In introducing the American Security Robotics Act of 2026, Senators Tom Cotton (R-AR) and Chuck Schumer (D-NY) have extended a now familiar congressional playbook into a new and consequential domain:  robotics.  The bill would prohibit executive agencies from procuring or operating unmanned ground vehicle systems (UGVs) manufactured or assembled by “covered foreign entities,” a term that targets companies tied to adversarial nations such as China.

The legislation also reflects early signs of bicameral alignment.  Representative Elise Stefanik (R-NY-21) has introduced companion legislation in the House, signaling that concerns regarding robotics systems manufactured by certain foreign entities are not confined to a single chamber or party.

At one level, the proposal is straightforward.  At another, it reflects a maturing legislative architecture that has evolved across successive National Defense Authorization Acts (NDAAs) and related statutes—an architecture that is increasingly product-specific, attentive to supply chain risk, and focused on issues of data access, operational control, and systemic vulnerability.

From Networks to Nodes to Machines

Congress’s earliest modern forays into technology-focused procurement prohibitions—most notably Section 889 of the FY 2019 NDAA—focused on telecommunications infrastructure.  Section 889 prohibited the federal government from procuring or using certain telecommunications equipment and services from named Chinese companies and, critically, extended that prohibition to contractors that use such equipment anywhere in their systems.

Section 889 reflected concerns about network infiltration—the risk that adversarial telecommunications infrastructure could permit data exfiltration and enable persistent surveillance or operational disruption.

Subsequent provisions expanded in both scope and sophistication.  Section 5949 of the FY 2023 NDAA, for example, shifted focus to semiconductors and microelectronics targeting a different layer of the technology stack while reflecting the same core concern:  supply chain dependency, particularly control over the sourcing of key inputs to advanced computing systems, as a national security risk.

The American Security Robotics Act represents the next logical step.  It shifts the focus from infrastructure and components to autonomous, data-generating, physically active systems.  These are not passive nodes in a network; they are actors in the physical world—robots capable of movement, sensing, and in some cases, decisionmaking.

Core Prohibitions:  A Familiar Structure, Applied to a New Domain

The bill adopts a structure that will be immediately recognizable to practitioners familiar with Section 889 and its progeny.

First, the statutory definition is precise in design, but broad in reach.  In traditional defense parlance, a UGV refers to a ground-based robotic platform:  typically, bomb disposal robots and small tracked reconnaissance systems.  The Act’s scope is more expansive, however.  It encompasses any mechanical device capable of locomotion on the ground, whether remotely operated or autonomous, and expressly includes remote surveillance vehicles, autonomous patrol technologies, “mobile robotics,” and even humanoid robots.  Yet the result is not a vague or overinclusive category, but a deliberately constructed legislative umbrella designed to capture a wide and evolving segment of modern robotics.

Further, the definition is explicitly systems‑oriented.  A “covered unmanned ground vehicle system” encompasses not only the robotic platform itself, but also its payload and any external control devices.  This reflects an understanding that risk does not reside solely in the robot’s physical chassis, but in the broader ecosystem of sensors, controllers, and data pathways that enable its operation—and that make these systems both valuable and potentially vulnerable to adversarial control or exploitation.

Second, it establishes a three-part prohibition:

  • A ban on procurement of covered systems;
  • A ban on the operation of such systems, taking effect one year after enactment; and
  • A funding restriction preventing the use of federal funds—whether through contracts, grants, or cooperative agreements—to procure or operate them.

Third, the Act extends its reach to contracted services, ensuring that agencies cannot circumvent the prohibition by outsourcing robotic capabilities. 

Key Distinction:  The Physicality of Risk

What distinguishes the Robotics Act from earlier prohibitions is the physical dimension of the risk it addresses.

Telecommunications equipment and semiconductors raise concerns about data exfiltration and system integrity.  Robotics raises those concerns—but adds another layer:  kinetic consequence.

