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