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Authority Is Not Enough

Implementing Australia’s Domestic Counter-UAS Mission

Uncrewed aerial systems (UAS) have become a defining feature of modern conflict. From Ukraine to the Middle East, their growing effectiveness has transformed reconnaissance, strike and air defence operations. Less visibly, however, these systems are also creating new national security challenges in domestic settings. Around the world, UAS have been used to support espionage, target government officials, conduct attacks against police and critical infrastructure, and enable a range of other nefarious activities.[1] While the Australian Army and the Australian Defence Force (ADF) must be prepared to counter such threats in offshore conflict scenarios, recent legislation also assigns Defence a significant role in managing and disrupting these domestic threats.

Defence Amendment (Counter-UXS Measures) Regulations 2025 establishes a new legal framework enabling Defence and other authorised personnel to detect, disrupt and neutralise uncrewed systems across domains that threaten defence assets, protected defence areas, or Australia’s broader defence and security interests within Australia.[2] Appropriately trained ‘authorised persons’, including ADF members, certain Australian Public Service employees or contractors, and specified law-enforcement personnel, may employ a wide range of measures to counter uncrewed systems when they reasonably believe a device poses a safety or security risk. These measures include identification, tracking, interference, diversion, seizure or destruction of the system, provided actions are reasonable, safe and consistent with ministerial guidance and international obligations.

The amendment also clarifies the scope of key concepts such as ‘protected defence areas’. Such areas can include defence premises, declared maritime or aviation zones and other locations designated by the Minister for Defence where national security interests are at stake. It provides authority to exploit captured systems for intelligence and investigative purposes, including collecting and sharing relevant information with law-enforcement and intelligence agencies. The Amendment makes clear that the ADF has a significant domestic security responsibility. Legislative authority alone, however, will not be sufficient to manage the threat. The ADF’s counter-UAS capabilities are currently limited and will likely remain insufficient to protect all potential targets. Thus, deliberate processes are required to prioritise their allocation based on the nature of the threat, the probability of successfully mitigating it, and the potential for collateral damage. Sensors and effectors, integrated through standardised command and control systems, must be tailored to specific locations and threat profiles rather than deployed in a one-size-fits-all fashion.

This places a premium on the ability to communicate risk, options and likely outcomes to decision makers. Assessments of threat severity, mitigation effectiveness and collateral consequences may need to be elevated to senior Defence leadership or the ministerial level to inform decisions about where and how counter-UAS forces should be employed by all three services.

These issues aren’t hypothetical. Useful lessons can be drawn from the United States’ experience implementing similar authorities to counter UAS under the FY2017 National Defense Authorization Act. Section 130i of Title 10 allows the U.S. Department of Defense to employ counter-UAS capabilities to protect certain sensitive military facilities and assets domestically. A recent U.S. DoD Inspector General report found that policy governing which locations and assets were covered under Section 130i was unclear. This resulted in confusion, the omission of certain critical assets and locations (like Luke Air Force Base, where F-35 training is conducted), and inconsistencies between lists among different U.S. Government departments and organisations.[3]

The report also highlighted the difficulty of gaining approval to deploy and employ specific counter-UAS technologies at particular sites.[4] Counter-UAS capabilities are evolving rapidly, and not all sensors and effectors are appropriate for all operating environments. A short-range kinetic solution such as the Phalanx close-in weapon system may be suitable to protect a frigate from UAS threats in open-water, but is far less appropriate for use while in a congested port such as Sydney Harbour.

This experience highlights the importance of clear guidance on how approval packages should be developed, how scarce capabilities should be prioritised for deployment, employment and acquisition, and how procedures and capabilities can be standardised across government organisations with responsibilities under the Defence Amendment (Counter-UXS Measures) Regulations 2025. This guidance should form the starting point for implementation of the Amendment.

