Drone Swarms in Poland – Civil Regulations, Light Shows and Military Applications

Last updated: 19.08.2026

A drone swarm, understood as the coordinated use of multiple unmanned aircraft within a single operation, is becoming an increasingly important technology in both the civil and military sectors. In practice, it may involve a light show, infrastructure inspection, area monitoring, rescue operations, industrial operations, as well as reconnaissance, jamming or strike systems used by armed forces.

For UAS operators, drone technology manufacturers, system integrators, show organisers, industrial entities and companies operating in the defence sector, a key issue is determining which regulatory framework applies to a specific operation.

From a legal perspective, however, a drone swarm is not a separate statutory category. Neither EU nor Polish regulations establish a separate regime called a “drone swarm”. What is assessed is the specific operation: the number of drones, the location of the flight, altitude, presence of uninvolved persons, degree of automation, possibility of human control, airspace, payload, sensors, purpose of use and the status of the operator.

This means that the same technological model may be assessed very differently depending on its application. A light show over a controlled area, an inspection of an industrial facility and a drone swarm system intended for military applications are subject to different regulatory obligations.

What is a Drone Swarm?

In practice, a drone swarm means an operation in which multiple unmanned aircraft perform a coordinated task according to a common mission plan. This does not necessarily imply full autonomy. A swarm may be manually controlled by several pilots, centrally managed by an operator through centralized control, follow a pre-programmed trajectory or operate on the basis of automatic coordination algorithms governing swarm behavior.

The key distinction is between:

From a legal perspective, it is therefore not enough to determine how many drones are involved in the operation or to assess individual drones in isolation. What matters is who manages them, in what environment the flight takes place, what level of automation is involved and what risks arise for persons, property, airspace and national security.

Drone Swarms in Civil Operations – VLOS and Regulatory Categories

Civil drone operations in the European Union are based on a risk-based model. The regulations do not generally distinguish between recreational and commercial flights, but classify the operation according to its level of risk. The basic division includes three categories:

1. the open category – low-risk operations,
2. the specific category – medium-risk operations,
3. the certified category – highest-risk operations.

In the case of drone swarms, the open category will only be possible in simple and low-risk scenarios. As a rule, it requires flight within visual line of sight, or VLOS, a maximum altitude of 120 m, drones with a mass below 25 kg, no flight over assemblies of people and compliance with the requirements of subcategory A1, A2 or A3.

Typical professional drone swarms, especially light shows, urban operations, night flights, operations involving multiple unmanned aircraft or operations near an audience, very often require analysis under the specific category. This does not automatically mean that they are prohibited, but it does require documentation, risk assessment and, where applicable, obtaining the relevant authorisation.

Drone Light Shows – Regulatory and Safety Requirements in Poland

Light shows are one of the most popular civil applications of drone swarms. From a legal perspective, they are not merely an event service – they are an aviation operation that requires proper classification, organisational preparation and risk mitigation.

When planning a show, the following should be assessed in particular:

• the number of drones,
• the class and mass of the unmanned aircraft,
• the place and time of the flight,
• the presence of an audience,
• the distance from uninvolved persons,
• night flight,
• geographical zones,
• DroneTower and PANSA requirements,
• the need for authorisation from the Civil Aviation Authority,
• site security,
• emergency procedures,
• third-party liability insurance,
• liability of the organiser and the operator.

In the open category, flights over assemblies of people are prohibited. Therefore, a show organised over or in the immediate vicinity of an audience should be analysed with particular caution. Even if a single drone is light, the risk of the entire operation may be high due to the number of devices, flight synchronisation, night-time conditions, possible system failure or positioning error.

The agreement between the event organiser and the swarm operator should clearly define who is responsible for the classification of the operation, notifications, authorisations, site security, the decision to launch, interruption of the show, insurance and damage caused to third parties.

Drone Swarms in the Specific Category – SORA, PDRA and Operational Authorisation in Poland

If a drone swarm operation goes beyond the limitations of the open category, the operator should consider the specific category. This may include, among others, BVLOS flights, operations in urban environments, complex flights, operations over a controlled ground area or operations requiring individual safety procedures.

In the specific category, the operator may act in particular on the basis of:

For a drone swarm, the risk assessment should cover more than the risk of a single unmanned aircraft falling. It should also take into account collisions within the swarm, loss of communication, loss of GNSS, incorrect synchronisation, emergency landing of multiple drones, the possibility of interrupting the mission and effective human supervision over the system.

Automatic and Autonomous Drone Swarms – Key Legal Differences

In drone swarm operations, the difference between automatic and autonomous flight is particularly important.

Automatic flight consists in following a pre-programmed route or sequence, while a human still supervises the operation and should be able to intervene. Autonomous flight means a higher level of system independence, where the drone or the entire fleet makes decisions in response to changing conditions.

This distinction has significant legal consequences. The greater the autonomy, the greater the importance of technical documentation, testing, validation, cybersecurity, event logging, emergency procedures and allocation of liability between the manufacturer, integrator and operator.

In practice, the following should be documented:

• who supervises the system,
• whether the operator can stop the entire operation,
• whether a single drone can be disconnected from the swarm,
• what emergency modes exist,
• how the system responds to loss of communication,
• how the algorithms were tested,
• whether logs allow the course of the operation to be reconstructed.

DroneTower, Geographical Zones and Airspace Rules for Drone Swarms

In Poland, before a flight, the pilot should check the airspace conditions and make a notification in accordance with the requirements of PANSA, the Polish Air Navigation Services Agency. The primary tool for notifying unmanned aircraft flights is DroneTower.

In the case of a drone swarm, flight notification should not be treated as a mere formality. The area of operation, altitude, time, number of unmanned aircraft and possible restrictions resulting from geographical zones, CTR, NOTAMs, public events, critical infrastructure or military facilities must be properly determined.

