Impact of the Revised 2025 Civil Aviation Law on A-Share Aviation Industry

I. Policy and Regulatory Framework (Legal Level)

• The newly revised Civil Aviation Law was passed by the Standing Committee of the National People’s Congress on December 27, 2025, and will take effect on July 1, 2026. It is a foundational legal upgrade for civil aviation activities, explicitly strengthening drone management and enhancing safety and legal responsibilities [1,2,3].
• Requirements for drone “airworthiness certification” and “unique product identification code”: The new law clarifies that entities engaged in the design, production, import, maintenance, and flight activities of unmanned aircraft shall apply for airworthiness certification from the civil aviation authority under the State Council in accordance with national regulations (except for excluded cases); producers must set a unique product identification code for their products [2,3]. This forms a coordinated regulatory framework with the Interim Regulations on the Flight Management of Unmanned Aircraft and subsequent national standards.
• Classified and tiered regulation: According to the law’s interpretation, drones are categorized into micro, light, small, medium, and large based on performance indicators. Medium and large drone-related activities require airworthiness certification; while micro, light, and small drones do not need airworthiness certification, they must comply with quality and mandatory national standards, reflecting the approach of “precision regulation and tiered management” [7].
• Safety and operational compliance: The new law strengthens airport safety and electromagnetic environment protection, prohibiting laser and other behaviors that affect airport visual navigation facilities; it also supports requirements such as operational identification, real-name registration, activation, and traceable operational trajectory [2,3,4,7].

II. Impact Assessment of Compliance Costs on A-Share Aviation Industry Chain Companies (Structured)

1. Direct Compliance Costs Related to Airworthiness Certification

• Qualification preparation and application: Enterprises need to invest in engineering documents, quality systems, verification testing, and continuous airworthiness management resources. The costs vary significantly among enterprises of different sizes and certification progress, depending on certification complexity, product maturity, and enterprise quality system maturity (no unified statistical basis in public information).
• Personnel and training: Training for airworthiness engineers and quality management personnel, as well as team building, brings fixed costs and ongoing human resource expenses.
• Certification and consulting fees: Expenses for third-party testing, verification, auditing, and professional consulting services (specific levels need to be based on enterprise disclosures or contracts; current public data is insufficient).

2. Unique Product Identification Code and Quality Traceability Costs

• Technological transformation and production-side upgrading: Including the implementation of coding rules, deployment of marking/laser etching, barcode/QR code, RFID/NFC, and other solutions, as well as integration with ERP/MES to achieve full-process traceability [4,7].
• IT system and data governance: Establishing a registration and operation identification system covering “one machine, one code, real-name binding”, integrating with a unified management platform, involving platform construction, data interfaces, and ongoing operation and maintenance investment [4,7].
• Label/consumable and quality control: Variable costs are incurred in links such as label materials, marking equipment calibration, quality sampling inspection, anti-counterfeiting, and tampering detection.

3. Safety and Operational Compliance Costs

• Electronic fence and remote identification: Meeting 17 technical requirements such as electronic fence, remote identification, and emergency response specified in the national standard “Safety Requirements for Civil Unmanned Aircraft Systems”, involving software and hardware upgrades and ongoing maintenance [4,7].
• Operational identification and data reporting: According to the “Operational Identification Specification”, information such as identity, position, speed, and status must be reported to regulators from startup to the entire flight process, requiring support from communication and data governance capabilities [4,7].
• Liability insurance and risk mitigation: The law requires liability insurance for commercial flights and specific types of drones; insurance costs vary with scale and risk level [4,7].
• Venue and airspace management: Higher requirements for clearance and electromagnetic environment protection around airports, stricter operation scenarios and airspace application procedures may lead to increased operational costs.

4. Structural Characteristics of Compliance Costs (Qualitative Judgment)

• Equal emphasis on fixed and variable costs: System construction and IT platform investment are one-time/phased fixed costs; certification, labels, and insurance are variable costs that increase with production volume and flight sorties.
• Significant “time cost”: The airworthiness certification cycle is long, which may affect product launch schedules and commercialization pace, putting greater pressure on small and medium-sized manufacturers.
• Rising dependence on data and IT: Requirements for unified platforms and full-process traceability make data governance, network, and cloud services become ongoing cost centers.

III. Long-term Impact Assessment on Competitive Landscape (Based on Public Evidence Deduction)

1. Rising Competitive Barriers and Industry Concentration Trends

• Rising airworthiness and compliance thresholds: Medium and large drones require airworthiness certification; micro/light/small drones must also comply with quality and mandatory national standards, raising industry entry thresholds, benefiting enterprises that have obtained or are close to obtaining certification, and increasing pressure on small and medium-sized manufacturers [2,3,7].
• Enhanced brand and service premium: Compliance records and the “one machine, one code” traceability system bring brand trust premiums, enhancing the bargaining power and customer stickiness of leading enterprises.
• Coexistence of vertical integration and specialized division of labor in the industry chain: Manufacturers with integrated capabilities in materials-components-whole machine-operation have more system integration advantages; specialized component suppliers (carbon fiber composites, precision structural parts, 3D printing) consolidate their shares relying on technical and certification barriers (see public supply chain analysis) [6].

2. Opportunities Brought by the New Law

• Low-altitude economy and accelerated commercialization: The new law strengthens the safety and regulatory framework, providing institutional guarantees for normalized operations and overseas orders. Since 2025, “low-altitude +” scenarios such as logistics, cultural tourism, and urban management have expanded rapidly, and orders and deliveries of leading manufacturers have increased significantly [4,5].
• Improved international competitiveness: The improved legal system reduces institutional transaction costs for market entities, builds an institutional framework for international cooperation, and helps Chinese enterprises gain the initiative in global low-altitude economy competition [4,7].
• Supply chain upgrading and domestic substitution: Under safety and airworthiness pressure, demand for upstream materials (such as carbon fiber composites), precision manufacturing (such as 3D printing), and core components is strong, and the space for domestic substitution and supply chain collaboration is expanding [5,6].

