Cite as. Gatewell Group, The Gatewell Protocol for Origin Evidence, Profile DU (Defense and federal UAS) (Public comment draft, Revision 1, September 17, 2026), https://gatewellgroup.com/protocol/profiles/defense-uas/. Cite a clause by its number, which is its anchor: https://gatewellgroup.com/protocol/profiles/defense-uas/#du.1.1.
Conformity with a profile is a documentation standard. It is not a determination by any contracting officer, awarding agency or other government body that an item complies with the governing instrument, and it guarantees no procurement, award or audit outcome. This document is not legal advice.
DU.1Scope and governing instruments
DU.1.1 This profile applies the Origin Evidence File to unmanned aircraft systems and their elements, where procurement, operation or funding of the system is governed by an instrument named in the front matter. The file's owner may be a manufacturer, an integrator, a contractor, a subcontractor or a recipient of federal funds.
DU.1.2 The instruments ask related questions that resolve differently, and a file serves them only by answering each separately:
- where the aircraft and each named element were manufactured, where the ground control system and operating software were developed, and where the responsible entity is domiciled;
- whether the system was manufactured or assembled by an entity on the list the Federal Acquisition Security Council publishes in the System for Award Management;
- whether federal funds awarded through a contract, a grant or a cooperative agreement, or otherwise made available, are used to procure the system or in connection with its operation;
- whether the file's owner operates equipment from a covered unmanned aircraft system company in performing a Department of Defense contract.
DU.1.3 A file assembled under this profile records evidence. It is not a determination that an item may be procured, operated or funded, and it is not a representation or certification made to any agency.
DU.1.4 Where the same items also fall within a Covered List category, one file may serve the Protocol and this profile under P.2.4, and the clause 4.1.3 schedule states per item which sections evidence which regime. A conclusion under one regime does not carry to another.
DU.2The governing tests (informative)
Subsection (a). The Secretary of Defense "may not operate or enter into or renew a contract for the procurement of" (1) "a covered unmanned aircraft system that ... (A) is manufactured in a covered foreign country or by an entity domiciled in a covered foreign country; (B) uses flight controllers, radios, data transmission devices, cameras, or gimbals manufactured in a covered foreign country or by an entity domiciled in a covered foreign country; (C) uses a ground control system or operating software developed in a covered foreign country or by an entity domiciled in a covered foreign country; or (D) uses network connectivity or data storage located in or administered by an entity domiciled in a covered foreign country," or (2) "a system manufactured in a covered foreign country or by an entity domiciled in a covered foreign country for the detection or identification of covered unmanned aircraft systems."
Subsection (b). The Secretary "may not enter into a contract (or extend or renew a contract) on or after October 1, 2024, with an entity that operates (as determined by the Secretary or the Secretary's designee) equipment from a covered unmanned aircraft system company in the performance of a Department of Defense contract."
Subsection (e) definitions. "Covered foreign country" means China, Russia, Iran and North Korea. "Covered unmanned aircraft system" means "an unmanned aircraft system and any related services and equipment." "Covered unmanned aircraft system company" means Da-Jiang Innovations or any subsidiary or affiliate; any entity that produces or provides unmanned aircraft systems and is on the Consolidated Screening List; and any such entity domiciled in a covered foreign country or "subject to unmitigated foreign ownership, control or influence by a covered foreign country, as determined by the Secretary of Defense ... in accordance with the National Industrial Security Program." Subsection (c) exempts stated counter-UAS and intelligence, electronic warfare and information warfare activities. Subsection (d) permits waiver on written certification to the congressional defense committees that the action "is required in the national interest of the United States."
Section 1822(1). "Covered foreign entity" means "an entity included on a list developed and maintained by the Federal Acquisition Security Council and published in the System for Award Management (SAM)." The section then states the categories the list "will include," among them entities on the Consolidated Screening List, entities subject to extrajudicial direction from a foreign government, entities determined to pose a national security risk, entities domiciled in the People's Republic of China or subject to influence or control by its government or by the Chinese Communist Party, and any subsidiary or affiliate of the foregoing. Section 1822(2) takes "covered unmanned aircraft system" from 49 U.S.C. 44801.