An unmanned ground vehicle deployed by a federal agency—whether for law enforcement, infrastructure inspection, or logistics—does not merely process data.  It acts in the physical world.  If compromised by an adversary, it could be redirected, disabled, or manipulated in ways that have immediate and tangible consequences.

Congress appears to be responding to this shift by treating robotics not simply as another IT category, but as a hybrid domain—one that combines software‑enabled vulnerabilities with real world operational and physical risk.

Exemptions:  Narrow and Operationally Driven

Like its predecessors, the bill includes exemptions—but they are carefully cabined. 

Agencies such as the Departments of War, Homeland Security, Justice, and State may procure or operate covered robotics systems for specified purposes, including testing, evaluation, counterintelligence, and law enforcement activities.  Alternatively, an exemption may apply where the system has been modified such that it can no longer transfer data to or download data from a covered foreign entity and poses no cybersecurity risk.

These exemptions reflect two realities.  First, exposure is sometimes necessary to counter risk; agencies must be able to study adversary systems and develop countermeasures.  Second, Congress is increasingly willing to allow risk mitigation through technical controls, provided those controls are deemed sufficient through an agency head‑level determination.

Executive Branch Alignment:  Robotics as Industrial Policy

The Robotics Act also arrives at a moment when the Trump Administration has begun to treat robotics not merely as a niche capability, but as a core element of industrial policy and national security competition.  Recent Department of War initiatives—particularly those focused on autonomous, AI‑enabled systems operating across multiple domains—reflect a concerted push to accelerate domestic robotics innovation and deployment.

In that context, the Cotton–Schumer proposal can be understood as the supply side complement to an increasingly assertive demand signal.  While the Administration works to expand U.S. capacity and adoption of advanced robotics, Congress is moving to exclude adversary-linked platforms from the federal ecosystem altogether.  The two approaches are mutually reinforcing. By narrowing the field of eligible suppliers, Congress effectively channels federal demand toward trusted or domestic providers, amplifying industrial base objectives.  At the same time, this alignment may create near-term friction—particularly for research institutions and agencies that have relied on lower cost foreign platforms—but, over time, it is likely to accelerate the development of a more secure and self sufficient U.S. robotics sector.

At the same time, these restrictions will operate within a broader foreign policy context in which the Executive Branch may seek to stabilize bilateral engagement with China.  Measures that further narrow market access for Chinese‑manufactured technologies can complicate diplomatic signaling and invite reciprocal responses, even where the underlying national security rationale is compelling.  Accordingly, the bill’s practical effect may depend as much on coordinated implementation and clear messaging as on the formal scope of the prohibition—ensuring that risk‑based protections for sensitive systems are understood as targeted safeguards rather than a general escalation in economic confrontation.

A Likely Vehicle:  The FY 2027 NDAA

If history is a guide, this measure is far more likely to be enacted as part of a broader legislative package than as a standalone bill.  The NDAA for FY 2027 presents the most plausible vehicle for enactment.  Congress has repeatedly used the NDAA to advance product-specific procurement bans—including Section 889 and subsequent Section 5949 semiconductor and supply chain restrictions.  The NDAA’s near guaranteed annual passage provides a reliable pathway for bipartisan measures that might otherwise struggle to advance independently.

As a threshold matter, a provision limited in application to the Department of War would fall squarely within the core jurisdiction of the Armed Services Committees.  Framed in that manner, the subject matter would align cleanly with the NDAA’s traditional focus on defense organization, capabilities, and risk management within the defense enterprise.

Even were the prohibition to retain its current, Executive Branch‑wide application, it would not necessarily fall outside the permissible scope of the NDAA.  Where such a provision is introduced after the NDAA is reported to the floor, and where the committees of jurisdiction outside Armed Services concur, the measure remains procedurally viable as part of the NDAA package, rather than requiring freestanding authorization.

