If you use drones for your funded research OR if you are involved in the purchase of drones or other unmanned aircraft systems (UAS)… research-related or not, READ THIS!
This Compliance Alert provides information regarding the federal government’s recent prohibition against the purchase or use of certain foreign-manufactured drones. This applies to both the purchase of these drones using federal funds as well as the use of these drones on sponsored awards or any activities funded in whole or in part by the federal government. In order to remain in compliance, we must avoid acquiring or using drones manufactured by those companies specified by the federal government.
What changed?
Recent federal laws (including the NDAA, FY2024, and the American Security Drone Act) restrict the use of certain drones in federally funded activities.
Key Rule
Effective December 22, 2025, federal funds cannot be used to purchase, operate, or use in any way, drones manufactured or assembled by “covered foreign entities”.
Who is covered?
This new rule applies to drones produced by entities tied to countries of concern which include:
- China
- Russia
- Iran
- North Korea
Who are some of the prohibited manufacturers?
Unless an exception applies or the funded agency has issued a waiver, the most common manufacturers that are now prohibited for use on anything funded federally are:
- Da-Jiang Innovations/DJI
- Autel Robotics
- Aerospace CH UAV Co., Ltd.
- Chengdu JOUAV Automation Tech Co., Ltd. (JOUAV)
- AEE
What counts as a "covered drone"?
To be covered, a drone must either be fully manufactured by a prohibited entity or be custom-built with foreign components, such as cameras, radios, flight controllers, or software.
Does this mean that I can not use my drone anymore?
No, but you need to be very careful. The prohibition is for anything that is federally funded. You can use one of these drones if (1) you, your department, or the university already own it AND (2) it is not being used for anything federally funded.
As long as all of the other requirements of UVM’s Unmanned Aircraft UOP are met, covered drones can be used for university operations such as the creation of marketing materials or promotional videos and natural disaster recovery efforts (to name a couple).
Be sure to read the policy and make sure you’ve met all the requirements before flying your drone.
Can I still purchase a covered drone or can I use my personal drone even if it is covered?
Because the University receives federal funding for more than just sponsored research, while this regulation is in effect, the University will no longer purchase prohibited drones. If you already own one, it is your responsibility to ensure that it is not being used on a federally funded award… even if it’s your own personal drone. If you choose to purchase one using your own money, you are still prohibited from using it on a federal award and you must still meet all the other requirements under UVM’s Unmanned Aircraft UOP.
What should I do now?
If you use drones in your work, you should do the following:
- Inventory what you have/what you use. Identify all drones used in research or for other work-related purposes.
- Ensure that your drone (or other UAS including model aircraft) has been registered and that the use of your drone has been approved according to UVM’s Unmanned Aircraft UOP. Contact the Office of Emergency Management (email link) if your drones are not registered or if you are not sure.
- Flag any equipment from a prohibited manufacturer.
- Transition federally funded projects to compliant drones.
- Check before you buy and make sure that the manufacturer is not prohibited.
If you are using drones on a federal award, you must stop immediately and contact the UAS Working Group (email link) to determine next steps.
Are there any compliant options currently?
Yes, with multiple tiers of compliance depending on requirements of the federal funding source:
NDAA-Compliant
- These systems are noted as compliant with NDAA FY24 regulations. There is no central database of NDAA-compliant UAS and sensors.
- These may be suitable for various federally funded research projects; however, you would need to confirm this with your funding agency.
- Ensures product/device security and supply chain risk management compliance.
- All systems and components on Green UAS list are NDAA-compliant.
- Primarily focused on US Defense Innovation Unit (DIU) Authority to Operate (ATO).
- Strictest security standards that meet qualifications for use by DoD. May be required for projects funded by USACE or other DOW departments.
- All systems and components on DCMA Blue List are NDAA-compliant.
Where can I find out more information?
The text of the public law (PDF) can be found on the congress.gov website. Search for “1709” and then find 1709(a)(1). You can also use the “Consolidated Sanction List” and search for the drone or component manufacturer there. UVM’s Emergency Manager (email link), the Assistant Director for UAS, Spatial Analysis Laboratory (email link), the Asst. Chief Safety & Compliance Officer (email link), and the Executive Director of Research Administration and Integrity (email link) are all good resources to get information related to drone usage on campus or for university activities including research.
