Background and Covered List Restrictions
On December 22, 2025, the Federal Communications Commission (FCC) updated its Covered List to include uncrewed aircraft systems (UAS) and UAS critical components produced in foreign countries. Under this designation, covered equipment is prohibited from obtaining an FCC equipment authorization unless a specific determination is provided by the Department of War (DoW) or the Department of Homeland Security (DHS) affirming that the equipment does not pose unacceptable risks to the national security of the United States or to the safety and security of U.S. persons.
On January 7, 2026, DoW and DHS announced formal guidance detailing the application process for UAS and UAS critical component producers seeking a Conditional Approval. This individualized assessment evaluates national security risks, supply chain resilience, and commitments to establishing domestic manufacturing capacity. An approved entity is temporarily exempted from the equipment authorization restrictions imposed by the Covered List. Submissions do not guarantee approval, and all decisions rendered by DoW and DHS are final.
- Covered List update date: December 22, 2025.
- Guidance issuance date: January 7, 2026.
- Assessing agencies: Department of War (DoW) and Department of Homeland Security (DHS).
- Conditional Approval validity period: Up to 12 months.
Application Requirements and Corporate Disclosures
Any entity seeking Conditional Approval that is not already covered under DoW determinations, such as Blue UAS or Buy America frameworks, must submit detailed corporate and operational data. Incomplete submissions may result in processing delays or application denials.
Applications must include an official certification signed by an authorized corporate officer attesting that all submitted information is complete and accurate, with an obligation to promptly report material changes. Knowingly violating terms or submitting misrepresentations will result in immediate termination of the Conditional Approval and bar the entity from future applications.
- Legal name, jurisdictions of incorporation, and principal place of business.
- Complete corporate ownership structure, encompassing parent companies, subsidiaries, affiliates, and joint ventures.
- Identification of all beneficial owners holding five percent or greater equity.
- List of board members and executive leaders, including their nationalities and countries of residence.
- Disclosures of foreign government ownership, control, influence, financing, material support, or arrangements enabling technology access and operational influence.
Manufacturing, Supply Chain, and Onshoring Plans
Applicants must submit comprehensive documentation regarding their supply chain dependencies and bill of materials. This includes component origins, software provenance, and justifications for utilizing foreign manufacturing over domestic alternatives.
Additionally, applicants must present a detailed, time-bound U.S. manufacturing and onshoring plan. This requires identifying dedicated personnel responsible for quarterly progress reporting to the issuing agency, alongside documented capital expenditure commitments and progress updates on prior conditional approvals.
- Detailed bill of materials, country of origin for all hardware components, and origin of onboard software and firmware.
- Justifications for foreign critical component sourcing and cost percentage of U.S.-sourced components relative to total cost.
- Locations for manufacturing, final assembly, and product testing.
- Supply chain concentration metrics by total value and volume, including single points of failure, sole-source suppliers, and contingency plans.
- Dedicated point of contact or office providing quarterly status updates on the onshoring plan.
- Inventory of current U.S. manufacturing headcount, facilities, and committed capital expenditures planned over a 1-to-5-year timeline.
Agency Contacts
The guidance provides specific points of contact for inquiries regarding regulatory compliance and application processing.
- Covered List regulatory inquiries: Chris Smeenk (chris.smeenk@fcc.gov).
- Conditional Approval applications and submissions: drones@fcc.gov.