Moreover, the NDAA conference process offers a structured forum to refine the bill and integrate it into a broader strategic framework addressing autonomy, artificial intelligence, and supply chain security.  Particularly if the Administration continues to elevate robotics as a national priority, this provision could emerge in conference not merely as a restriction, but as part of a comprehensive legislative approach to robotics and autonomous systems.

A Broader Legislative Trend:  Toward Product-Specific Decoupling

Taken together with Section 889, Section 5949, and related provisions—including those tied to the Section 1260H list and associated procurement restrictions—the Robotics Act reinforces a broader trend:  the gradual construction of a product-specific decoupling regime.

Rather than imposing sweeping, economy-wide restrictions, Congress has opted for a targeted approach, identifying specific categories of technology and imposing tailored prohibitions that reflect their unique risk profiles.  This approach allows for iterative policymaking and facilitates bipartisan consensus, but it also creates an increasingly complex compliance environment for federal agencies and contractors alike.

Implications for Government and Industry

For agencies, implementation will require inventory, assessment, and transition planning.  The one‑year delay on the prohibition on operating such systems provides some runway, but experience suggests that compliance will demand significant effort and coordination.

For contractors, the Robotics Act—if enacted—would likely have implications extending beyond federal procurement.  The combination of procurement bans and funding restrictions could create de facto market barriers, particularly for firms reliant on federal customers or federally funded research.

More broadly, the Act signals where Congress is headed.  Robotics is unlikely to be the final frontier.  As emerging technologies continue to blur the boundary between digital and physical systems, Congress appears poised to extend this model further.

Photo of Christopher Adams Christopher Adams

Christopher Adams leads the firm’s China-related public policy, international trade, and geopolitical risk work. A non-lawyer, Chris served as the Senior Coordinator for China Affairs at the Treasury Department. He coordinated China policy issues across the U.S. government, led negotiations with China on…

Christopher Adams leads the firm’s China-related public policy, international trade, and geopolitical risk work. A non-lawyer, Chris served as the Senior Coordinator for China Affairs at the Treasury Department. He coordinated China policy issues across the U.S. government, led negotiations with China on a broad range of trade and investment issues, managed the highest level U.S.-China economic policy dialogues for the Obama and first Trump administrations, and advised the Treasury Secretary and other cabinet officials.

Chris helped develop and implement U.S. trade policy toward China and the broader Asia region with the Office of the United States Trade Representative (USTR) from 2007 to 2015 as Deputy Assistant U.S. Trade Representative for China Affairs, Senior Policy Advisor to the Deputy USTR, and Minister Counselor for Trade Affairs at the U.S. Embassy in Beijing, USTR’s first representative in China.

Chris directed government affairs, public relations, and corporate marketing in China for the Eastman Kodak Company from 2001 to 2006 as Chief Representative for China; Vice President, North Asia Region; and Director, Olympic Programs. During this time, Chris was elected to four consecutive terms as a Governor of the American Chamber of Commerce in China and served on the Chamber’s Public Policy Development Committee.’

Chris assisted companies with market access issues as a commercial officer in the U.S. Foreign Commercial Service in Beijing and Taipei, from 1993 to 2001. Before joining the Commerce Department, Chris managed media relations and information programs with the American Institute in Taiwan and directed business advisory services at a private trade association in Washington, DC.

Photo of Stephen Rademaker Stephen Rademaker

With wide-ranging experience working on national security issues in the White House, the State Department, and the U.S. Senate and House of Representatives, Stephen Rademaker helps clients navigate international policy, sanctions, and CFIUS challenges.

Among his accomplishments in public service, Stephen had lead…

With wide-ranging experience working on national security issues in the White House, the State Department, and the U.S. Senate and House of Representatives, Stephen Rademaker helps clients navigate international policy, sanctions, and CFIUS challenges.

