Unmanned aircraft systems (UAS) have witnessed a radical increase in a variety of applications. While delivering obvious benefits, there are also hazards and risks regarding, for example, physical safety, people’s privacy, and cyber security. The regulatory framework on UAS was considerably changed due to the adoption of Regulation (EU) 2018/1139, which, as a centralised, top-down regulation, covers nearly all UAS, regardless of their weight and size. Although the ensuing regulations and guidelines from the European Commission and European Aviation Safety Agency (EASA) give detailed provisions for things like the operation and design of UAS, the implementation of said rules and the necessary procedures involved are up to the member states and their competent authorities. This paper compares current differences in selected member states considering the implementation of new UAS regulations. The results imply that there is a wide variability between member states in how they cover different aspects of the new regulation. This paper also draws preliminary conclusions on the maturity of the governance and regulatory framework.