12 Key NDAA and Blue UAS Requirements Every Drone Buyer Should Know
Three separate checks decide whether a drone can be bought and flown in U.S. government and grant-funded work: NDAA sourcing rules, the Blue UAS Cleared List, and FCC equipment authorization. Passing one does not mean passing the others.
NDAA rules govern who made a drone and its critical parts, and bind federal agencies, contractors and funds. Blue UAS is a list of vetted models and components, now run by the Defense Contract Management Agency (DCMA). FCC authorization lets a drone be imported or marketed, and since December 2025 the Covered List blocks new authorizations for foreign-produced drones unless exempt.
This is general information, not legal advice. Rules were checked on September 22, 2026.
How we chose
Quick comparison
| Requirement | Source | Best for | Notable |
|---|---|---|---|
| NDAA §848 | FY2020 | DoD buyers | Covers critical parts |
| NDAA §817 | FY2023 | DoD contractors | Contractor rule, Oct 2024 |
| NDAA §1822 | FY2024 | All agencies | FASC list in SAM |
| NDAA §1823, §1826 | FY2024 | Federal buyers | In force Dec 2023 |
| NDAA §1824, §1825 | FY2024 | Grantees | In force Dec 2025 |
| FAR 52.240-1 | FAR | Contractors | Since Nov 2024 |
| NDAA §162 | FY2025 | DoD suppliers | Teardowns |
| NDAA §1709 | FY2025 | DJI, Autel users | Covered List trigger |
| Blue UAS list | DCMA | Defense buyers | Moved Dec 2025 |
| Covered List | FCC | Importers | Since Dec 2025 |
| Exemptions | FCC | OEMs | To Jan 1, 2028 |
| Proposals | FCC | Fleet owners | Not final |
FY2020 NDAA §848: the original DoD ban
Best for: Department of Defense buyers and program offices.
Section 848 bars DoD from operating or buying a drone made in a covered foreign country or by an entity domiciled there. It also covers drones that use flight controllers, radios, data links, cameras or gimbals made there, ground control or operating software developed there, or network and data storage run from there. That component list is why “NDAA-compliant” claims depend on the parts inside a drone. The text sits as a note to 10 U.S.C. 4871.
FY2023 NDAA §817: more countries and a contractor rule
Best for: companies holding or bidding on DoD contracts.
Section 817 amended §848. It defines the covered foreign countries as China, Russia, Iran and North Korea, and names DJI and its affiliates as a covered drone company. It also adds a contractor rule: from October 1, 2024, DoD may not enter, extend or renew a contract with an entity that operates covered-company drone equipment in performing DoD work. Narrow exemptions and written waivers exist, but contractors should not assume one applies.
FY2024 NDAA §1822: covered foreign entities
Best for: federal agencies and anyone selling to them.
The American Security Drone Act of 2023 is sections 1821 to 1832 of the FY2024 NDAA. Section 1822 defines a covered foreign entity as one on a Federal Acquisition Security Council list published in SAM. It can include Consolidated Screening List firms, firms under foreign extrajudicial direction, firms DHS finds pose a national security risk, entities domiciled in or influenced by China, and their affiliates. Unlike §848, this law applies government-wide.
FY2024 NDAA §1823 and §1826: buying and purchase cards
Best for: contracting officers and cardholders at any federal agency.
Section 1823 bars executive agencies from procuring a drone manufactured or assembled by a covered foreign entity, including its communication links and control components. Section 1826 took effect immediately and bars using government purchase cards to buy one. Both apply from enactment on December 22, 2023. Narrow national-interest exemptions exist for DHS, DoD, State and the Attorney General, and section 1832 covers some wildfire, search and rescue, intelligence and Tribal uses.
FY2024 NDAA §1824 and §1825: operating and federal funds
Best for: agencies, grant recipients and service contractors.
Both took effect on December 22, 2025, two years after enactment. Section 1824 bars federal agencies from operating a drone made or assembled by a covered foreign entity, including through contracted services. Section 1825 bars using federal funds awarded through a contract, grant or cooperative agreement to buy or operate one. That second rule reaches state, local and private recipients of federal money, which is why grant-funded programs now check sourcing first.
FAR 52.240-1: the contract clause
Best for: federal prime contractors and subcontractors.
The FAR Council implemented the American Security Drone Act through an interim rule effective November 12, 2024. It created clause 52.240-1, “Prohibition on Unmanned Aircraft Systems Manufactured or Assembled by American Security Drone Act-Covered Foreign Entities.” The clause carries the statutory prohibitions into contract terms, including the rule that from December 22, 2025 contractors may not operate a covered drone in contract performance or use federal funds to buy or run one. Check which clause version your contract uses.
FY2025 NDAA §162: supply chain teardowns
Best for: DoD supply chain planners and component suppliers.
Section 162 directs DoD to find risks in the small drone supply chain and build resilience with domestic and allied parts. DoD must fully disassemble a DJI drone, or a similar one from a covered foreign country, within 90 days and at least every three years until 2034 to build a component risk taxonomy. It also calls for a risk framework, a review of suppliers for the DoD “1260H” list, and a sourcing strategy. It bans no product by itself.
FY2025 NDAA §1709: the DJI and Autel trigger
Best for: operators running DJI or Autel fleets.
