Assessing the USCG's Unmanned Systems Test Area Policy: Three Reasons to Add Cybersecurity

Julius Shin
Julius Shin
Maritime Technical Consultant · Shipboard Cybersecurity & Compliance
- LinkedIn : https://www.linkedin.com/in/abysstoinfinity

Summary. The U.S. Coast Guard's policy on designated test areas for unmanned systems (WWM 26-05) is a timely measure that pursues innovation support and maritime safety management together. Centered on physical navigation safety, it lays the foundation for a risk assessment and management framework. Extending that framework to cybersecurity, in light of the distinctive characteristics of unmanned systems, would make the policy considerably more effective. This article sets out three reasons to add cybersecurity to the policy: for unmanned systems, a cyber incident is an operationally fatal event; their cyber resilience and recoverability can be verified only to a limited extent in the private sector because of technical and regulatory constraints; and, from the perspective of unmanned weapon systems, cybersecurity bears directly on the operational reliability of national security assets.

The article assesses the policy from three perspectives, fitness for purpose, operational structure, and extensibility, and then explains why it should be extended to cybersecurity and in which direction.

1. Fitness for Purpose: A Timely Measure Balancing Innovation and Maritime Safety

On October 15, 2026, the USCG issued Policy Letter WWM 26-05. The document instructs field units on establishing designated test areas for testing unmanned, autonomous, and remotely operated maritime systems and other novel maritime technologies. It aligns with America's Maritime Action Plan, released by the White House in February of the same year, and reflects a broader view of unmanned maritime systems as a strategic sector for both commerce and national security.

The policy is timely because it addresses two objectives at once.

▸Supporting innovation. Developers no longer face the uncertainty of seeking permission case by case and can test new technologies in a predictable environment.
▸Managing maritime safety. Concentrating test activity in waters away from major shipping lanes and fishing grounds reduces the risk of conflict with general shipping, fishing, and recreational activity.

As an example of a regulator opening the way first in order to keep pace with innovation, the policy offers a useful reference for other countries.

2. Operational Structure: A Foundation Built Around Physical Navigation Safety

The policy establishes the foundation of a risk assessment and management framework centered on physical navigation safety. Its main elements are as follows.

▸Advance designation. Each Captain of the Port (COTP) designates test areas in advance, avoiding high-traffic routes and major fishing grounds.
▸Extended waters. Test areas may extend beyond the territorial sea into the Exclusive Economic Zone (EEZ), with candidate sites recommended on the basis of vessel traffic data and port access route studies.
▸Risk assessment. A navigation safety risk assessment is conducted that reflects the operator's concept of operations (CONOPS).
▸Records and notification. Assessment results and measures are recorded in USCG record systems and communicated to waterway users through navigational warnings and local stakeholder forums.
▸Operator responsibility. The USCG does not approve or certify individual systems, and it makes clear that responsibility for safe operation rests with the operator.

This structure is well suited to managing physical hazards such as collision, grounding, and interference with traffic routes in a systematic way. Moreover, as operational guidance rather than binding regulation, the policy leaves room for further guidance. It provides a flexible base on which the scope of oversight can be broadened as technology evolves.

3. Extensibility: A Structure That Can Absorb Cybersecurity Without a New Regime

In terms of extensibility, the policy's greatest strength is that cybersecurity can be added without creating a separate regime.

Extension does not mean building a new system. It means adding a cyber perspective to the foundation already in place. Operators would address cyber risks in their CONOPS, the COTP's risk assessment would review them alongside navigational risks, and the results would be kept in the same record systems. In this way, test areas would evolve from "places to test navigational capability" into "places to verify safety comprehensively."

Why cybersecurity, then? There are three reasons.

4. Three Reasons to Add Cybersecurity

Reason 1. For unmanned systems, a cyber incident is operationally fatal

Unmanned systems are operated not by people but through communication links, positioning data, sensors, and software. On a crewed vessel, if a cyber incident occurs, the crew can switch to manual operation and continue the mission. Unmanned systems have no such fallback. The very means of controlling the operation lie in the cyber domain.

A cyber incident on an unmanned system therefore directly affects the entire operation.

