FCC Proposal May Increase Scrutiny of Drone Software and Supply Chains
The Federal Communications Commission has proposed new rules that could require drone manufacturers to disclose detailed information about the hardware and software inside their products

The Federal Communications Commission is considering new rules that could bring drone software and supply chains under greater scrutiny. A recent proposal published in the Federal Register could require equipment certification applicants to provide a Hardware Bill of Materials and a Software Bill of Materials.
## Background The proposal is part of the FCC's Third Further Notice of Proposed Rulemaking, which covers a broad range of possible changes to the FCC equipment authorization system. The notice was published on August 7, opening the proceeding for public comment. The proposals accompany the FCC's Third Report and Order, adopted on July 22 and released on July 23.
The FCC is seeking comment on the proposal and possible narrower alternatives, which could limit the requirements to certain sectors or products. The proposal has sparked concern among drone manufacturers, who may be required to document the origin of their components and software.
## Proposed Requirements The proposed requirements would apply to all certification applicants, who would be required to submit signed records identifying each component's producer, production location, and percentage of value by country. The records would need to be updated within 30 days of any change. The FCC is also considering whether equipment containing software or firmware produced by a Covered List entity should be prohibited from receiving authorization.
The following table summarizes the proposed requirements:
## Implications for Drone Manufacturers The proposed rules could have significant implications for drone manufacturers, who may need to re-evaluate their supply chains and software development processes. According to Will Dawson, Director of the Agricultural Drone Initiative, the proposal signals that the FCC's scrutiny could extend deeper into drone hardware, software, and firmware.
The rules could also affect the use of third-party firmware, foreign-developed applications, and imported components. Drone manufacturers may need to document the origin of these components and software, and ensure that they comply with the proposed requirements.
## Next Steps The FCC is seeking comment on the proposal, which is currently open for public comment. The agency will review the comments and consider possible narrower alternatives before making a final decision. The outcome of the proceeding could have significant implications for the drone industry, and manufacturers should closely monitor the developments.





