Most people in the drone industry have never heard of “DronesQuad” (DsQ), an unofficial coordination group, which has operated behind-the-scenes as a semi-formal, working level coordination channel among the “big four” civil aviation authorities (FAA, EASA, Transport Canada, and Brazil’s ANAC). DsQ has no legal charter, no rulemaking authority and no public-facing regulatory role. For years, it existed simply to let regulators compare notes and meet the challenges posed by UAS design and airworthiness issues for both OEMs and regulators in the “Specific” operational category, the tier sandwiched between low-risk recreational flying and full manned aircraft type certification. That informal coordination has now produced something that could either propel or challenge the industry further, the High-Level Product Safety Criteria, or HPS Criteria (also referred to as HPSC), for cross-border UAS certification. It’s forcing a genuine debate across OEMs and the standards development community about what problem is actually being solved, and at what cost.
The Gap HPS Criteria Is Trying to Close
The drone industry already has a loosely shared language for operational risk. JARUS’s Specific Operations Risk Assessment (SORA) is used, in some form, by regulators worldwide to evaluate how risky a given drone operation is. What has never existed is an equivalent shared language for airworthiness, the design-and-build standards a product itself must meet.
Each of the four DsQ authorities has built its own declarative compliance pathway for the Specific (or specific-like) category largely in isolation. EASA has its Special Condition for Light UAS (SC-LUAS) and AMC to Article 11 of Regulation 2019/947. The FAA is working through Part 108, its forthcoming beyond visual line of sight (BVLOS) rule, still in rulemaking. Transport Canada has its Pre-Validated Declaration (PVD) process. ANAC has RBAC nº100. As a result, a manufacturer wanting to sell the same product into all four markets today effectively must engineer four separate compliance bases from scratch.
HPS Criteria is DsQ’s attempt to give standards development organizations (SDOs) one target to write toward instead of four. It consists of 31 performance-based design criteria that cover areas like cybersecurity, detect-and-avoid, command-and-control (C2) link integrity, crashworthiness and configuration control. The DsQ deliberately constructed HPSC as a “superset” that meets or exceeds what each of the four authorities separately requires. The logic is straightforward. If a product satisfies the superset, it has, by construction, satisfied every individual domestic requirement underneath it.
The end state DsQ is aiming for is elegant in theory: one declaration of compliance, recognized across four jurisdictions. A manufacturer complying with a DsQ endorsed standard would simultaneously be declaring compliance to EASA’s SAIL III design basis, FAA Part 108 Subparts G and H, TCCA’s PVD process, and ANAC’s RBAC nº100, ALL without re-engineering their product for each market.
Here is how it would work, as a practical matter. HPS Criteria carry no legal weight on their own. They aren’t regulations. The legal substance only appears once a Standards Development Organization (SDO) such as ASTM, EUROCAE, ISO or another body, writes an actual consensus standard against the criteria, and DsQ “endorses” that standard as a Means of Compliance (MoC). From there, each authority formalizes recognition through its own domestic channel: the FAA via a Notice of Availability, and ANAC, EASA and Transport Canada via Advisory Circulars or Guidance Material. Operational approval would remain separate and jurisdiction-specific, but the underlying design itself becomes portable.
Regulatory Commitment Is Real, Not Symbolic
It would be easy to dismiss this as a slow-moving, informal working group’s pet project. The evidence suggests otherwise. In October 2025, the FAA issued a message specifically to reassure standards bodies that the agency remained fully committed to the DsQ process and the HPS Criteria framework. FAA staff had been active participants in its development from the very beginning. Separately, all four authorities have jointly recommended that SDOs prioritize HPS Criteria in their product-related standards work. Thus all 4 CAAs seem to be consistently emphasizing support for this process.
Where OEMs and Industry Are Pushing Back
Industry’s discomfort isn’t with the goal of cross-border transferability. Nearly everyone agrees that it’s worth pursuing. The discomfort lies with the foundation the framework currently rests on, and it breaks down into several distinct concerns.
First, there’s a traceability gap. HPS Criteria have not gone through formal public consultation, and there is currently no documented traceability connecting the criteria back to the actual domestic requirements they claim to be a superset of. That matters enormously in practice because the risk sits almost entirely with industry, an OEM or SDO investing substantial engineering and standards-development effort who might only later discover the output doesn’t clear the bar.
Second, capacity for developing the criteria presents a binding constraint. SDOs and the industry subject-matter experts who staff their committees are already fully committed to work already underway, such as Part 108-aligned ASTM standards and EUROCAE’s ED-325 among them. ASTM and EUROCAE have agreed to consider HPS Criteria for specific standards development, but that consideration draws directly on the same limited pool of experts and volunteer hours already stretched thin.
Third, and perhaps most consequential for OEMs specifically, could be the significant superset design costs in actual practice. Because HPS Criteria are built to meet or exceed every participating authority’s domestic requirement simultaneously, an OEM designing to meet it would effectively be engineering to the strictest requirement across each of the 31 criteria categories regardless of which market or markets the product is intended for. In concrete terms, that can mean absorbing added cost, weight, and design complexity to satisfy a rule from a jurisdiction that isn’t even a target market for that product, purely to preserve the benefit of a multi-jurisdiction declaration.
DsQ offers transferability without re-engineering as a real and worthy tradeoff. This only holds if the underlying criteria are stable, traceable and genuinely attainable. Until that traceability is demonstrated, industry is effectively being asked to over-build against a moving, unvalidated target, in exchange for a promise of reciprocity that hasn’t yet been proven.
A Proposed Way Through
The approach matters because, done well, it offers something rare in this space: a unified, performance-based framework for drone safety standards, developed collaboratively by major aviation authorities rather than negotiated bilaterally after the fact. It gives standards organizations a common target for consensus-based standards that could be recognized across multiple jurisdictions at once, easing the burden of demonstrating compliance, reducing development and testing costs, and opening access to international markets without redundant engineering. Streamlined this way, it could accelerate the adoption of new technologies and support safer, more robust drone products, while genuinely advancing regulatory harmonization and product transferability between countries. That upside is real, and it’s a meaningful part of why industry and SDOs are working to make this succeed rather than simply resisting it. The debate is over how to get there safely and efficiently, not whether the destination is worth reaching.
The resolution path favored by much of industry and one that appears at least partially consistent with DsQ’s own thinking is to avoid building HPSC-specific standards from scratch. Instead, finish what’s already underway. ASTM F38’s Part 108-aligned standards, by some estimates, may already cover the great majority of HPS Criteria’s design requirements, particularly when read alongside ED-325, EUROCAE’s Means of Compliance guidance for SC-LUAS covering SAIL III/IV medium-risk operations. Under that approach, existing work becomes the common baseline. Each SDO’s remaining effort narrows to the smaller set of genuinely jurisdiction specific gaps. This would constitute a far more tractable task, given the capacity constraints everyone is already operating under.
Whether DsQ, ASTM, and EUROCAE converge on that path will likely become clearer as the standards community and DsQ sit down together in the coming months to compare the body of standards work with the HPSC. What’s already clear is that the ambition behind HPS Criteria is real, as is the regulatory commitment behind it. The traceability and capacity questions industry is raising are not process complaints to be waved away — they truly go to whether the framework can deliver the transferability it promises. But the tone from both sides of the table is one of good faith problem solving rather than standoff. Industry and SDOs want a framework that works, and are actively looking for the version of HPS Criteria that gets there without asking manufacturers to over-build against an unproven target.