The Pentagon wants hundreds of thousands of cheap attack drones in American hands by 2027. The factories can mostly build them. The signatures required to buy, certify, and field them are another matter.
The Pentagon wants hundreds of thousands of cheap attack drones in American hands by 2027. The factories can mostly build them. The signatures required to buy, certify, and field them are another matter.
The Dominance Directive Meets the Defense Forms
The US Drone Dominance push — formalized through the June 2025 executive order on unmanned systems and the Pentagon's follow-on implementation memos — sets an aggressive target: arm every Army squad with small drones by the end of 2026 and flood the force with attritable systems by 2027. The money is arriving. The Army's FY2026 budget request put roughly $1.2 billion toward small UAS procurement and counter-UAS, and the reconciliation bill added billions more for autonomous systems across the services.
The technology is not the constraint. Switchblade 600s, Coyote interceptors, FPV airframes derived from Ukrainian designs — all of it exists, in production, today. The constraint is the administrative machinery that a system must survive between a successful demo and a fielded capability. That machinery was built for $40 million helicopters with 30-year service lives. It is now being asked to process $2,000 quadcopters with an expected service life measured in sorties.
Airworthiness for Aircraft Designed to Crash
Start with airworthiness. Under AR 70-62 and the broader military airworthiness framework, every Army aircraft — including a 3-kilogram FPV drone — requires an airworthiness release before soldiers fly it. The process assumes a certified design that stays stable across a fleet. Attritable drones break every assumption in the form.
Consider what airworthiness means for an FPV quad built from commercial flight controllers, where the firmware updates monthly, motors get swapped by unit armorers, and the airframe is expendable by design. Certifying one configuration takes months; the configuration is obsolete before the paperwork clears. The Army's answer so far has been a series of interim and tailored releases — airworthiness delegated down to lower approval levels, risk accepted on paper by commanders. That works for training ranges. It scales badly to a force-wide fleet, and nobody has yet published the doctrine for certifying a drone whose bill of materials changes weekly.
Ukraine solved this by not having the problem: no peacetime airworthiness regime, front-line feedback loops of days. The US cannot and should not copy that. But the delta between a 48-hour Ukrainian fielding cycle and a 14-month American certification cycle is the gap the Drone Dominance memos are actually trying to close.
ITAR on a Shopping Cart
The second wall is export control. ITAR treats many drone components — certain cameras, encrypted datalinks, inertial navigation units — as controlled defense articles regardless of how commercial they have become. This produces a running absurdity: a US unit can buy a drone whose parts are commercially available worldwide, but the manufacturer must navigate export-control classification before selling that same drone to an ally, and components sourced from allied firms can trigger licensing questions in the supply chain of an otherwise domestic system.
The NDAA Section 848 prohibitions and the Blue UAS cleared-list process add a parallel filter: no Chinese-made components, no DJI-derived supply chains, validated cybersecurity. The intent is sound. The side effect is a compliance layer that small drone firms — exactly the firms Drone Dominance wants to cultivate — must fund out of seed rounds. Blue UAS list evaluations have historically run six to twelve months, and being on the list has never guaranteed a contract, only eligibility. Companies like Skydio and Anduril can absorb that overhead. The two hundred FPV startups the Pentagon says it wants mostly cannot.
The Cybersecurity Queue
Layer three is cybersecurity certification. Every networked system needs an Authority to Operate under the Risk Management Framework, and as of November 2025, defense contractors handling controlled unclassified information fall under CMMC 2.0 enforcement. For a drone that talks to FAAD C2 or a tactical network, the ATO process alone can run longer than the hardware's commercial refresh cycle.
The practical result, visible already in Replicator tranche 1 and tranche 2, is that software approval — not airframe production — set the fielding tempo. Anduril's Ghost-X and PDW's C100 moved comparatively fast because the companies pre-built accreditation packages and maintained dedicated compliance staff. That is a capability, and it costs money, and it is now a quiet competitive moat that favors venture-backed primes over garage innovators. The Drone Dominance rhetoric celebrates the garage. The paperwork rewards the moat.
OTAs, FAR, and the Middlemen
The acquisition community's favorite workaround is the Other Transaction Authority — contracting instruments that bypass much of the Federal Acquisition Regulation and can put a prototype on contract in weeks. DIU used OTAs to field commercial drones at speed, and the services have leaned on them heavily for urgent counter-UAS buys like Coyote and Epirus Leonidas.
But OTAs have a known ceiling. They excel at prototypes and early fielding; transitioning to a program of record means re-entering the FAR world — cost accounting standards, technical data rights, competition requirements — often with the same documentation the OTA was invoked to avoid. The system has, in effect, built a fast lane that merges back into traffic at the worst possible point. The Replicator initiative's stated goal of "thousands of attritable autonomous systems across multiple domains within 18 to 24 months" was met largely by routing around normal acquisition entirely, with the deputy secretary personally arbitrating. That is not a process. It is a workaround held together by senior attention, and senior attention rotates.
The offices now trying to institutionalize the workaround — the Joint Counter-small UAS Office, DIU, the Army's UAS Project Office, and the new drone-dominance implementation teams — share a common playbook: pre-negotiated airworthiness templates, blanket ATOs for approved configurations, pre-competed OTA consortia so units can order drones like catalog items. Expect 2026 to be the year these mechanisms are tested at volume, and expect the first GAO report on their cost discipline shortly after.
The United States does not have a drone technology gap. It has a signature gap — measured in approval cycles, not kilograms of payload.
What to Watch Through 2027
The honest trajectory: the paperwork is being rewritten, but rewriting is not the same as rewritten. Specific markers over the next 6 to 24 months:
- Army squad-level drone fielding against the end-2026 deadline — watch whether "fielded" means trained and sustained or merely delivered. - A published tailored airworthiness standard for Group 1-3 attritables; if one does not appear by mid-2027, interim releases become the permanent exception. - Blue UAS list throughput — whether evaluation timelines compress toward 90 days as promised, or drift. - The first large OTA-to-program-of-record transition for an attritable system, which will show whether the fast lane actually connects to the highway. - CMMC enforcement effects on the small-drone industrial base, visible in contract-award concentration.
The factories are ready. Watch the forms.
The Pentagon wants hundreds of thousands of cheap attack drones in American hands by 2027. The factories can mostly build them. The signatures required to buy, certify, and field them are another…