NDAA Compliance

Every Fiscal Year Congress approves a National Defense Authorization Act (NDAA) that authorizes appropriations for military activities and programs for the Department of Defense (e.g., personnel; research, development, test, and evaluation; and procurement of items such as UASs and components).

The term “NDAA Compliant” is widely used in the drone industry to refer to drones that are available and safe to use for government agencies and enterprises.

Two important constraints created for federal agencies include:

  • The National Defense Authorization Act (NDAA) which defines what the Department of Defense can buy (and is used by other agencies as implicit guidance)

  • The Executive Order 13981 advising against purchasing and using Chinese and Russian* drones and smart components in all federal agencies

The Executive Order 13981 is a federal directive issued by the President that orders a risk assessment of all “covered UAS” in use by Government Departments. A “covered UAS” has been manufactured in part or whole by an entity domiciled in an adversary country. It also includes the UAS that uses critical electronic components installed in flight controllers or gimbals that have been manufactured in an adversary country. The Executive Order advises against the use of microprocessors and software (or assemblies, like flight controllers).

With this, The US House Armed Services Committee voted in favor of the National Defense Authorization Act (NDAA) for Fiscal Year 2022, which included tighter language over sourcing of printed circuit boards from adversarial nations. The committee passed the Annual Defense Appropriation Bill. The bill tightens restrictions on the acquisition of certain printed circuit boards for which supply chains may be susceptible to interference by the Chinese government.

"These provisions will reduce supply chain risk in critical defense systems, and will encourage development of reliable, effective, and efficient sources of printed circuit board technology in the United States and its allies and partners," the NDAA summary says.

In 2021, IQ began manufacturing some of its PCBs in the US to address this issue for a few of its customers selling into the DoD. The first wave of this legislation focused heavily on flight control technology, but it is clear that restrictions on motor controllers (and any other PCB on-board a UAV) may be the next target for FY2022 NDAA.