IV. Specific Impacts and Uncertainties on Key Links of the Industry Chain (Public Evidence + Data Gap Explanation)

1. Whole Machine Manufacturing (eVTOL/Industrial Drone/Logistics Drone)

• Positive factors: Policy norms promote commercial implementation and large-scale application; in 2025, many leading manufacturers obtained large orders and made significant delivery progress [4,5].
• Challenges and uncertainties: Airworthiness progress directly affects launch schedules and costs, with large gaps between different enterprises; the magnitude of the financial impact of compliance costs (team, certification, IT, and insurance) on enterprises needs to be based on company disclosures (current public data is insufficient for accurate quantification).

2. Core Components and Materials (Composites, Precision Structural Parts, 3D Printing)

• Positive factors: High technical barriers and certification thresholds, stable position of leading enterprises, continuous advancement of domestic substitution; multiple listed enterprises (such as Boli Te (铂力特), Guangwei Composites (光威复材), etc.) have deeply participated in the commercial aerospace and aviation manufacturing supply chain [5,6].
• Uncertainties: Quantitative assessment of the impact of compliance costs and profitability on specific companies needs to be based on their business composition, product categories (micro/light/small/medium/large), and certification progress; public information is not sufficient to give company-level conclusions.

3. Operation and Services (Logistics Delivery, Cultural Tourism Sightseeing, Inspection/Security)

• Positive factors: Clarification of regulations reduces policy uncertainty for trial and normalized operations; pilot areas and routes are expanding faster [4,7].
• Uncertainties: The impact of the actual availability of airspace application procedures, airspace resources, and operation time windows on operational costs and pace needs to be evaluated in combination with regional pilot situations; the impact of新增 costs such as insurance and data reporting on profit margins depends on scale effects and cost pass-through capabilities (needs to be disclosed by operation entities).

V. Investment and Evaluation Methodology Recommendations (Avoid Quantitative Misleading)

• Three-dimensional evaluation framework of “airworthiness progress × scenario closed-loop capability × sustainable operation capability”: Priority is given to enterprises with advanced airworthiness progress, complete scenario adaptation, high R&D investment, and healthy cash flow [4].
• Focus on compliance governance and IT capabilities: Enterprises with unified coding, full-process traceability, operation identification, and data governance capabilities have more long-term resilience.
• Differentiation and structural opportunities: Small and medium-sized manufacturers that do not have large-scale certification and compliance capabilities will face reshuffling; leading and specialized suppliers are expected to benefit from increased industry concentration and order aggregation.

VI. Data Gaps and Next Work Recommendations (To Meet “In-depth Investment Research” Needs)

• Key company data to obtain: Compliance team size and cost, airworthiness certification investment and amortization policy, label/IT system investment, insurance expense ratio, R&D investment and certification milestones; these data usually appear in annual reports/prospectuses/inquiry letter replies or company announcements; no complete disclosure is found in current search results.
• Feasible paths for quantitative evaluation:

1. Use Python to calculate and compare “compliance expense ratios” of comparable companies based on financial report data and announcement texts;
2. Establish a cost model based on industry average certification cycle and cost cases (needs industry research supplement);
3. Calculate the sensitivity of compliance costs to gross profit margin and cash flow by scenario.

References (Cited Online and News Sources)
[1] Sina Finance - The newly revised Civil Aviation Law will take effect on July 1, 2026 (2025-12-27) https://finance.sina.com.cn/jjxw/2025-12-27/doc-inhefkhm1759724.shtml
[2] Shangguan News/CCTV News Client - The newly revised Civil Aviation Law will take effect on July 1, 2026 (2025-12-26) https://www.jfdaily.com/news/detail?id=1042538
[3] Civil Aviation Administration of China - The newly revised Civil Aviation Law will take effect on July 1, 2026 (2025-12-27) http://www.caac.gov.cn/XWZX/MHYW/202512/t20251227_229595.html
[4] Securities Times - Low-altitude Economy in 2025: Accelerated Commercialization Strides Toward Trillion-yuan New Blue Ocean (2025) https://www.stcn.com/article/detail/3559095.html
[5] Shanghai Securities News/China Securities Network - Seeking Productivity from the Sky! Ten Thousand Wings of Low-altitude Economy Rise Together (2025-12-24) https://wap.eastmoney.com/a/202512243601010485.html
[6] Caifuhao/Eastmoney.com - List of Listed Companies in the Core Supply Chain of LandSpace (Zhuque Series) (2025-12-26) https://caifuhao.eastmoney.com/news/20251226232348265515300.html
[7] CCTV.com - Building a Sound Drone Management Legal System to Safeguard Low-altitude Safety and High-quality Economic Development (2025-12-26) https://news.cctv.com/2025/12/26/ARTIjd0bAfPtZ3vDC8Gz1PR2251226.shtml
[8] People.cn - Building a Sound Drone Management Legal System to Safeguard Low-altitude Safety and High-quality Economic Development (2025-12-25) http://society.people.com.cn/n1/2025/1225/c1008-40632173.html

Note: The above assessment is mainly based on public online news and authoritative interpretations, combined with professional analysis and auxiliary calculation attempts using securities firm API tools. Due to incomplete company-level disclosure data, there are uncertainties in the quantitative assessment of compliance costs and competitive landscape; further analysis needs to be conducted in “in-depth investment research mode” combining company disclosures and industry research. If needed, I can extract annual reports and announcements one by one based on the target company list to build cost models and scenario calculations.