More information: Guidance on the implementation of Article 16 of Regulation 2019/947
The authorisation under Article 16 will need to set minimum competence requirements. That follows from Article 8(3) (“remote pilots operating in the framework of model aircraft clubs or associations shall comply with the minimum competence requirements defined in the authorisation granted in accordance with Article 16.”). For those obtaining an authorisation under Article 16(2)(b) there is the additional requirement that those authorisations will need to require associations and clubs to assist their members in “achieving the minimum competence required to operate the UAS safely and in accordance with the conditions and limitations of the authorisation”.
EASA’s guidance in the AMC and GM gives a lot of detail on the level of competence for open category pilots, and how that level of competence should be achieved. Important to keep in mind is however that: 1) the AMC and GM are not legally binding, but only provide guidance; and, more importantly; 2) the EASA guidance on competence of the pilot applies to the open category alone. Legally, that guidance is therefore irrelevant for the competence requirements which are defined in the Article 16 authorisation, regardless if that is issued under 16(2)(a) or (b).
This means that the reference to competence requirements in the authorisations under Article 16 can be very short and simple. It could for instance include a requirement for the pilots to be informed of the requirements of the authorisation and a requirement for pilots to ensure that they have the necessary competence to operate their aircraft safely.