What do I have to keep doing after an FCC Conditional Approval?

No. The approval lifts the Covered List bar on the named models. Each of them still needs its FCC authorization afterwards.

The robotics guidance describes covered equipment as “prohibited from receiving an equipment authorization from the FCC unless the Department of War (DoW) makes a specific determination.”

Under 47 CFR § 2.907(a), a radio-frequency device may be certified only by the Commission or a recognized Telecommunication Certification Body (TCB). The TCB issues the authorization itself. Whether a covered product can reach an authorization at all is answered in the Covered List FAQ.

Source: 47 CFR § 2.907(a); Advanced Robotics Conditional Approval guidance (Annex A), July 27, 2026.

No. Delivery to a customer waits for the authorization.

Under 47 CFR § 2.803(a), marketing “includes sale or lease, or offering for sale or lease, including advertising for sale or lease, or importation, shipment, or distribution for the purpose of selling or leasing.” A robot supplied as a service is leased, so it is marketed.

Conditional sales contracts under § 2.803(c)(2)(i) are allowed only for devices that “could be authorized under the current rules.” They require three prominent disclosures: that delivery is conditional on authorization, that FCC rules do not address consumer-protection law, and the seller’s obligations if authorization fails.

Units may be imported under § 2.1204(a)(3) for testing and evaluation, product development or suitability for marketing, provided they are not offered for sale or marketed.

Source: 47 CFR §§ 2.803(a), 2.803(c)(2)(i), 2.1204(a)(3).

Yes. The FCC’s module integration guide requires the host product to obtain the equipment authorization for its unintentional-radiator functions under Part 15 Subpart B. It also requires testing of the finished product with its transmitters operating, which can be done by spot-checking emissions while all of them transmit simultaneously.

A certified module may be used only under the conditions of its grant. Under § 2.6 of the FCC’s Knowledge Database (KDB) publication 996369 D03, using it with other transmitters operating simultaneously requires additional evaluation, testing, or testing and a Class 2 permissive change. Where no emission of the combined device exceeds the limit of any individual device, KDB policy lets the host manufacturer evaluate the combination without a Class 2 permissive change. The host manufacturer must fix any failure.

From October 13, 2026, a new application cannot obtain an authorization for a device carrying a logic-bearing component, such as a module, produced by an entity named on the Covered List, where the device would be barred had that entity produced it. The bar does not apply to the entries defined by place of production, such as foreign-produced UAS and routers, unless the producer is itself named. The component rule page covers its reach.

Source: FCC KDB 996369 D03 v01r01 (October 25, 2022) § 2.6 and n.7; FCC KDB 996369 D04 v02 (October 13, 2020); 47 CFR § 2.947; FCC 26-50, 91 FR 57798 (September 11, 2026).

The authorization stands. Under 47 CFR § 2.960(i), “even if the Commission withdraws recognition of a TCB, the certifications issued by the TCB remain valid unless specifically set aside or revoked by the Commission.”

The Enforcement Bureau cited that rule twice in DA 26-970, a September 11, 2026 Citation to Derycom Certification Services, Inc. for falsely stating it was a US-based entity to obtain TCB status and for certifying at least ten devices beyond its authorized 40 GHz scope. The Citation sets aside none of Derycom’s certifications.

Under § 2.960(d), the Commission recognizes a TCB located outside the United States only under a mutual recognition agreement (MRA). DA 26-970 states that “no existing MRA permits recognition of TCBs in China.”

Source: 47 CFR §§ 2.960(d), 2.960(i); FCC Citation DA 26-970, File No. EB-SED-26-00041408, September 11, 2026.

Quarterly status reports. The Conditional Approval guidance for advanced robotic devices and power inverters requires a detailed, time-bound onshoring plan with a dedicated point of contact or office reporting status to the issuing agency quarterly.

Review sits with the Department of War for robotics, and with the Department of War or the Department of Homeland Security for inverters.

An authorized corporate officer certifies that the application information is complete and accurate. The applicant discloses material changes promptly. Knowing violations or material misrepresentation lead to termination and preclusion from re-applying.

An earlier grant’s record feeds the next application. The robotics guidance, at Annex A item 3.e, asks a repeat applicant for “an inventory of the progress made” on earlier onshoring plans. What happens when a plan slips is answered on the Conditional Approval page.

