Kim Larsen Outlines FCC Robotics Restrictions and Compliance Considerations in Law360

09.28.2026

Stinson LLP Partner Kim Larsen authored a Law360 article examining the Federal Communications Commission's new restrictions on foreign-produced advanced robotic devices and the practical compliance and transactional considerations for manufacturers, distributors, technology companies and other businesses affected by the rules.

Larsen explains that the FCC's July 28, 2026, addition of foreign-produced advanced robotic devices to its Covered List has implications beyond companies that traditionally view themselves as subject to FCC regulation. Manufacturers and sellers of covered devices face restrictions on obtaining new equipment authorizations, while companies with previously authorized products must navigate limitations on subsequent software and firmware updates.

The article outlines several areas where the new restrictions may affect business relationships and transactions. Larsen discusses the importance of reviewing Covered List status during M&A due diligence, as well as addressing regulatory risk in supply and distribution agreements, IP licenses and contracts involving third-party AI and cloud services. He also highlights the need for companies to understand how changes to AI models and software may affect the regulatory status of connected robotic devices.

Larsen also examines the Conditional Approval pathway available for certain covered devices and explains why companies should evaluate domestic content compliance as a potential longer-term strategy. He notes that the process requires detailed disclosures regarding corporate ownership, component origins, software provenance and plans to increase domestic production, making early planning important for manufacturers that may need to pursue approval.

"Regardless of practice area, lawyers encountering clients that manufacture, import, distribute, or sell connected mobile hardware should be raising key questions," Larsen writes. He identifies several considerations for counsel, including whether products meet the FCC's definition of an advanced robotic device, the percentage of domestic component costs, reliance on continuous AI updates, and whether existing agreements appropriately allocate Covered List risk.

Larsen has over three decades of experience advising businesses on a range of complex corporate matters, including domestic and international mergers and acquisitions, joint ventures, IPOs and commercial transactions. He is a trusted adviser to businesses of all sizes, including emerging companies and small and medium-sized corporations.

To read the full article, visit Law360.