Section 1823(a). "The head of an executive agency may not procure any covered unmanned aircraft system that is manufactured or assembled by a covered foreign entity," including associated elements for the collection and transmission of sensitive information, for which the Council maintains a list with the Department of Transportation. Section 1824(a)(1). "Beginning on the date that is two years after the date of the enactment of this Act, no Federal department or agency may operate a covered unmanned aircraft system manufactured or assembled by a covered foreign entity," and (a)(2) extends that to systems used by an executive agency "through the method of contracting for the services" of such systems. Section 1825(a). Beginning on the same date, "no Federal funds awarded through a contract, grant, or cooperative agreement, or otherwise made available may be used ... (1) to procure a covered unmanned aircraft system that is manufactured or assembled by a covered foreign entity; or (2) in connection with the operation" of such a system. Section 1826. "Effective immediately, Government-issued Purchase Cards may not be used to procure any covered unmanned aircraft system from a covered foreign entity."
Section 1832 states exceptions applying to sections 1823, 1824 and 1825 for wildfire management and search and rescue, for intelligence activities under title V of the National Security Act, and for Tribal law enforcement and Tribal emergency service agencies on Indian lands. Section 1825 states further exemptions and an agency-head waiver requiring approval of the Director of the Office of Management and Budget. Section 1833. "Sections 1823, 1824, and 1825 shall cease to have effect on the date that is five years after the date of the enactment of this Act." On the enacted date that is December 22, 2028, the expiry FAR 40.202 prints.
FAR 40.201 defines an American Security Drone Act-covered foreign entity as an entity on the list published in SAM, and takes "unmanned aircraft" and "unmanned aircraft system" from 49 U.S.C. 44801(11) and (12). FAR 40.202-3 carries the three statutory prohibitions and prints December 22, 2025 for the section 1824 and section 1825 limbs. Clause 52.240-1(b) binds the contractor not to deliver a prohibited system, not to operate one after that date, and not to use federal funds for one after that date. Paragraph (c) requires the contractor to search the SAM list before proposing or using any unmanned aircraft system. Paragraph (e) flows the substance of the clause down "in all subcontracts and other contractual instruments, including subcontracts for the acquisition of commercial products or commercial services." FAR 40.202-8 prescribes the clause for all solicitations and contracts.
Subsection (a)(1) directs that "an appropriate national security agency shall determine" whether stated communications or video surveillance equipment or services "pose an unacceptable risk to the national security of the United States or the security and safety of United States persons," reaching equipment produced by Shenzhen Da-Jiang Innovations Sciences and Technologies Company Limited and by Autel Robotics, and, with respect to either, "(i) any subsidiary, affiliate, or partner"; "(ii) any entity in a joint venture"; "(iii) any entity to which the named entity has a technology sharing or licensing agreement"; together with services, including software, provided by such an entity "or using equipment described in such subparagraphs." Subsection (a)(2) provides that if no determination is made within one year of enactment, "the Commission shall add all communications equipment and services listed in paragraph (1) to the covered list."
"Unmanned aircraft" means "an aircraft that is operated without the possibility of direct human intervention from within or on the aircraft." "Unmanned aircraft system" means "an unmanned aircraft and associated elements (including communication links and the components that control the unmanned aircraft) that are required for the operator to operate safely and efficiently in the national airspace system."
DU.3Applicability determination
DU.3.1 The OEF SHALL contain, for each scheduled item, a separate applicability determination for each instrument named in DU.1, made against that instrument's own definitions and not against a paraphrase or against another instrument's definitions. [Section 848, the Act and section 1709 each define their subject differently, and section 1822(1) defines its subject by membership in a published list.]
DU.3.2 Each determination SHALL follow clause 4.2.1 in form, and SHALL additionally record the party the instrument binds and whether the file's owner is that party, supplies that party or receives funds from that party.