Source: Advanced Robotics and Power Inverter Conditional Approval guidance (Annex A), July 27, 2026.

The onshoring plan and updated vetting. The FCC’s list of UAS Conditional Approvals states that, consistent with the National Security Determination of July 21, 2026, approvals that do not reflect a termination date “will remain effective indefinitely, so long as the entity that received Conditional Approval abides by the onshoring plan outlined in its Conditional Approval application and pursuant to updated vetting of the products.”

Why drone grants carry no end date is answered on the Conditional Approval page.

Source: FCC list of UAS Conditional Approvals, footnote; UAS National Security Determination, July 21, 2026.

Two signed statements, made as of the date the application is filed with a TCB. Under 47 CFR § 2.911(d)(5), the applicant certifies that the equipment is not prohibited from receiving an equipment authorization under § 2.903. It also states affirmatively or negatively whether the applicant is identified on the Covered List.

If the Covered List is modified after that certification but before the grant, § 2.911(d)(6) requires a new signed certification. A Class II permissive change carries the same two statements under § 2.1043(b)(2)(i)(B) and (C). The Covered List FAQ covers changes to an authorized covered product, and Protocol for manufacturers covers the changes that force a fresh attestation.

A false attestation opens the streamlined revocation track. In the words of DA 26-839, the Commission’s rules “contain streamlined procedures for revoking authorizations of covered equipment if the applicant made any false statement or representation in its attestation(s).”

Source: 47 CFR §§ 2.911(d)(5), 2.911(d)(6), 2.1043(b)(2)(i)(B)-(C), 2.939(d); FCC Order of Revocation DA 26-839 ¶ 4, August 11, 2026.

Yes. Under 47 CFR § 2.911(d)(7), an applicant for equipment authorization designates an agent located in the United States to accept service of process. The attestation names the agent, its physical US address and its email address. The designated agent signs it too. An applicant located in the United States may designate itself.

The applicant consents to service of process in the United States “for matters related to the applicable equipment,” at the agent’s physical US address and email address. The attestation quoted in DA 26-694 accepts the obligation to maintain the agent for “no less than one year after either the grantee has permanently terminated all marketing and importation of the applicable equipment within the U.S., or the conclusion of any Commission-related administrative or judicial proceeding involving the equipment, whichever is later.”

Equipment authorized through a Supplier’s Declaration of Conformity needs a responsible party located in the United States under § 2.909(b). That party is the manufacturer or assembler, or for imported equipment the importer.

Source: 47 CFR §§ 2.909(b), 2.911(d)(7); FCC Notice of Apparent Liability DA 26-694 ¶¶ 8-9, July 10, 2026; FCC Forfeiture Order DA 26-920 ¶ 2, August 31, 2026.

In the Cogito Tech matter service still counted. Email and certified mail sent to one of the company’s two designated agents came back undeliverable, and the Enforcement Bureau also reached the company directly by certified mail and the other agent by email.

Cogito drew a $25,000 forfeiture order on August 31, 2026, DA 26-912, for failing to respond to the Bureau’s Letter of Inquiry. The violation found is the non-response.

Source: FCC Notice of Apparent Liability DA 26-694 ¶ 13, July 10, 2026; FCC Forfeiture Order DA 26-912, August 31, 2026; 47 U.S.C. § 503(b)(1)(B).

Yes, within 21 days. Under 47 CFR § 2.945(b)(1), the Commission may request that the responsible party or any other party marketing the equipment submit a sample, or provide a voucher for the equipment to be obtained from the marketplace. The requested party bears the shipping. Failure to comply within 21 days can bring suspension of applications or forfeitures.

Under § 2.945(c), each responsible party submits its § 2.938 records on request within 21 days, with forfeiture for failure. Those records are design drawings and changes, production inspection and test procedures, and test results. The Letter of Inquiry in the Cogito Tech matter demanded an equipment voucher under § 2.945(b)(1).

A TCB also performs post-market surveillance of the equipment it certified under § 2.962(i), based on type testing a number of samples. A failure it finds triggers written notice to the grantee and the Commission.

Source: 47 CFR §§ 2.938, 2.945(b)-(c), 2.962(i); FCC Notice of Apparent Liability DA 26-694, July 10, 2026.