Beyond policy and procedural challenges, a more fundamental reality must be acknowledged: it is neither feasible nor affordable for Army to deploy active counter-UAS defences to all critical infrastructure, defence facilities and assets. Comprehensive protection against drone threats won’t be achievable in the coming decade. Instead, countering UAS will be an exercise in risk management, requiring decisions about where to allocate scarce capabilities based on the likelihood and potential consequences of attack.

Several factors can help Army reduce the overall risk posed by UAS in domestic environs. High-quality, actionable intelligence can improve understanding of the types of systems that may be employed for surveillance, targeted attacks or other malicious activity, the actors likely to employ them, and the locations most at risk. In favourable circumstances, such intelligence may even enable attacks to be pre-empted before they occur, allowing counter-UAS systems to be allocated to other priorities. Passive defensive measures will also play an important role in reducing both the probability of successful attacks and their potential impact. These measures may include training local personnel to recognise and respond to drone incursions, providing timely warning of aerial threats and designing facilities that are hardened against attack or less vulnerable to aerial surveillance.

At the same time, Defence will need to procure counter-UAS systems across all three services which are suited specifically to domestic employment. Capabilities that are effective and acceptable in combat environments may be less appropriate in populated areas where collateral damage and public safety are vital. Procurement and force planning will also require careful decisions about the balance between fixed systems deployed to protect key sites and more deployable capabilities that can be rapidly repositioned in response to emerging threats.

While the Defence Amendment (Counter-UXS Measures) Regulations 2025 provides the authority needed to respond to a growing domestic security challenge, successful implementation depends on how Army and Defence conceptualise and execute this mission. Counter-UAS can’t be approached as a problem of achieving comprehensive coverage in the near-term, nor as one that can be solved through technological solutions alone. Counter-UAS must therefore be understood less as a mission of defending everywhere and more as one of managing risk. This will require clear prioritisation frameworks, decision-support mechanisms, investment in intelligence and passive defensive measures, and the acquisition and deployment of capabilities suited to the domestic environment. By acting on these issues now, Defence can ensure that counter-UAS resources are employed in ways that meaningfully reduce vulnerability and strengthen national resilience against a threat that is certain to grow in the coming years. 

Endnotes

[1] Cody Weddle and Iona Cleave, “Gangs Bomb Police with Drones in Retaliation for Rio de Janeiro Raid,” The Telegraph, October 29, 2025, https://www.telegraph.co.uk/us/news/2025/10/28/drones-helicopters-bomb-gangs-rio-de-janeiro-raid/; Billy Stockwell and Catherine Nicholls, “Drones Spotted above Belgian Airbase Were ‘Spying’ on Military Planes, Defense Minister Says,” CNN, November 4, 2025, https://www.cnn.com/2025/11/02/europe/drones-spotted-belgian-airbase-spying-intl-latam; Michael Kosnar and Ken Dilanian, “Trump Shooter Flew Drone over Venue Hours before Attempted Assassination, Source Says,” NBC News, July 20, 2024, https://www.nbcnews.com/news/us-news/trump-shooter-flew-drone-venue-hours-attempted-assassination-source-sa-rcna162817.

[2] Defence Amendment (Counter‑UXS Measures) Regulations 2025, accessed February 11, 2026, https://www.legislation.gov.au/F2025L01553/asmade.

[3] U.S. Department of Defense, Inspector General, (U) Management Advisory: Immediate Attention Required to Protect DoD Covered Assets Against Unmanned Aircraft Systems (UAS), Project No. D2025-DEV0SR-0038.000 (Alexandria Virginia, U.S.: U.S. Department of Defense, Inspector General, 2026), https://media.defense.gov/2026/Jan/21/2003858370/-1/-1/1/DODIG-2026-045_REDACTED%2520SECURE.PDF.

[4] U.S. Department of Defense, Inspector General.

The views expressed in this article and subsequent comments are those of the author(s) and do not necessarily reflect the official policy or position of the Australian Army, the Department of Defence or the Australian Government.

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