DU.3.3 Whether an item is an unmanned aircraft system SHALL be determined against 49 U.S.C. 44801(11) and (12), which FAR 40.201 and section 1822(2) both incorporate, and the determination SHALL identify which associated elements are within the system as so defined. [Section 44801(12) reaches "associated elements (including communication links and the components that control the unmanned aircraft)," so the boundary of the item is itself a recorded conclusion.]
DU.3.4 A determination SHALL NOT rest on the absence of an entity from a published list unless that list was searched and the search recorded under DU.6.
DU.3.5 Where an exception, exemption or waiver is relied on, the file SHALL identify the provision by number, quote it, and cite the document evidencing that it has been granted or that its conditions are met. [Section 1832; the section 1825 exemptions and waiver; section 848(c) and (d).]
DU.3.6 Instruments SHALL be re-retrieved and determinations re-confirmed at each revision date under P.5.1. Where an instrument states a commencement or expiry date, the determination SHALL record it.
DU.4Application of the Origin Evidence File
| Protocol clause | Status | Modification |
|---|---|---|
| Part III, 3.1, 3.2 Conformity levels and currency | Applies as written | Levels 1, 2 and 3 carry their Protocol meanings. |
| 3.3 Quarterly onshoring evidence module | Not applicable | The module attaches to a Conditional Approval condition and applies only where the same file also serves the Protocol for such a model. |
| 4.1 Device identity | Applies as modified | The schedule lists unmanned aircraft systems in scope whether or not they hold an FCC authorization. FCC ID and SDoC fields are completed where they exist and marked not applicable otherwise. Each item carries its DU.7.1 record references. |
| 4.2 Coverage determination | Applies as modified | Read as DU.3. A Covered List coverage determination is required only where the file also serves the Protocol. |
| 4.3 Production provenance | Applies as modified | Site attestations additionally state whether the site manufactures or assembles the item or a named element, per DU.5.5. |
| 4.4.1, 4.4.2 Component origin and design origin | Applies as modified | Extended by the DU.7.2 schedule for the elements the instruments name. |
| 4.4.3, 4.4.4, 4.4.5 Concentration, sole source | Applies as written | None. |
| 4.5 Corporate provenance | Applies as modified | The chain record adds the domicile of each entity, evidenced per DU.5.2. |
| 4.6 Software, firmware and IP provenance | Applies as modified | Extended by DU.5.3 and DU.5.4 for development location and for connectivity and storage administration. |
| 4.7 Evidence quality, translation, retention | Applies as written | DU records and registers are retained on the same terms. |
| 4.8 Attestation | Applies as written | The Annex A attestation covers the DU records as file sections. |
| Annex B.1 | Applies as modified | DU.7.2 adds fields for the named elements; B.1 remains the record for all other lines. |
| Annex B.2, B.3 | Applies as written | None. |
| Annex C | Applies as written | Declarations one tier up are required for every named element present. |
| Annex D, UAS row | Applies as modified | The DU.7.2 schedule adds the named elements the row does not carry, namely ground control system, operating software, network connectivity and data storage. |
| Annex E | Applies as modified | Extended by DU.6. |
| Part V | Applies as modified | The verifier additionally re-performs the DU.6.4 search as of the verification date and reconciles the DU registers to the schedule. Confirmation counts are unchanged, and the selection includes at least one line for each named element class present. |
| Part VI | Applies as modified | Adds the triggers at DU.5.9. P.5.2 supplies the instrument-change trigger. |
| Part VII, P.6 | Applies as modified | Read with DU.8. |
DU.5Additional evidence
DU.5.1 The OEF SHALL contain a critical-component schedule per item, conforming to the DU.7.2 schema, covering each element the instruments name that is present in the design or in the system as delivered. [Section 848(a)(1)(B) to (D) names flight controllers, radios, data transmission devices, cameras, gimbals, ground control system, operating software, network connectivity and data storage. The schedule adopts that list and adds nothing to it.]