▸Loss of control. If remote control is lost or hijacked, the vessel cannot be operated at all.
▸Mission disruption. If positioning or sensor data are manipulated, the mission either cannot continue or is distorted by erroneous decisions.

For an unmanned system, then, a cyber incident is not collateral damage such as a data leak; it is a fatal event that halts or neutralizes the operation itself. Cybersecurity is a precondition for operating unmanned systems.

The failure of an operation, moreover, does not stay the operator's problem. An unmanned system that has lost control can cross the boundary of the test area and become a hazard in general waters. The guidance itself states that use of a test area does not relieve operators of their responsibility for safe operation. In this respect, the cybersecurity of unmanned systems goes beyond the operator's business risk and touches the safety of the marine transportation system that the policy seeks to protect.

If what a test area ultimately seeks to confirm is "whether an unmanned system can operate safely," the policy's objective can be fully achieved only when the cyber dimension is addressed as well.

Reason 2. Technical and regulatory constraints limit private-sector verification of cyber resilience and recoverability

Developers can verify physical navigation performance themselves in a test area. Resilience to cyberattack, and the ability to recover to normal operation after an attack, are far harder for the private sector to verify on its own.

▸Technical constraints. The security of an unmanned system extends beyond the hull to the shore-based remote operations center, satellite and cellular links, and the cloud. For small and mid-sized developers, building a test environment that reproduces realistic attack scenarios across this entire chain imposes a heavy burden of cost and expertise.
▸Regulatory constraints. The tests that matter most for unmanned systems, such as communications jamming and position spoofing, cannot lawfully be conducted at sea by private parties at will. In the United States, federal communications law prohibits private use of jamming equipment altogether (FCC Enforcement Advisory). Without government control and authorization, such tests cannot take place at all.
▸Absence of standards. IACS UR E26/E27, the existing cyber requirements for ships, define their scope of application by ship type and size (IACS), which makes them difficult to apply as they stand to small unmanned systems. Without common test criteria, regulators, insurers, and buyers find it hard to compare or trust the test results of individual developers.

Verifying cyber resilience and recoverability is therefore an area that the market alone is unlikely to address, and one where a public role is needed.

Reason 3. For unmanned weapon systems, cybersecurity bears directly on the operational reliability of national security assets

The guidance explicitly lists national security applications alongside commercial ones among the intended uses of unmanned systems. Unmanned weapon systems, such as unmanned warships and swarming unmanned surface vessels, typically undergo final verification at navy test ranges. However, the defense contractors and dual-use technology companies that develop them are likely to use civilian test areas in early development. If cyber verification is missing at the civilian testing stage, that gap carries through to the point of military acquisition.

For unmanned weapon systems, cyber and electronic warfare threats are not a risk that might materialize but an operating environment they will certainly face. Recent cases make this clear.

▸Black Sea. Ukraine's uncrewed surface vessels have significantly constrained the operating range of Russia's Black Sea Fleet, demonstrating that unmanned systems can change the balance of maritime power (RUSI). At the same time, this means unmanned systems become prime targets for an adversary's concentrated interference and countermeasures.
▸Baltic Sea. A 2025 shipborne measurement study identified attacks that went beyond simple jamming, combining counterfeit GPS signals with interference against other satellite navigation systems (UK Defence Journal). For unmanned systems that depend on positioning data, this is a direct threat.

In such an environment, an unmanned weapon system whose minimum level of cyber warfare readiness has not been verified will struggle to establish confidence in its ability to carry out operations. Swarm assets in particular are exposed: when a single control system is neutralized, many platforms are affected simultaneously, so the impact is far greater than for a single platform.

Verifying cyber resilience and recoverability from the civilian test area stage onward is therefore the starting point for assuring the operational reliability of national security assets.

5. Direction of Extension and Participating Agencies

This extension is not something the USCG's waterways management organization can take on alone. A realistic approach is to use the test areas established under WWM 26-05 as a common platform, with the agencies responsible for each domain participating together.

