Federal Regulations Updates

Overview

As a research institution actively engaged in federally funded projects and Department of Defense (DoD) contracts, it is critical that all drone activities conducted under university oversight comply with current U.S. Federal Laws and Regulations.

Recent legislation, including the National Defense Authorization Acts (NDAA) and updates to the Federal Acquisition Regulation (FAR), has introduced strict limitations on the purchase and operation of foreign-manufactured drones, particularly those from China-based companies such as DJI. These rules apply to all projects funded by federal agencies and affect both current inventory and future procurement.

Recent NDAAs

FY 2020 NDAA
  • Introduced the foundational ban on using DoD funds to procure or operate:
    • Drones manufactured or assembled in adversarial countries (e.g., China, Russia, Iran, North Korea)
    • Drones containing critical components from these countries (e.g., flight controllers, cameras, radios)
  • Marked the start of DJI and similar manufacturers being deemed non-compliant for federal use.
  • Reinforced compliance with Section 848 and encouraged U.S. agencies to begin auditing drone fleets.
  • Directed investment into secure drone platforms and technologies (precursor to the Blue UAS initiative).
  • Strengthened cybersecurity and supply chain scrutiny of drone systems used in DoD contracts.
  • Supported further development of the Blue UAS Program to create a vetted list of compliant drones.
  • Expanded operational scrutiny for DoD contractors using drones in sensitive applications.
  • Began setting groundwork for removing non-compliant systems from use, not just stopping purchases.
  • Explicitly prohibited the operation (not just procurement) of banned drones on federal projects.
  • Applied stricter enforcement mechanisms through the Federal Acquisition Regulation (FAR).

What Does This Mean?

DoD Contracts

If you are working on a DoD–funded contract or grant, you are legally required to comply with all applicable drone restrictions outlined in the NDAAs and Federal Acquisition Regulations. This means you cannot purchase, operate, or use drones (including DJI and other foreign-manufactured systems) in connection with your project—even for data collection, testing, or training—unless they are explicitly approved under the DoD’s Blue UAS program.

A full list of restricted foreign companies can be found in the “American Security Drone Act-covered foreign entities” list here.

Drone use in federally funded research—such as projects supported by NSF, NIH, DOE, or NASA—is governed by restrictions originating from the National Defense Authorization Acts (NDAAs) and enforced through the Federal Acquisition Regulation (FAR). These rules prohibit the use of federal funds to purchase or operate drones from certain foreign manufacturers, including DJI, regardless of when the equipment was acquired. A transition period is in place, requiring all non-compliant drones to be removed from federally supported activities by December 22, 2025. To remain eligible for funding, researchers should begin reviewing their drone inventories and transitioning to approved systems.

We recommend discussing your grant with the Office of Grants and Contracts. Flight Operations can not lead you in the right direction unless we know where your grant is coming from and if there are any exceptions included in your grant.

Are There Any Exceptions to These Rules?

Short answer; no. These regulations apply to all federal grants unless an exception is clearly stated. CU strives to maintain strict compliance with federal regulations and help future researchers earn grant money for UAS research. As previously mentioned, non-DoD contracts have a grace period until the end of 2025.

 

Summary

The federal government has already put rules in place—through the NDAA and FAR—that prohibit the purchase and use of drones from certain foreign manufacturers, like DJI, in federally funded research. However, for non-DoD grants, there is a grace period until December 22, 2025, allowing institutions time to phase out non-compliant drones. After this date, using restricted drones in federal research projects will violate compliance requirements and could put funding at risk.