The mere notification of a flight does not replace an operational authorisation, consent of the zone manager, pilot qualifications or documentation required for the specific category.

Drone Swarms, GDPR and Privacy – Personal Data Requirements in Poland

Not every drone swarm will process personal data. A light show performed by drones without cameras may generate limited privacy risk. Swarms used for monitoring, inspections, facility protection, crowd analysis or public operations should be assessed differently.

If the system records persons, vehicles, licence plates, properties, employees or event participants, the GDPR may apply. The operator should assess the legal basis for processing, the scope of recordings, retention period, access to data, information obligations and the need to conduct a DPIA.

A lawful flight does not automatically mean lawful recording. Aviation law, data protection and protection of personal rights should be analysed together.

Drone Swarm Cybersecurity – Communication, GNSS and System Control

A drone swarm is a cyber-physical system. It includes hardware, software, communications, data, a control station, updates, positioning systems and human procedures. Cybersecurity is therefore one of the key elements of compliance.

The most important risks include:

• loss of communication,
• signal interference,
• GNSS spoofing,
• unauthorised access to the system,
• update errors,
• lack of software version control,
• data leakage,
• lack of logs,
• takeover or disruption of the operation.

The operator should have procedures for access control, updates, pre-operational testing, incident response and safe mission interruption.

Liability and Insurance for Drone Swarm Operations

A drone swarm operation increases liability exposure. In the event of damage, liability may concern the UAS operator, event organiser, landowner, manufacturer, integrator or subcontractor.

In Poland, third-party liability insurance for UAS operators is required in certain cases. In swarm operations, however, minimum insurance may not correspond to the real business risk. Especially in the case of public shows, urban flights and industrial operations, it is advisable to verify the insured amount, exclusions, subcontractors, personal injury, property damage and contractual liability.

Contracts should precisely regulate:

• who is the UAS operator,
• who is responsible for authorisations and notifications,
• who secures the area,
• who decides to interrupt the operation,
• who bears liability for damage,
• what scope of insurance is required,
• who is responsible for personal data,
• who bears the risk of weather conditions.

Dual-Use Drone Technology – Legal Requirements for Drone Swarms in Poland

Drone swarm technology may have both civil and military applications. The same system for coordinating multiple unmanned aircraft may be used for a light show, infrastructure inspection, border monitoring, military reconnaissance or support for combat operations.

Therefore, an entrepreneur involved in the development of drone swarm technology should assess whether the product, software, documentation or know-how is subject to regulations on dual-use items, strategic trade or goods intended for military or police use.

The analysis should cover:

• technical parameters and system capabilities,
• intended use of the product,
• end user,
• destination country,
• possible military application,
• software and algorithms,
• sensors,
• communication systems,
• technical documentation,
• training and service support.

The mistaken assumption that a technology is “civilian” may lead to a breach of export control, sanctions or special trade regulations.

Military Applications of Drone Swarms and Drone Warfare

In military applications and drone warfare, drone swarms may be used for reconnaissance, observation, jamming, facility protection, logistics, deception, artillery support or strike operations. Operations conducted by armed forces are, as a rule, not subject to the typical civil EASA regime, but this does not mean that they are unregulated.

The following are particularly relevant:

• national regulations on state and military aviation,
• airspace safety rules,
• defence procurement regulations,
• special trade control,
• dual-use items,
• protection of classified information,
• cybersecurity,
• the Act on trade in strategic goods,
• international humanitarian law.

An entrepreneur producing or supplying swarm technologies for the military should assess whether a licence, export authorisation, end-user document, industrial security procedures or special contractual provisions concerning intellectual property and technology transfer are required.

Autonomous Combat Drone Swarms and International Humanitarian Law

The most sensitive area concerns autonomous or semi-autonomous drone swarms with potential combat applications. Such systems must be assessed through the lens of international humanitarian law, in particular the principles of distinction, proportionality, military necessity and precautions.

Of particular importance is the obligation to assess the legality of new means and methods of warfare. In the case of a drone swarm, the analysis should cover not only the hardware itself, but also software, decision-making algorithms, the level of autonomy, human supervision, the ability to interrupt the mission and the predictability of the system’s behaviour.

The key legal questions concern whether a human retains effective control over the use of force, whether the system may independently select targets, whether the system’s decisions are predictable and whether responsibility for an error can be attributed.

Drone Swarm Compliance – Key Legal and Operational Requirements in Poland

An entity planning a drone swarm project should prepare at least the following:

What Legal Issues Should You Consider in a Drone Swarm Project in Poland?

A drone swarm should not be assessed through the lens of a single device, but as a complex operational system. In civil applications, EASA regulations, Aviation Law, categories of operations, notifications to PANSA, authorisations from the Civil Aviation Authority, risk assessment, data protection, cybersecurity and civil liability are of key importance. In military and dual-use applications, export control, licensing, defence procurement, classified information and international humanitarian law also become relevant.

A properly prepared drone swarm project requires the combination of technological, operational and legal competences.

The greater the number of unmanned aircraft, the higher the level of automation and the more sensitive the flight environment, the greater the importance of documentation, procedures, testing, contractual liability and prior regulatory classification.

Legal Support for Drone Swarm Operations and Technology Projects

Our team supports UAS operators, drone technology manufacturers, integrators of autonomous systems, show organisers, industrial entities and companies from the defence sector. We assist with the classification of operations, preparation of documentation, risk analysis, contracts, GDPR, insurance, public procurement, licensing, export control and dual-use projects.

Are you planning a drone swarm operation or developing drone technology for civil, dual-use or military applications? Contact our team to discuss the legal and regulatory requirements applicable to your project.