radius accordingly.

Who Is Legally Responsible

The remote pilot in command carries the legal responsibility for the safe conduct of the flight, including making sure the visual observer meets all requirements and performs their duties.⁸ If an observer misses an approaching aircraft and an incident follows, FAA enforcement targets the pilot, not the observer. The pilot picked that person, briefed them (or did not), and remained in command throughout.

The financial exposure is real. The FAA can impose civil penalties of up to $75,000 per violation for drone operators conducting unsafe or unauthorized operations, an amount increased under the FAA Reauthorization Act of 2024.⁹ Enforcement can also include suspension or revocation of the Remote Pilot Certificate.⁸ Operating without a required observer, using one who cannot actually see the aircraft, or losing communication mid-flight can each stand as a separate violation.

1
eCFR. 14 CFR 107.31 – Visual Line of Sight Aircraft Operation
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eCFR. 14 CFR 107.3 – Definitions
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Federal Aviation Administration. Small Unmanned Aircraft Systems (UAS) Regulations (Part 107)
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Federal Aviation Administration. Part 107 Waivers
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eCFR. 14 CFR 107.33 – Visual Observer
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eCFR. 14 CFR 107.37 – Operation Near Aircraft; Right-of-Way Rules
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eCFR. 14 CFR 107.29 – Anti-Collision Lighting
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Federal Aviation Administration. Aeronautical Information Manual Chapter 11, Section 8 – Other Information and Best Practices
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Federal Aviation Administration. FAA Proposed $341,413 in Civil Penalties Against Drone Operators