Larsen Examines FCC Grandfathering Challenges for Foreign-Produced AI Robotics in Corporate Compliance Insights

09.21.2026

Stinson LLP Partner Kim Larsen authored an article in Corporate Compliance Insights examining the limitations of the Federal Communications Commission's grandfathering protections for foreign-produced AI-enabled robotic devices and the compliance challenges companies may face as these technologies continue to evolve.

Larsen explains that while existing devices with FCC Part 15 authorizations may continue to be marketed under the FCC's new Covered List restrictions, the grandfathering framework can constrain companies' ability to update and improve those products. He examines how the FCC's equipment authorization rules, which were designed primarily to address electromagnetic interference, are now being applied to address broader national security concerns involving AI-enabled robotics.

The article also explores the challenges posed by AI systems that can evolve through cloud-based software, third-party services and continuously updated models. Larsen notes that these technologies do not always fit neatly within a regulatory framework built around discrete software and firm updates, creating uncertainty for companies seeking to determine whether changes to their products fall within the FCC's limited exceptions.

Larsen advises companies to evaluate their AI architecture and data flows against the FCC's regulatory requirements and assess software changes for both their technical effects and whether they qualify under the applicable grandfathering provisions. He also identifies domestic content compliance as a more durable strategy for companies seeking to avoid the Covered List restrictions.

"Grandfathering is a bridge, not a destination," Larsen writes, emphasizing that companies should view existing protections as a temporary measure while developing longer-term compliance strategies.

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 Corporate Compliance Insights.