Direction Content Key participants
Cyber test criteria Develop common criteria, adapting existing international standards to the testing stage of unmanned systems, in phases starting at the advisory level USCG cyber organizations, CISA, classification societies
Cyber test infrastructure Authorize communications jamming and position spoofing tests on a per-test-area basis, and support shared test facilities that emulate shore-based remote operation environments Spectrum authorities (FCC, NTIA), Maritime Administration (MARAD)
Civil-military cooperation Defense authorities with electronic warfare test capabilities support private-sector testing Department of Defense, defense and commercial developers

Civil-military cooperation in particular benefits both sides. The private sector gains verification opportunities it could not obtain on its own, and the military can confirm early the cyber resilience of assets it plans to acquire. With a single infrastructure serving both civilian and military users, the public value and effectiveness of the infrastructure itself also grow.

6. Anticipated Objections and Responses

Objection 1. Cyber requirements conflict with the policy's intent to streamline.
The core of the guidance is to simplify testing procedures to support innovation. One might worry that adding cyber requirements would raise barriers to entry and slow innovation instead.
Response.
What is proposed here is not mandatory requirements but advisory-level criteria and optional testing opportunities. At the testing stage, it is enough to start with basic checks such as "does the system detect anomalies and come to a safe stop?" Confirming this early in testing reduces developers' overall cost and schedule burden compared with facing security requirements for the first time just before commercialization.
Objection 2. Cyber test infrastructure is expensive. Who will bear the cost?
Response.
That is precisely why a public role is needed. Having every developer build its own test environment amounts to duplicated investment from the standpoint of society as a whole. Bundling authorizations by test area and having civilian and military users share a single infrastructure lowers individual burdens and increases the infrastructure's public value.
Objection 3. Cybersecurity is outside the remit of USCG waterways management.
Response.
This is a fair point. For that reason, this article does not ask the waterways management organization to take on every role. It proposes a structure in which the test areas established under WWM 26-05 serve as a common platform, on which the agencies responsible for cyber, spectrum, defense, and other domains cooperate.

7. Implications for South Korea

South Korea already has a similar institutional framework in place. The Act on the Promotion of Development and Commercialization of Autonomous Ships, which took effect in January 2025, grants exemptions from the Ship Safety Act, the Ship Officers Act, and other laws once a safety assessment has been passed within separately designated operating waters (News Seoul). The area around Ulsan Port has been designated as the first such operating waters, and in June 2026 the first approval for real-sea demonstration operations under the Act was granted (Newswire).

The U.S. designated test areas and South Korea's operating waters rest on the same idea: demonstrating safely within defined waters. The extension tasks raised in this article therefore apply equally to South Korea.

▸Add cyber items to the operating-waters assessment. Consideration could be given to including a review of cyber risks in the safety assessments for designating operating waters and approving demonstrations.
▸Add cyber testing capabilities to public demonstration platforms. Combining communications jamming and position spoofing test environments with public demonstration infrastructure, such as performance demonstration centers, would substantially reduce the verification burden on domestic developers.
▸Build on the foundation for civil-military cooperation. Linking the defense sector, which is developing maritime unmanned systems, with the civilian demonstration framework would allow a single infrastructure to meet both civilian and defense needs.

Now that the United States has just launched its test area program, if South Korea is first to combine a cyber verification framework with its operating-waters program, it could also take the lead in international norm-setting discussions on autonomous ships and unmanned systems.

8. Conclusion

WWM 26-05 is a meaningful first step in which a regulator has opened the way for innovation in the era of unmanned maritime systems. The foundation it builds around physical navigation safety is sound, and the room it leaves for further guidance provides a natural channel for adding cybersecurity on top of it.

For unmanned systems, cyber incidents are operationally fatal; their verification is constrained in the private sector by technical and regulatory limits; and for unmanned weapon systems, they bear directly on operational reliability. All three reasons point in the same direction. By adding cybersecurity to its test area policy, the USCG can achieve its goals of supporting innovation and ensuring maritime safety at a higher level.


References

Julius Shin
Julius Shin
Maritime Technical Consultant · Shipboard Cybersecurity & Compliance

Owner-side maritime cybersecurity advisor covering IACS UR E26/E27 compliance, zone and conduit design, and OT/IT security architecture for commercial vessels — working across LR, ClassNK, DNV, ABS, and BV newbuilding projects.

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