A FASC-Prohibited Unmanned Aircraft System (UAS) refers to any drone or drone component that has been identified by the Federal Acquisition Security Council (FASC) as posing an unacceptable risk to national security and is therefore prohibited from being used in federal procurement and operations. These prohibitions apply to both the acquisition and use of such systems by executive agencies, as outlined in federal law and policy.
The restrictions are part of a broader federal effort to protect supply chains from foreign ownership, control, or influence—particularly in sensitive technologies such as surveillance, telecommunications, and unmanned systems. In the context of federal acquisition, including GSA Schedules and other contract vehicles, the use or procurement of FASC-prohibited UAS is strictly barred.
Background and Authority
The FASC was established under the Federal Acquisition Supply Chain Security Act of 2018, which gave the Council the authority to identify and recommend exclusion of technologies, manufacturers, or products that threaten the integrity or security of the federal supply chain. The process includes input from agencies such as the Department of Homeland Security (DHS), Department of Defense (DoD), and the Office of the Director of National Intelligence (ODNI).
Once a determination is made, the Federal Acquisition Security Council (FASC) may recommend that the Office of Management and Budget (OMB) issue a governmentwide exclusion or removal order, which applies to:
- Specific companies or suppliers
- Specific product lines, models, or components
- Entire classes of technology that meet certain risk criteria
FASC determinations are not discretionary for agencies; once published, agencies are required to comply and ensure the removal or non-procurement of the affected systems.
Why Certain UAS Are Prohibited
The primary reason for prohibiting specific unmanned aircraft systems is the national security risk associated with certain foreign-manufactured drones—particularly those made by companies with ties to foreign governments or intelligence services. These risks may include:
- Unauthorized data access or transmission to foreign servers
- Embedded vulnerabilities in hardware or firmware
- Backdoors or remote shutdown capabilities
- Inability to audit or control software functions
- Lack of transparency in supply chain manufacturing
In recent years, entities such as DJI (Da Jiang Innovations) have been the subject of scrutiny, and their products have been banned from federal use by legislation and policy directives.
Implementation in Federal Procurement
Contracting officers and procurement officials are responsible for ensuring that federal purchases are compliant with FASC-issued exclusion orders. This includes:
1. Screening vendors and products:
- Checking exclusion lists such as those published by OMB, GSA, or DHS
- Reviewing manufacturer disclosures for country of origin and supply chain transparency
- Avoiding resellers who may bundle prohibited UAS components in assembled systems
2. Updating contract language and clauses:
- Including FAR and agency-specific clauses prohibiting the purchase or use of banned UAS
- Requiring contractor certifications that confirm compliance with FASC directives
- Conducting post-award reviews to identify any unauthorized use of prohibited systems
Agencies may also use supply chain risk management tools and GSA-provided guidance to stay updated on compliance requirements. Vendors on GSA Schedules are required to certify that their offerings do not include FASC-prohibited items, and noncompliance can result in contract cancellation or enforcement action.
Conclusion
A FASC-Prohibited Unmanned Aircraft System is more than just a restricted product — it represents a clear line drawn by the federal government to protect its data, networks, and mission integrity from supply chain risks. For contractors, acquisition professionals, and federal program managers, understanding and adhering to these restrictions is essential. As threats evolve, the list of prohibited systems may expand, making ongoing compliance and awareness a critical component of responsible federal procurement.
