We spent this week at Commercial UAV Expo in Las Vegas. It's the largest commercial drone show in the country, and it's a good place to take the industry's temperature: who's flying, who's selling, and what everyone is worried about. This year the worry was easy to find. Almost every conversation we had with an operator — including operators already flying paid missions and running profitable businesses — eventually arrived at the same question: how do we become NDAA-compliant?
What Changed in December
On December 22, 2025, the FCC added foreign-made unmanned aircraft systems and their critical components to its Covered List, and named DJI and Autel specifically. In practical terms, that means no new equipment authorizations for those manufacturers' products — the 2026 models can't legally come to market in the United States. Aircraft that were already authorized can keep flying, and the FCC has waived the restriction on software updates for existing equipment through at least the start of 2029. DJI and Autel are both challenging the listing, and briefing in the Ninth Circuit doesn't begin until November. So nothing is fully settled, and nothing disappears tomorrow.
The same day, the procurement side finished tightening. The American Security Drone Act — which extends the Defense Department's long-standing restrictions to every federal agency and to programs spending federal money — reached full effect. If you want to sell drone services into a federal contract, or into a state or local program funded by a federal grant, your aircraft can't come from a covered foreign entity. Not the airframe, and not the parts inside it.
Why "Just Swap the Drone" Doesn't Work
Here's the part that was catching people off guard on the show floor. NDAA compliance isn't a certificate you apply for. It's a property of the bill of materials. The rules look at the critical components — the flight controller, the radio and communication modules, the camera and gimbal, the navigation system — and if any one of them comes from a covered entity, the whole aircraft fails. There is no partial credit.
That's what makes retrofitting so hard. An operator who built a business on a well-known foreign platform doesn't have one problem to solve; they have four or five, and each one lives inside a tightly integrated product they didn't design. Swap the radio and the flight controller may not talk to it. Swap the gimbal and the software that made the aircraft useful in the first place stops working. Most of the teams we spoke with had already worked this out, which is why the question was never whether to comply. It was how, and how much it would cost.
One more thing worth saying plainly, because it came up again and again: the Department of Defense's Blue UAS list is a validation program, not the law. An aircraft can be fully NDAA-compliant without appearing on it. The list is useful assurance. It is not the finish line.
The Booth That Made Us Laugh
DJI had a booth. We'll admit that got a laugh out of us — nine months after the FCC listing, with new products frozen out of the market and litigation under way, the company at the center of the entire conversation was right there on the floor. It says something about how much of this industry was built on that hardware, and how far the industry now has to travel.
What We Did Differently — and Why It Wasn't Clever
When we started Civilian Aeronautics, we made a decision that felt expensive at the time: we would build our own aircraft, from the airframe up, rather than adapt someone else's. Not because we saw the December listing coming — nobody had that calendar — but because our customers are fire departments and public agencies, and we knew that anything we flew for them would eventually be held to the government's supply-chain rules. Designing for compliance from the first part was cheaper than earning it later.
So today every critical component in our aircraft comes from U.S. and allied manufacturers. Flight controller, propulsion, mesh radio, thermal payload — none of it from a covered entity, and no Chinese-origin parts anywhere in the system. Our airframes are proprietary, designed and built in-house in Los Angeles. We'll name the specific vendors once each has confirmed they're comfortable being cited; for now, the categories are the point.
The reaction to that on the floor was consistent: surprise. Most of the teams we talked to had assumed a company our size would be flying a modified commercial platform, because that's the fast route, and it's the route most of the industry took. Hearing that we'd built the whole stack — airframe, autonomy, mission software, and payload integration, engineered as one product — was not the answer they expected.
What It Cost Us, and What It Bought
We should be honest about the trade. Building everything ourselves is why our observer aircraft, the CA-O1, is in final assembly instead of already flying. It's why our suppression platforms are still on the drawing board. The hard path is slower, and we have felt every month of it.
But this week made clear what the slowness bought. The operators who beat us to market are spending 2026 re-engineering their fleets around a rule they didn't design for. We're spending it finishing an aircraft that was designed for the rule from the beginning. When the CA-O1 flies, it flies compliant on day one, with no retrofit ahead of it — and the same will be true of everything that comes after it.
The Short Version
NDAA compliance is a property of components, not a certificate. Every critical part has to clear the bar, and one failure fails the aircraft. The industry is discovering that retrofitting toward that standard is hard and expensive. We didn't have to discover it, because we designed for it before we ordered the first part — and that, more than any single feature, is what we came home from Las Vegas feeling good about.
If you're a fire agency or a public-sector buyer trying to work out what the December rules mean for the aerial services you can procure, we're happy to walk through it. It's a conversation we've been having all week.
Sources: FCC Covered List · Iowa State CALT — Foreign-Made UAS Stay on the FCC Covered List as DJI and Autel Challenges Proceed