Section 1709 gave a national security agency one year to decide whether DJI and Autel communications and video surveillance equipment posed an unacceptable risk. If no agency acted, the FCC had to add that equipment to its Covered List. The FCC added it on December 22, 2025. Covered List status blocks new FCC authorizations for those products. The FCC has said drones already bought can still be flown, but new DJI and Autel models cannot be authorized.
The Blue UAS Cleared List and Framework
Best for: defense buyers and OEMs seeking DoD sales.
The Blue UAS Cleared List names drone platforms vetted for cybersecurity and supply chain risk. The Blue UAS Framework lists vetted components and software for builders. The Defense Innovation Unit announced on December 3, 2025 that the program had moved to DCMA’s Unmanned Systems Experimental Command in Palmdale, California, and that listed companies did not need to recertify. Blue UAS covers named models. An “NDAA-compliant” claim is not the same thing.
The FCC Covered List for foreign-produced drones
Best for: importers, resellers and OEMs that build outside the U.S.
On December 22, 2025 the FCC added all drones and drone critical components produced in a foreign country to its Covered List (DA 25-1086), based on an Executive Branch national security determination. Critical components include data links, flight controllers, ground stations, navigation, sensors, cameras, batteries and motors. New covered products cannot receive FCC authorization, so they cannot be imported or marketed. Models authorized earlier can still be imported, sold and used for now.
FCC exemptions under DA 26-761
Best for: OEMs planning products for the U.S. market.
The FCC’s July 21, 2026 notice extended two exemptions to January 1, 2028: products on DCMA’s Blue UAS Cleared List, and “domestic end products” under the Buy American standard, meaning made in the U.S. with domestic components above the FAR threshold (65% for items delivered 2024 through 2028). Conditional Approvals from the Department of War or DHS no longer expire on December 31, 2026 and last while the holder keeps to its onshoring plan.
Pending FCC proposals on authorized drones
Best for: fleet owners planning 2027 purchases.
Two open proposals could stop sales of already-authorized models. DA 26-742 (July 17, 2026) seeks comment on ending import and marketing of certain covered drones and §1709 equipment. DA 26-758 (July 21, 2026) targets foreign-produced “military-grade” drones: 55 lb and heavier aircraft, pesticide sprayers, and those with thermal imaging, lidar, docks or swarming. Neither would stop use of drones already bought. As of September 22, 2026, neither was final, and adoption dates were not set.
Common questions
What is the difference between NDAA compliant and Blue UAS?
NDAA compliance is a sourcing test set by law: where a drone and its critical parts are made and by whom. Blue UAS is a DCMA list of specific models and components that passed a government review. “NDAA-compliant” is usually a maker’s own claim, not a certification.
Does NDAA compliance mean a drone has FCC approval?
No. NDAA rules govern government purchases and funds. FCC authorization governs whether a drone can be imported or marketed at all. A foreign-produced drone can meet NDAA rules and still need a Covered List exemption (Blue UAS, Buy American or a Conditional Approval) for a new authorization.
Can I still fly my DJI drone?
The FCC has said the Covered List action does not affect drones already lawfully bought. Federal agencies and federally funded programs differ: §1824 and §1825 bar operating covered drones from December 22, 2025. Pending FCC proposals target further sales, not use.
Building to these rules
Settle sourcing, Blue UAS and FCC plans early, since each shapes supplier choices. Aerora Technology, a Santa Clara ODM that builds to NDAA (FY2020 §848 / FY2024 §1823-1826) sourcing requirements, manufactures in Vietnam and is not on the Blue UAS list, so, as with any offshore-built hardware, ask for each product’s FCC authorization and exemption status. See ODM services and our list of UAV contract manufacturers for U.S. drone OEMs.
Related reading: Best drone industry conferences.
Sources (14)
- https://uscode.house.gov/view.xhtml?req=granuleid%3AUSC-prelim-title10-section4871&num=0&edition=prelim (FY2020 NDAA §848 as amended by FY2023 NDAA §817, 10 U.S.C. 4871 note)
- https://www.mayerbrown.com/en/perspectives-events/publications/2022/12/us-ndaa-for-fiscal-year-2023-important-changes-to-procurement-laws-and-policy
- https://www.govinfo.gov/content/pkg/PLAW-118publ31/html/PLAW-118publ31.htm (FY2024 NDAA §§1821-1832)
- https://www.acquisition.gov/far/52.240-1
- https://www.govinfo.gov/content/pkg/FR-2024-11-12/html/2024-26061.htm
- https://www.govinfo.gov/content/pkg/PLAW-118publ159/html/PLAW-118publ159.htm (FY2025 NDAA §162 and §1709)
- https://www.diu.mil/latest/dius-blue-uas-list-to-transition-to-dcma
- https://docs.fcc.gov/public/attachments/DA-25-1086A1.pdf
- https://www.hklaw.com/en/insights/publications/2025/12/fcc-adds-all-foreign-made-drones
- https://docs.fcc.gov/public/attachments/DA-26-22A1.pdf
- https://docs.fcc.gov/public/attachments/DA-26-761A1.pdf
- https://www.acquisition.gov/far/25.101
- https://docs.fcc.gov/public/attachments/DA-26-758A1.pdf
- https://jrupprechtlaw.com/fcc-drone-import-marketing-ban/
Ready to build what’s next?
Whether you’re developing autonomous aircraft, robotics, intelligent sensing systems or connected platforms, Aerora can help bring your vision to life.
Submit a design inquiry