It had some similarities with the Avro 519 (a single-seater intended for the Royal Flying Corps (RFC)) and the twin-seat 519A, built for the Royal Naval Air Service (RNAS),[2] though neither of these were armed and both had 150 hp Sunbeam Nubian engines rather than the 225 hp Sunbeam of the 528.
The fuselage had similarities with the RNAS 504s though the overall length of the 528 was greater by about 4 feet (1.2 m): both had a generous fixed fin in contrast to the all moving, comma shaped rudder of the RFC's 504s.
The Sunbeam engine drove a four-bladed propeller and had a single, central, and nearly vertical exhaust pipe.
Two tank-like features are shown in both image and diagram on the lower wings just inboard of the innermost interplane struts; they may be fuel tanks.
[3] The aircraft remained troublesome, with a variety of propellers being tried but the Admiralty lost interest and the 528 last flew in April 1917.