RAND researchers examined current and potential export control regulations on artificial intelligence and uncrewed aircraft systems; analyzed how current regulations are effective, inadequate, or even detrimental; and assessed how the United States might create a system of export controls that balances competition with China and securely guided proliferation of these technologies.

Export Controls on Artificial Intelligence and Uncrewed Aircraft Systems

Interagency Challenges

Will Shumate, David Luckey, Timothy Marler, Monika Cooper, Christopher Scott Adams, Julia Arnold, Clay Strickland, Jacqueline Gardner Burns

ResearchPublished Feb 17, 2026

China and the United States are developing technology for both artificial intelligence (AI) and uncrewed aircraft systems (UASs). Both countries will be able to fill the demand in other countries for these systems. AI and UAS technologies, particularly those with dual uses, are advancing with increasing speed, but export controls lag. This deficiency in regulations can stifle appropriate national security, industry autonomy—and thus technological advances—and coordinated integration of the two technologies. In this report, authors review current export control systems for AI and UASs, examine their effectiveness, and consider how the United States could form a balanced system of export controls for AI and UASs. The report focuses on dual-use technologies. It covers the Export Administration Regulations, the International Traffic in Arms Regulations, and the interagency process.

For this report, the authors examined the current and potential future states of export control regulations on AI and UAS technologies; analyzed how current regulations are effective, inadequate, or even detrimental; and assessed how insights on AI and UAS export controls might be applicable to creating a system of export controls for AI and UASs that balances competition with China and securely guided proliferation of AI and UAS technologies.

Key Findings

  • The U.S. defense industrial base lacks a significant technology edge over adversaries’ counterparts in AI and UASs.
  • Overregulation of these technologies could dampen domestic competitiveness, accelerate advances abroad, and create security risks.
  • Export controls can either strengthen or deplete the U.S. lead in these technologies.
  • Export controls could be evaluated more regularly.
  • The need for efficiency and adaptiveness is increasing.
  • Regulating military training data is crucial. The U.S. Department of Commerce (DOC), U.S. Department of Defense (DoD), and U.S. Department of State (DOS) would need to determine what makes data military training data.

Recommendations

  • DoD should find ways to further develop innovation leadership with research and development for AI and UASs.
  • The Defense Technology Security Administration (DTSA) should work more in depth with the AI industry to increase understanding of the infrastructure and ecosystem related to AI.
  • DTSA and DOC should conduct more-proactive analysis to identify and assess potential security risks associated with technological advancements.
  • The U.S. government needs to develop a more flexible and responsive regulatory framework for adaptive policymaking.
  • DOC should lead an effort with DOS and DoD to explore methods and procedure for more systematically tracking the effects and effectiveness of export regulations as perceived by each department.
  • DOC, DoD, and DOS should expand interagency efforts at technology assessments and forecasting to consider the intersection of emerging technologies and decrease stovepiping of relevant areas of expertise.

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Shumate, Will, David Luckey, Timothy Marler, Monika Cooper, Christopher Scott Adams, Julia Arnold, Clay Strickland, and Jacqueline Gardner Burns, Export Controls on Artificial Intelligence and Uncrewed Aircraft Systems: Interagency Challenges. Santa Monica, CA: RAND Corporation, 2026. https://www.rand.org/pubs/research_reports/RRA3296-1.html.
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This research was conducted within the Acquisition and Technology Policy Program of the RAND National Security Research Division.

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