DU.5.2 For each scheduled element and for each entity in the clause 4.5 chain, the file SHALL record domicile, meaning the jurisdiction of organization and the principal place of business as evidenced by a registry extract or equivalent official document. Country of manufacture and domicile of the manufacturer are separate facts and SHALL be recorded separately. [Subparagraph (B) reaches an element "manufactured in a covered foreign country or by an entity domiciled in a covered foreign country," in the alternative. The Annex B.1 mfr_country field records a headquarters country, which answers neither limb.]
DU.5.3 For the ground control system and for operating software, the file SHALL record the country in which the software was developed, the developing entity and that entity's domicile. [Subparagraph (C) turns on where software was "developed" and on the developer's domicile. Clause 4.6.3 records country of origin of onboard software, which is a different fact.]
DU.5.4 For each endpoint in the clause 4.6.5 data-flow summary and each repository holding data generated by a scheduled item, the file SHALL record the country in which connectivity or storage is located, the administering entity and that entity's domicile. [Subparagraph (D) reaches connectivity or storage "located in or administered by an entity domiciled in a covered foreign country," so both are recorded.]
DU.5.5 Each site attestation under clause 4.3.3 SHALL state whether the site manufactures or assembles the scheduled item or a named element. [Sections 1823(a), 1824(a)(1) and 1825(a)(1) each reach a system "manufactured or assembled by" a covered foreign entity, so assembly alone is within the test.]
DU.5.6 Where the file's owner holds or seeks federal funds, the file SHALL contain a federal award register conforming to the DU.7.4 schema. [Section 1825 reaches funds "awarded through a contract, grant, or cooperative agreement, or otherwise made available," so the register is not limited to procurement contracts.]
DU.5.7 Where the owner is a contractor subject to FAR 52.240-1, the file SHALL record, for each subcontract and other contractual instrument under which an unmanned aircraft system or named element is acquired, that the substance of the clause was included, with the instrument reference and date. [Paragraph (e) flows the substance down in all subcontracts and other contractual instruments, including those for commercial products or commercial services, and states no exclusion of any paragraph. An exclusion stated in a different clause is not read into this one.]
DU.5.8 Where the owner performs or seeks a Department of Defense contract, the file SHALL contain an operated-fleet register conforming to the DU.7.5 schema. [Subsection (b) conditions eligibility on equipment the entity itself operates, which is a use fact evidenced nowhere else in the file.]
DU.5.9 In addition to the Part VI triggers and P.5.2, each of the following is a material change, re-attested within thirty days: a change in the list searched under DU.6.4 that touches an entity in the file; a new federal award or a change in the funding source for a scheduled item; the grant, expiry, withdrawal or condition failure of a waiver, exemption or exception recorded under DU.3.5; and a change in the equipment recorded in the DU.7.5 register.
DU.6Entity screen
DU.6.1 The Annex E procedure applies. The screen list SHALL additionally include the manufacturer and assembler of each scheduled item and named element, the developer of the ground control system and operating software, and each administering entity recorded under DU.5.4.
DU.6.2 Each listed entity SHALL be screened separately against each of: (a) the list maintained by the Federal Acquisition Security Council and published in the System for Award Management, searched directly; (b) the section 848(e) definition of a covered unmanned aircraft system company, including its Consolidated Screening List limb and its domicile limb; and (c) the relationships section 1709(a)(1)(C) describes, namely subsidiary, affiliate, partner, joint venture, and technology sharing or licensing agreement with an entity named in section 1709(a)(1)(A) or (B). Results SHALL be recorded per screen and not merged. [Each instrument defines its own subject, and a clear result under one is not a result under another.]
DU.6.3 For the manufacturer and for each supplier of a named element, the file SHALL state whether it holds any technology sharing or licensing agreement with an entity named in section 1709(a)(1)(A) or (B), and SHALL identify any such agreement by counterparty and date. A statement that none exists SHALL be made expressly, not by omission. [Subparagraph (a)(1)(C)(iii) reaches an entity by the existence of such an agreement.]
