The Federal Communications Commission has moved on several fronts that materially affect electronic warfare, spectrum use, and unmanned aircraft systems. The two most consequential items for the EW community are the addition of foreign-produced UAS and UAS critical components to the FCC Covered List and a continuing push to free up upper microwave bands for more intensive commercial use. Both carry direct operational and procurement implications for engineers, integrators, and responsible hobbyists.

On December 22, 2025 the Public Safety and Homeland Security Bureau announced that uncrewed aircraft systems produced in a foreign country and a broad set of UAS critical components are now included on the FCC Covered List. The practical effect is categorical and prospective: new models and new critical components produced abroad become ineligible for FCC equipment authorization, which is the gateway for lawful importation, sale, and operation in the U.S. The FCC clarified that equipment already authorized before the listing remains permitted to be imported, sold, and used for now, but that applicants for new authorizations must certify their devices are not “covered.” This action follows a National Security Determination from an Executive Branch interagency body and implements provisions called for by the FY2025 NDAA.

What that means on the ground. First, the immediate market effect is a freeze on the flow of newly developed foreign-produced UAS technologies into U.S. supply chains unless a specific DoD or DHS determination provides an exemption. Integrators and agencies that rely on foreign platforms must be cautious about future upgrades or replacement parts: a minor hardware or firmware revision that requires a new equipment authorization could trigger the prohibition. Second, certification houses and Telecommunication Certification Bodies will be performing stricter due diligence on UAS applications and grantee codes, and companies should expect additional scrutiny on supply-chain provenance. Finally, because the Covered List mechanism can be used in a non-entity specific way for the first time, manufacturers and systems architects should assume origin-of-production matters as much as vendor name.

Spectrum and counter-UAS consequences. The listing does not change the FCC’s long standing prohibition on private use of jammers or other unlawful RF interference. Electronic mitigation techniques that disrupt control or navigation links remain tightly regulated because they involve intentional interference with authorized radio communications. That prohibition continues to limit non-federal deployment of active electronic mitigations; any lawful use of non-kinetic or RF mitigation capabilities requires specific statutory or interagency authorization. At the same time, the policy shift makes domestic procurement of counter-UAS sensors, processing payloads, and mitigation components a higher priority for national and critical-infrastructure customers.

Parallel spectrum work: upper microwave bands. The FCC released a Notice of Proposed Rulemaking in 2025 to facilitate more intensive use of upper microwave spectrum. The aim is to increase flexibility and access in higher frequency bands that are attractive for high-capacity point-to-point links and certain sensing applications. The Commission extended comment deadlines for that NPRM, signaling that stakeholders should engage now if they want to influence technical sharing rules, emission limits, or licensing approaches. For EW engineers, these proceedings matter because relaxed rules or expanded commercial use in those bands will change the interference environment, potential deconfliction requirements, and opportunities for band-specific RF sensing or comms work.

Regulatory housekeeping and implementation timeline. The FCC has also been pruning obsolete rules to reduce regulatory clutter. A direct final rule eliminating outdated and duplicative wireless regulations was adopted in late 2025 and published in the Federal Register for an effective date in early 2026 unless adverse comments intervened. While this is mostly administrative, it is part of a broader FCC agenda to streamline processes that can affect how quickly equipment authorization and rulemaking updates move through the system.

Legislative and interagency context. Several pieces of legislation and executive initiatives provide the backdrop for the FCC actions. Notably, the SHIELD U Act and portions of the FY2025 NDAA articulate roles for FCC and NTIA in consultations about authorized counter-UAS activities and outline the need for multi-agency processes before non-kinetic measures are used by state and local actors. Until Congress and the executive branch provide a broader statutory framework authorizing non-federal RF mitigation measures, the FCC’s spectrum rules and equipment-authorization process will remain the main control points.

Operational takeaways for the EW community and drone operators:

  • Inventory and provenance controls: Immediately document which platforms and components in your inventory have pre-existing FCC equipment authorizations. Treat any hardware or firmware revision that would require a new authorization as a de facto procurement risk. Engage procurement and legal early.
  • Design to be modular and replaceable: Where possible, architect systems so that critical RF or sensor subsystems can be swapped to domestically sourced equivalents without needing full reauthorization. This reduces mission downtime if an item later becomes ineligible.
  • Don’t take enforcement risks: Do not acquire or operate jamming gear or other signal-disrupting equipment outside explicit federal authority. Civilian actors remain exposed to substantial fines, seizures, and criminal risk for unauthorized interference. Coordinate with federal partners if you believe an operational need requires active mitigation.
  • Participate in spectrum proceedings: If your work depends on upper microwave bands, submit technical comments to the FCC NPRM. Changes to sharing rules, out-of-band emission limits, or licensing could directly affect system performance and allowable operations.
  • Watch for waiver pathways: The FCC process contemplates case-by-case determinations from DoD or DHS that can exempt specific UAS or components. Companies should be prepared to provide evidence and engage with appropriate agencies to seek an exemption where national-security reviews are favorable.

Conclusion. The FCC’s December 2025 Covered List expansion and ongoing spectrum rulemaking together signal a shift toward tighter control of hardware provenance and greater emphasis on domestic supply resilience. For the EW and UAS communities, the immediate risk is operational friction during procurement and upgrade cycles. The practical response is straightforward: harden supply-chain documentation, minimize changes that trigger new authorizations, engage in the rulemakings, and avoid unauthorized RF mitigation. Those steps preserve mission capability while remaining inside the law.