Before Clarion, I designed, certified and manufactured a 406 MHz aircraft emergency locator transmitter — the SkyHunter 406 — through my earlier company, SkyHunter 406 Ltd. It holds Cospas-Sarsat type approval certificate number 226. We are ready to ramp up production as required. The approval is held by SkyHunter 406 Ltd., not by Clarion Drone Academy.

As of November 25, 2025, Transport Canada requires most Canadian-registered aircraft to be equipped with a 406 MHz ELT, with exceptions for gliders, ultralights, gyroplanes, balloons, and airships. That deadline was the final phase of SOR/2020-238, which was published on November 25, 2020, and it is now fully in force for all required aircraft. COPA states that it engaged with Transport Canada and the Department of National Defence to advocate for alternative means of compliance, but that they are not considering changes to the mandate. The regulation is settled. What is not settled is a question the regulation never asked.

What the Mandate’s Analysis Covered

The Canada Gazette Regulatory Impact Analysis Statement for SOR/2020-238 estimated that approximately 25,807 Canadian-registered aircraft were required to carry an ELT, and that approximately 12,835 of them — 49.7% — had at least one active 406 MHz ELT registered through the Canadian Beacon Registry at the time of the analysis. That fleet count is based on data cited from approximately October 2017.

The RIAS cost-benefit analysis projected that the mandate would result in a timelier rescue of approximately 186 individuals over 15 years and an overall net monetized benefit of approximately $41.53 million. Procurement, installation and registration costs were estimated at $15.35 million, $10.84 million and $0.32 million, for total operator costs of $26.52 million. The analysis discusses those costs in detail. What it does not discuss is where the beacons are built and by whom. The Canada Gazette RIAS contains no language about where ELTs are manufactured or about domestic manufacturing capacity.

Since 2009, the COSPAS-SARSAT system has tracked only the more precise digital 406 MHz frequency. Canada’s SAR area of responsibility extends over 18,000,000 km² of land and sea, and the Department of National Defence is the principal SAR asset provider in both personnel and aircraft. The Canada Gazette RIAS notes that Canada is taking a more precautionary approach than the United States, given that Canada has much larger areas that are sparsely populated and without radar coverage. The mandate is justified on those grounds. The supply chain behind it was not examined in the same document.

Where the Defence Industrial Strategy Goes Silent

On February 17, 2026, Prime Minister Carney launched Canada’s first Defence Industrial Strategy, with a stated vision to prioritize Canadian suppliers and materials, invest in Canadian innovation and commercialization, and streamline procurement to give businesses consistent and predictable demand. The strategy projects that it will create 125,000 high-paying careers, increase defence exports by 50%, raise the share of defence acquisitions awarded to Canadian firms to 70%, and grow Canadian defence industry revenues by more than 240%.

The strategy defines sovereign capabilities as those without which Canada cannot defend its sovereignty or meet its allied commitments, and lists ten named areas: Aerospace, Ammunition, Digital Systems, In-Service Support, Personnel Protection, Sensors, Space, Specialized Manufacturing, Training and Simulation, and Uncrewed and Autonomous Systems. The Aerospace area explicitly includes avionics and aircraft communications — the category an aircraft ELT would fall under. Yet as of October 9, 2026, we found no mention of emergency locator transmitters, ELTs, aviation beacons, search and rescue equipment, or 406 MHz technology anywhere in the Defence Industrial Strategy document — not in the sovereign capability list and not elsewhere in the strategy text. The word “beacon” does not appear in it.

The Gap Between a Mandate and a Strategy

Canada now requires a 406 MHz ELT on virtually every aircraft the regulation covers. Transport Canada accepts for operational use under CAR 605.38 only those 406 MHz ELTs that also transmit on 121.5 MHz, and each must be registered with the Canadian Beacon Registry before it is installed on a Canadian-registered aircraft. The certificate issued by Cospas-Sarsat does not on its own authorize the operational use of a beacon in Canada. Transport Canada requires ELTs to meet CAN-TSO standards.

The SkyHunter 406 holds both: Transport Canada CAN-TSO approval and Cospas-Sarsat type approval certificate number 226. That is a different position from starting from nothing.

Canada has a Defence Industrial Strategy that prioritizes Canadian suppliers and materials, names ten sovereign capability areas — including avionics and aircraft communications — and does not name beacons, ELTs, or search and rescue equipment in any of them. The mandate’s final phase came into force on November 25, 2025. The strategy was launched on February 17, 2026. The two have not yet met on this point. If Canada wanted a 406 MHz emergency beacon built in Canada, how long would it take to start from nothing?