DU.6.4 The search under DU.6.2(a) SHALL record the date searched and the publication or revision date of the list as searched. It SHALL be re-run at each revision date, on any material change under Part VI, P.5.2 or DU.5.9, and, for a party bound by FAR 52.240-1, before each offer and before first operational use of an item. [Paragraph (c) of the clause requires a search of the list before proposing or using any unmanned aircraft system.] The screen is otherwise current for twelve months per Annex E.
DU.6.5 The file SHALL record the result of the search performed, and SHALL NOT state that an entity is or is not a covered foreign entity other than by reference to the list as searched on a stated date. [Section 1822(1) defines the term by membership in a published list, so the question is list membership at a point in time rather than one the file can answer from an entity's characteristics.]
DU.6.6 Section 1709 imposes no obligation on any company by its own terms. A screen under DU.6.2(c) records a relationship, and SHALL NOT be recorded as a conclusion about any listing, authorization or procurement outcome.
DU.6.7 A match or possible match on any screen halts reliance on the file pending resolution, documented with its basis, per Annex E.
DU.7Records and schemas
DU.7.1 Instrument applicability record
One record per scheduled item per instrument.
| Field | Definition | Rules |
|---|---|---|
| item_ref | The scheduled item the determination covers | Must appear in the clause 4.1 schedule |
| instrument | The instrument determined against | One of the instruments named in the front matter |
| instrument_version | Version, public law citation or edition applied | With retrieval date; re-retrieved at each revision date |
| binding_party | The party the instrument binds | Stated as in the instrument, not as the owner's role |
| owner_relation | The file owner's relation to that party | Is the party / supplies the party / receives funds from the party / none |
| definition_doc_id | Document ID of the quoted definition text applied | Quotation retained in the file |
| analysis_doc_ids | Document IDs evidencing each factual element | One or more per criterion |
| conclusion | The determination reached | Within scope / outside scope / not applicable, with the element or exception relied on |
| exception_ref | Provision number and evidencing document for any exception, exemption or waiver relied on | Required when the conclusion rests on one |
| preparer, determination_date | Preparer and date | Determination date within twelve months of the revision date |
DU.7.2 Critical-component schedule
One record per named element present, per scheduled item.
| Field | Definition | Rules |
|---|---|---|
| item_ref | The scheduled item | Must appear in the clause 4.1 schedule |
| named_element | The element as the instrument names it | One of: flight_controller, radio, data_transmission_device, camera, gimbal, ground_control_system, operating_software, network_connectivity, data_storage |
| bom_line_ref | The Annex B.1 line, where the element is a BOM line | Required for hardware elements; not applicable for the software and service elements |
| manufacture_country | Country in which the element was manufactured | ISO 3166 alpha-2; hardware elements only |
| development_country | Country in which the element was developed | ISO 3166 alpha-2; required for ground_control_system and operating_software |
| hosting_country | Country in which connectivity or storage is located | ISO 3166 alpha-2; required for network_connectivity and data_storage |
| responsible_entity | Legal name of the manufacturer, developer or administrator, as applicable | Not the distributor or reseller |
| entity_domicile | Jurisdiction of organization and principal place of business of that entity | Evidenced per DU.5.2; recorded separately from manufacture_country |
| declaration_ref | Identifier of the Annex C declaration on file | Required for every hardware named element |
| evidence_doc_ids | Document IDs evidencing development or hosting location and administration | Required where no Annex C declaration covers the element |
| verified_date | Date the entries were last confirmed | Within twelve months of the revision date |
DU.7.3 Screen result fields
Recorded with each Annex E screen record, one per entity per screen.
| Field | Definition | Rules |
|---|---|---|
| screen_basis | The screen performed | One of: fasc_sam_list, s848_company, s1709_relationship, sanctions_supplementary |
| source_reference | The list or definition text searched or applied | With its publication or revision date |
| search_date | Date the search or application was performed | Currency per DU.6.4 |
| result | Outcome | Clear / match / possible match, recorded per screen and not merged across screens |
| relationship_detail | For s1709_relationship, the relationship found or expressly absent | Counterparty and date where an agreement exists |
| reviewer, resolution_ref | Reviewer, and document ID resolving any match or possible match | Resolution required before reliance resumes |
DU.7.4 Federal award register
One record per federal award under which a scheduled item is procured or operated.