Among his accomplishments in public service, Stephen had lead responsibility, as a U.S. House staffer, for drafting the legislation that created the U.S. Department of Homeland Security. Serving as an Assistant Secretary of State from 2002 through 2006, he headed at various times three bureaus of the State Department, including the Bureau of Arms Control and the Bureau of International Security and Nonproliferation. He directed the Proliferation Security Initiative, as well as nonproliferation policy toward Iran and North Korea, and led strategic dialogues with Russia, China, India, and Pakistan. He also headed U.S. delegations to numerous international conferences, including the 2005 Review Conference of the Parties to the Treaty on the Nonproliferation of Nuclear Weapons.

Stephen concluded his government career on Capitol Hill in 2007, serving as Senior Counsel and Policy Director for National Security Affairs for then-Senate Majority Leader Bill Frist (R-TN). In this role, he helped manage all aspects of the legislative process relating to foreign policy, defense, intelligence and national security. He earlier served as Chief Counsel for the House Select Committee on Homeland Security of the U.S. House of Representatives and as Deputy Staff Director and Chief Counsel of the House Committee on International Relations.

During President George H. W. Bush’s administration, Stephen served as General Counsel of the Peace Corps, Associate Counsel to the President in the Office of White House Counsel, and as Deputy Legal Adviser to the National Security Council. After leaving government in 2007, he continued to serve as the U.S. representative on the United Nations Secretary-General’s Advisory Board on Disarmament Matters, and he was subsequently appointed by House Republican Leader John Boehner (R-OH) to the U.S. Commission on the Prevention of Weapons of Mass Destruction Proliferation and Terrorism.

In addition to his practice at Covington, Stephen is an adjunct assistant professor at Georgetown University, where he teaches a course on Sanctions in U.S. Foreign Policy in the Security Studies Program of the School of Foreign Service.

Photo of Stephanie Barna Stephanie Barna

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior…

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior leader on Capitol Hill and in the U.S. Department of Defense (DoD). Most recently, she was General Counsel of the Senate Armed Services Committee, where she was responsible for the annual $740 billion National Defense Authorization Act (NDAA). Additionally, she managed the Senate confirmation of three- and four-star military officers and civilians nominated by the President for appointment to senior political positions in DoD and the Department of Energy’s national security nuclear enterprise, and was the Committee’s lead for investigations.

Previously, as a senior executive in the Office of the Army General Counsel, Stephanie served as a legal advisor to three Army Secretaries. In 2014, Secretary of Defense Chuck Hagel appointed her to be the Principal Deputy Assistant Secretary of Defense for Manpower and Reserve Affairs. In that role, she was a principal advisor to the Secretary of Defense on all matters relating to civilian and military personnel, reserve integration, military community and family policy, and Total Force manpower and resources. Stephanie was later appointed by Secretary of Defense Jim Mattis to perform the duties of the Under Secretary of Defense for Personnel and Readiness, responsible for programs and funding of more than $35 billion.

Stephanie was also previously the Deputy General Counsel for Operations and Personnel in the Office of the Army General Counsel. She led a team of senior lawyers in resolving the full spectrum of issues arising from Army wartime operations and the life cycle of Army military and civilian personnel. Stephanie was also a personal advisor to the Army Secretary on his institutional reorganization and business transformation initiatives and acted for the Secretary in investigating irregularities in fielding of the Multiple Launch Rocket System and classified contracts. She also played a key role in a number of high-profile personnel investigations, including the WikiLeaks breach. Prior to her appointment as Deputy, she was Associate Deputy General Counsel (Operations and Personnel) and Acting Deputy General Counsel.

Stephanie is a retired Colonel in the U.S. Army and served in the U.S. Army Judge Advocate General’s Corps as an Assistant to the General Counsel, Office of the Army General Counsel; Deputy Staff Judge Advocate, U.S. Army Special Forces Command (Airborne); Special Assistant to the Assistant Secretary of the Army (Manpower & Reserve Affairs); and General Law Attorney, Administrative Law Division.

Stephanie was selected by the National Academy of Public Administration for inclusion in its 2022 Class of Academy Fellows, in recognition of her years of public administration service and expertise.