Although the threat of drone use by domestic extremist actors is growing, countries still have an opportunity to act and minimise vulnerabilities. The key elements of that action should be to: (1) establish national counter-drone coordination units whose primary goal is the oversight of domestic counter systems; (2) harmonise and coordinate safety-by-design regulations to achieve international consistency; and (3) formulate and implement specific policies and interventions to address the threat posed by additive manufacturing. These recommendations are designed to be country agnostic while highlighting the need for international engagement and coordination among partner countries.
Current national counter-drone responses tend to fall awkwardly between multiple agencies with unclear authority hierarchies and no single point of coordination. To begin to address the challenge of domestic extremist and malign actor use of drones, jurisdictions should establish dedicated national counter-drone coordination units, operating as joint task forces, responsible for testing, standardising, and evaluating domestic counter-drone tactics within legal and ethical constraints. The task forces would comprehensively bring together law enforcement operational expertise, aviation regulatory authority, and intelligence service threat assessment capabilities.
The United States has recently established such a coordination unit, the Joint Interagency Task Force 401, which spearheads the acquisition and integration of air defence systems aimed at taking down small uncrewed aerial systems. [60] Similar coordination units could be established to ensure the efficacy of country-specific counter-drone strategies and platforms.
These units would be responsible for evaluating counter-drone technologies suitable for civilian environments. Military counter-drone systems rely heavily on kinetic interdiction or broad-spectrum jamming that create unacceptable risks in populated areas outside conflict zones. Domestic settings require different approaches. Domestic counter-drone defence requires iterative testing and regular recalibration as both commercial platforms and additive and modification techniques from areas such as 3D printing and AI evolve. The coordination unit would establish testing protocols that evaluate each technology against effectiveness in real-world conditions and work to match those capabilities against known and likely future threats.
National coordination units will be most effective when supported by broader international cooperation. Each country operates under its own distinct regulatory framework; what is legally permissible in one may violate the law in another, forcing nations to develop capabilities in isolation. However, international knowledge sharing can enable countries to identify solutions compatible with their own regulatory constraints while benefiting from collective learning without requiring regulatory harmonisation.
Governments should also focus on preventive approaches that mandate embedded safety features directly into drone design and production. If geofencing and remote identification become standard across legitimate drone operations, unauthorised activity becomes more visible. By making hobbyist and commercial drones easier to identify, and barring them from sensitive areas, authorities will be able to more rapidly distinguish inadvertent disruptions from nefarious threats. Security personnel can treat unidentified drones operating near sensitive sites as potentially hostile rather than spending time sorting genuine threats from casual rule violations.
Regulatory compliance should be a condition of market access, enforced through government verification rather than manufacturer cooperation. This requires prohibiting the import and sale of drones lacking functional safety features, treating non-compliant equipment as contraband at customs, and imposing substantial penalties on distributors selling uncertified products.
Several countries have pursued such a regulatory approach. The United States now requires most registered drones to broadcast Remote ID signals that transmit identifying and location data during flight, while the European Union introduced mandatory remote identification for many drones in 2024 and enforces geofenced airspace restrictions around sensitive locations. Japan similarly mandates remote identification for drones over 100 grams.
However, this approach only succeeds through international coordination among major markets. If countries establish common technical standards and mutual recognition of certification, manufacturers face genuine pressure to comply or forfeit market access. Without coordination, manufacturers optimise for the least restrictive market and circumvent stricter jurisdictions through e-commerce. The international cooperation framework should therefore include common drone certification standards as a central pillar, transforming fragmented national regulations into unified requirements. There will be challenges including enforcement costs for customs inspection and market surveillance, and political obstacles to achieving genuine regulatory harmonisation rather than lowest-common-denominator standards.
DJI’s dominance, and its recent shift from manufacturer-reliant to user-reliant safety compliance represents a substantial hurdle to an integrated and robust safety-by-design framework. However, this is precisely why an internationally coordinated regulatory approach is needed. If major markets such as the United States and the European Union, and smaller markets like Australia and Japan, adopt common certification standards, manufacturers will face strong commercial incentives to comply despite regulatory divergence in their home markets.
Similar dynamics are already visible in other areas. Australia’s recently enacted regulation of social media use places responsibility on platforms to implement age assurance measures as a condition of operating within the Australian market, regardless of where those platforms are headquartered. A comparable logic can underpin safety-by-design drone regulation. Even when major manufacturers based outside participating jurisdictions do not adopt safety-by-design features, regulatory obligations will require them to comply with certification rules if they wish to sell products in those jurisdictions.
Even the most comprehensive safety-by-design frameworks cannot account for the growing threat posed by additive technology. While the additive ecosystem includes several threats, the ease of access to 3D printing for domestic malign actors is particularly concerning. Similar challenges have been highlighted in the space of 3D-printed firearms, where so-called “ghost guns” have provided malicious actors with untraceable weapons that circumvent black-market supply chains. [61] Here, several countries, including Australia and the United Kingdom, have responded by criminalising the manufacture and possession of both the products and their digital blueprints. [62]
However, unlike firearms, which are already heavily restricted in most countries, many 3D-printed drone components serve legitimate recreational and commercial purposes. Over-regulation risks alienating hobbyists and stifling innovation. Rather than sweeping restrictions, policymakers should pursue a more targeted response.
A database of prohibited 3D-printed drone component schematics should be established, regularly updated, and accessible to partner states through existing counter-terrorism cooperation frameworks. Establishing such a database would contribute to internationally coordinated prevention efforts focused on this narrow class of schematics. It would also avoid fragmented national efforts and mitigate the risk of over-regulation.
By establishing this shared list of prohibited blueprints, countries can work with file-sharing platforms and printer manufacturers to target restrictions. AI algorithms can now detect prohibited design files and block their production. Multiple systems have been developed to detect 3D-printed guns. Print&Go's “3D GUN’T” uses AI-driven filters embedded in printer firmware to help prevent manufacture of restricted items. [63] Following US government pressure, Thingiverse, the world's largest platform for 3D printing files, implemented AI-powered detection that scans uploads to flag and remove prohibited designs. [64] These interventions occur at multiple points in the process, including on file-sharing platforms, in slicer software that prepares models for printing, and in printer firmware itself.
The effectiveness of such a framework relies on widespread industry participation. Printer manufacturers unwilling to implement detection systems or embed identifying protocols would face market access restrictions in participating countries, similar to the internationally coordinated manufacturer enforcement approaches suggested above for commercial off-the-shelf drones.