| Field | Definition | Rules |
|---|---|---|
| award_id | Award or contract identifier | As issued by the awarding agency |
| awarding_agency | Agency making the award | Legal name |
| instrument_type | Form of the award | Contract / grant / cooperative agreement / other federal funds made available |
| clause_present | Whether FAR 52.240-1 is included in the instrument | Y / N / not applicable, with the clause date where present |
| period | Period of performance or availability of funds | Start and end dates |
| items_procured | Scheduled items procured with funds under the award | item_ref values, or none |
| operation_funded | Whether funds are used in connection with the operation of a scheduled item | Y / N, with the evidencing document ID |
| exception_ref | Exception, exemption or waiver relied on | DU.7.1 exception_ref where one is claimed |
DU.7.5 Operated-fleet register
One record per item of equipment operated in the performance of a Department of Defense contract.
| Field | Definition | Rules |
|---|---|---|
| fleet_ref | Internal identifier of the operated item | Unique within the file |
| make_model | Make and model as marked | Plain text |
| operating_entity | Entity that operates the item | Legal name and domicile |
| contract_ref | The Department of Defense contract in whose performance it is operated | Award identifier |
| in_performance | Whether the item is operated in the performance of that contract | Y / N, with the evidencing document ID |
| screen_ref | The DU.7.3 screen record for the item's producer or provider | Screen basis s848_company required |
| last_reviewed | Date the entry was last reviewed | At each revision date, and on any DU.5.9 trigger |
DU.8Claims of conformity
DU.8.1 P.6 applies, with "Profile DU" as the designation named in the claim.
DU.8.2 A claim is a statement about the file. It is not a determination that an item may be procured, operated or funded under any instrument named in DU.1, not a representation or certification to any agency, and not a legal opinion.
DU.8.3 A claim SHALL NOT state or imply that any government body has reviewed, accepted or endorsed the file, that the file bears on inclusion in or exclusion from any government list, or that conformity leads to, anticipates or substitutes for such inclusion.
DU.8.4 Where a file supports a representation or certification its owner makes in a federal solicitation or award, that representation remains the owner's, made under the terms of the instrument requiring it.
DU.9Limits of this profile, and questions for comment
DU.9.1 This profile sets no threshold. Every country designation, entity category, percentage and date is incorporated from the instrument as in force on the file's revision date, under P.2.2.
DU.9.2 The contents of the list published in the System for Award Management are not reproduced or characterized here, and this profile states nothing about whether any entity appears on it. A recorded search under DU.6 is the only form in which a file answers that question.
DU.9.3 The following are outside what this profile establishes, and a file SHALL NOT rest on any of them: whether implementing policy and an appeal process issued under Pub. L. 117-263 section 817(b); whether any uniform guidance provision implements section 1825; and whether waivers granted under section 1825 are published.
DU.9.4 The Federal Communications Commission's Covered List entry for unmanned aircraft systems excepts, until January 1, 2028, systems on the Blue UAS Cleared List (National Security Determination as superseded July 21, 2026, DA 26-761). What such a listing establishes under the instruments named in DU.1 is not established here. This profile makes no statement about the Blue UAS Cleared List or any other qualification program, and conformity is not a substitute for any of them.
DU.9.5 Comment is invited through October 31, 2026 on the following:
- Should DU.7.2 record entity domicile for every bill-of-materials line, or only for the elements section 848 names?
- Is a search fixed before each offer and before first operational use the right point at which to record a list search in the file, and how should the search be evidenced when the searching party is a subcontractor rather than the prime?
- Where funds arrive through a grant or cooperative agreement rather than a contract, what evidence shows that funds were not used in connection with the operation of a scheduled item, given that operation is continuing and procurement is an event?
- Should the expiry the Act states for its own authorities be a revision trigger in its own right, rather than a date recorded under DU.3.6?
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