Yes, under 47 CFR § 2.939. Three of its provisions bear on covered equipment. Section 2.939(a) is general revocation. It reaches “any equipment authorization” for reasons that include “conditions coming to the attention of the Commission which would warrant it in refusing to grant an original application.”

Section 2.939(d) provides streamlined revocation where the applicant made a false statement or representation in its covered-equipment attestation. Section 2.939(e) limits an existing authorization to prohibit continued importation or marketing. It is exercised at bureau level by the Public Safety and Homeland Security Bureau and the Office of Engineering and Technology, after notice and comment. An (e) limitation does not revoke the underlying authorization.

Source: 47 CFR § 2.939(a), (d), (e); FCC Public Notice DA 26-832, August 10, 2026; FCC Order of Revocation DA 26-839 ¶ 4, August 11, 2026.

Odyssey Robot LLC lost its authorizations on the false-attestation track. DA 26-839, released August 11, 2026 by the Chiefs of the Office of Engineering and Technology and the Public Safety and Homeland Security Bureau in ET Docket 26-186, revoked the authorizations for a drone and its controller, FCC IDs 2BSYT-FMAWZOD and 2BSYT-YMAWZOD. The revocation took effect on the date of the order, under 47 U.S.C. § 302a and 47 CFR § 2.939(d).

Odyssey attested that the equipment was not covered on January 12, 2026. The grants issued April 20, 2026. Revocation came about seven months after the attestation.

Published revocation orders from 2004 and 2005 turned on nonconformance. DA 04-1704 revoked the certification of radios authorized for voice emissions only that used data emissions to send GPS location information. DA 05-1014 revoked two certifications for remote controls that could be tuned to unauthorized and restricted-band frequencies. Both revoked under § 2.939(b) on grounds in § 2.939(a)(2) and (a)(4). Section 2.939(a)(2) reaches equipment that “does not conform to the pertinent technical requirements or to the representations made in the original application.”

Source: FCC Order of Revocation DA 26-839, ET Docket 26-186, August 11, 2026; DA 04-1704, 19 FCC Rcd 10643, June 16, 2004; DA 05-1014, EB Docket 05-30, April 18, 2005; 47 CFR § 2.939(a)(2), (a)(4), (b), (d).

Yes, under § 2.939(e). DA 26-635, released June 26, 2026 in PS Docket 26-72, prohibits continued importation and marketing of equipment on Covered List entries dated 2024 or earlier that was authorized before the 2022 rules. It took effect July 16, 2026.

A limitation leaves the authorization in place. The drone category proposal DA 26-758, released July 21, 2026, states that the limitation “would not result in the revocation of an existing authorization of covered equipment and, therefore, would not affect the continued use or operation of devices that consumers already possess.”

The drone proposal DA 26-742, released July 17, 2026 and directed at nine named producers, carves out equipment holding a Department of War or Department of Homeland Security Conditional Approval. Whether a Conditional Approval protects a product already on the market is answered on the Conditional Approval page.

Source: 47 CFR § 2.939(e); FCC Public Notice DA 26-635, PS Docket 26-72, 91 FR 41023, July 6, 2026; FCC Public Notice DA 26-742, PS Docket 26-184, 91 FR 48108, July 30, 2026; FCC Public Notice DA 26-758, PS Docket 26-189, 91 FR 48870.

Condition maintenance after grant is $20,000 to $30,000 per year, offered at grant notification. It covers quarterly point-of-contact status-report support, the material-change disclosure file, updated-vetting readiness, and milestone evidence against the onshoring plan.

Equipment authorization management is $12,000 to $25,000, labs at actuals, for post-approval certification through accredited laboratories and TCBs. US Responsible Party and Agent for Service is $4,000 to $6,000 per year.

Annual attestation and monitoring is $15,000 to $46,000 and up per year, tiered by stock-keeping unit (SKU) count, for a standing evidence file with annual re-verification. Continuous Compliance is $3,000 to $6,000 per month. It includes the annual attestation at the covered tier of up to ten SKUs, a quarterly evidence refresh, Covered List and Uyghur Forced Labor Prevention Act (UFLPA) Entity List change alerts scoped to the client’s own supplier bench, and one incident-response activation each year.

Source: Gatewell Group Services, fees as of September 29, 2026.