Who's the Prime Person, and Why Does the CAA Interview Them Personally?

Who's the Prime Person, and Why Does the CAA Interview Them Personally?

By Rachel Simpson

Most of the process for getting your organisation's UAOC (Unmanned Aircraft Operator Certificate) is paperwork. You write an exposition, the CAA reviews it, you make the changes they ask for. But before they'll issue the certificate, one more thing has to happen: a CAA inspector sits down and interviews a specific, named person from your organisation. Not the company who helped with the exposition. Not whoever's free that day. One person, decided in advance, who has to prove they understand what they're signing up for.

That person is called the Prime Person, and the interview is the last gate before your organisation gets its UAOC.

What is a Prime Person?

A Prime Person is the individual your organisation names as having overall responsibility for its UAOC and everything that happens under it. It sits at the organisation level, tied to the UAOC rather than to any individual's Part 102 Drone Pilot Certificate. Your certificate proves you've done the training and passed the flight test. Prime Person is a separate question: who answers for the organisation's operations as a whole.

The CAA's own guidance puts it plainly: "A prime person is responsible for all the functions associated with an operation, and they foster the safety culture of the organisation."

In practice, that covers safety culture, making sure crew are trained and competent, keeping on top of maintenance, managing risk and investigating when something goes wrong, staying compliant and reporting occurrences, and being the CAA's main point of contact.

Why does the CAA interview a Prime Person instead of just approving the paperwork?

Because Part 102 isn't written the way a lot of aviation rules are. As the CAA puts it: "Part 102 is a performance-based set of rules, which is different to many prescriptive civil aviation rules."

A prescriptive rule tells you exactly what to do in a given situation. A performance-based rule sets the safety outcome and leaves the operator to work out how to get there, inside their own exposition. That flexibility is useful, but it only works if someone in the organisation genuinely understands how to apply it, not just recite it. The CAA can check a document. They can't check a document's judgement. So they check the person who'll be exercising it.

What does a Prime Person need to know?

You don't need an aviation background to be a Prime Person, but you do need a real, practical grip on the risks involved. The CAA expects a working knowledge of:

The Civil Aviation Act 2023
Part 101 and Part 102 rules, in real depth
Your own organisation's exposition, in depth
Transport instruments (the rules and other legal documents CAA issues under the Act, separate from the Act itself) and advisory circulars (CAA's non-binding guidance on how to actually meet those rules)

A Part 102 training course from an approved provider can help build that base, particularly the exposition and rules knowledge the interview is checking for.

What happens in a Prime Person interview?

It's built around what the CAA calls the "fit and proper person" test, not a memory test. You can expect questions about your attitude to rules and bookkeeping generally, how you think about risk, and how you'd handle a boss or client pushing you to go ahead when you know conditions aren't safe.

They'll also check your knowledge of your organisation's exposition, but not by asking you to recite it. What they want is confidence that you know where to find things in it, because that document holds the actual methods and procedures your organisation operates by. You don't need it memorised cover to cover. You need to know it well enough to go straight to the right section when something's happening.

Airspace questions tend to come up too, off the cuff rather than as a set section, which tests whether that knowledge is really there rather than revised for the day.

What they're really forming a view on, across all of it, is whether risk is something you take seriously as a matter of course, not something you've learned to say the right words about. In the CAA's own language, this sits alongside your knowledge of the organisation and the regulations, whether you actually have the time and resources to do the job properly, and how you manage conflicts of interest.

Who normally becomes the Prime Person?

There's no single template. In a small operation, it's often the owner, sometimes the same person who's flying. In a bigger team, it's more likely a manager. What the CAA is really checking for either way is enough real aviation knowledge to understand what you're signing off on every time you approve a flight, and the time available to do it properly, not just a title.

Can a Prime Person be changed?

Yes. If your Prime Person moves on, your organisation submits an amendment to the CAA and gets the new person approved by the Director of Civil Aviation, which means they go through the same interview process as the first one did. It isn't a quiet swap on a form.

It's also not a one-off check that happens once and gets filed away. The CAA keeps paying attention to Prime Person capability on an ongoing basis, not just at certification.

Where this fits if you're heading toward a UAOC

If you're working through the ag pathway, or any pathway that ends in your organisation holding its own UAOC, the Prime Person interview is the last gate before the certificate gets issued. Getting your Part 102 Drone Pilot Certificate and writing a solid exposition doesn't get you there on its own. Someone in your organisation still has to walk into that interview and show the CAA they genuinely understand the rules, the exposition, and the risk they're taking responsibility for.

Our Part 102 course builds exactly that knowledge base. If your exposition's already underway, our Exposition Writing Service can help make sure the document your Prime Person will be tested on actually reflects how your operation works.

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