Mapping of regulatory needs towards C-UAS in the EU

This document provides a comprehensive mapping of how EU Member States regulate counter-unmanned aircraft systems (C-UAS) and identifies the regulatory gaps that limit Europe’s ability to address the growing security risks posed by non-cooperative drones. Based on fifty institutional responses from twenty-five countries, complemented by an EU-level survey and extensive desk research, the report finds that while drones are increasingly used in civilian and security-sensitive environments, the legal and operational frameworks for countering malicious or unsafe drone activity remain highly fragmented across the Union. Most Member States rely on dispersed provisions in aviation, police, defence and telecommunications legislation, and only a few have begun developing integrated national C-UAS strategies. A central finding is that civilian and critical-infrastructure operators typically lack any legal authority to neutralise a threatening drone. Active mitigation measures such as jamming, spoofing or kinetic intervention remain restricted to military and specialised police units due to strict spectrum-interference and aviation-safety rules. As a result, many operators can detect threats but cannot respond effectively, which delays neutralisation and increases security risks. The report further observes major inconsistencies in national definitions, notably around the concept of a “non-cooperative drone,” leading to operational uncertainty. Testing, certification and R&D environments for C-UAS are similarly limited, hindering technological development and cross-border procurement. Data-protection challenges are widespread: GDPR and the Law Enforcement Directive apply, but Member States differ considerably in their interpretation of lawful bases, retention limits and data-sharing protocols, especially when C-UAS systems capture personal data from pilots, devices or surrounding environments. At the same time, the absence of unified national or EU-level incident-reporting platforms prevents a common situational picture and constrains risk analysis.
The recommendations set out in this document provide a coherent, future-oriented path for strengthening the EU’s resilience against drone-related threats. They call for the creation of a dedicated regulatory framework for C-UAS, integrated into national UAS governance and supported by harmonised terminology, clearer legal bases and well-defined mandates for all actors involved. A key proposal is to establish controlled and proportionate legal pathways for certain critical-infrastructure operators to deploy active mitigation measures under strict safeguards, improving reaction times without compromising safety, privacy or spectrum integrity. The recommendations also emphasise the need for EU-wide technical standards for detection, tracking, identification and neutralisation technologies, accompanied by certification schemes that ensure interoperability and support transparent procurement. They further highlight the importance of dedicated test environments and innovation sandboxes, along with adapted frequency-management rules that enable C-UAS deployment while protecting the radio spectrum.
This document stresses that Europe needs stronger governance structures, both nationally and at EU level. Member States would benefit from national C-UAS coordination centres with clear chains of command, shared operational procedures and integrated crisis-management mechanisms. At EU level, a central role for the Commission is encouraged, including the creation of a pan-European drone-incident reporting platform and knowledge hub. Finally, the report underscores the urgent need for capacity-building, including standardised training curricula, cross-border exercises and sustained investment in research, testing and pre-commercial procurement. Collectively, these recommendations aim to overcome current fragmentation, accelerate innovation and provide a harmonised, effective and rights-respecting approach to counter-drone security across the European Union.