03rd June 2026

White Paper

Beyond 2019

A New Counter Uncrewed Systems and Air Threat Resilience Strategy for the United Kingdom, After Ukraine and Iran

By Mr Richard Ryan, Barrister, Blakiston’s Chambers · June 2026

Status and method. This paper relies on primary and official sources, supplemented by reputable reporting for incident chronology. All facts are verified as at 2 June 2026. Battlefield figures drawn from active conflict reporting are attributed to their originating source and presented as attributed claims rather than judicially established fact. The paper contains no classified or privileged material. All footnote links are live.

The United Kingdom’s published national counter drone policy; the UK Counter-Unmanned Aircraft Strategy, presented to Parliament as Command Paper 187 on 21 October 2019[1]; is materially out of date as a strategic document. It remains the only published national strategy in the field for the whole of government, yet it is now approximately six years and seven months old, and roughly three and a half years beyond its own planning horizon.

The strategy was sound for its time. It identified the highest harm illegal uses of small drones; terrorism, smuggling into prisons, disruption of critical national infrastructure; and prescribed layered intervention, industry standards, responder powers and public education.[2] But it was expressly confined to malicious and illegal use of small aerial drones, in a domestic policing and protective security frame. That frame has been overtaken by operational reality in Ukraine and the Iranian theatre: massed one way attack drones, combined drone and missile salvos, container and special forces launch, dense electronic warfare, fibre optic command links and AI assisted guidance now define the threat.

Subsequent UK documents do not update the 2019 strategy; they work around it. The Defence Drone Strategy (2024),[3] the Strategic Defence Review 2025,[4] NPSA’s site specific guidance,[5] and the Ministry of Defence’s 2026 pursuit of new defeat powers at military sites[6] together form a patchwork of sectoral adaptations laid over an unrevised core. This paper argues that the 2019 strategy should be retired as a standalone statement and replaced by an integrated Counter Uncrewed Systems and Air Threat Resilience Strategy, supported by a consolidated legal code for detection, disruption and defeat, and by an annual ministerial statement to Parliament.

1.  The threat has become a strategic mass system

The central lesson of 2024–2026 is not that drones have become more common but that they have become a strategic mass system — a consumable class of munition and sensor used for saturation, decoying, attrition of intelligence assets, target acquisition and the deliberate erosion of a defender’s cost exchange ratio. On the night of 2 June 2026, Ukraine’s air force reported that Russia had launched 656 drones and 73 missiles in a single overnight barrage, of which 602 drones and 40 missiles were downed or suppressed.[7][8] Single salvos now routinely exceed several hundred drones.

Critical infrastructure has been directly affected. In February 2025 a Russian Geran-2 (Shahed type) drone struck the New Safe Confinement over Chornobyl’s reactor four;[9] by December 2025 the International Atomic Energy Agency assessed that the structure had lost its primary safety functions, including confinement.[10] In May 2026 a drone strike caused a fire at an electrical generator on the perimeter of the United Arab Emirates’ Barakah nuclear plant; a civilian reactor site; leaving one unit running on emergency diesel generators.[11][12]

The homeland and deployed force dimension is now concrete for the United Kingdom. In early March 2026 a Shahed type drone struck a runway at RAF Akrotiri in Cyprus; a British Sovereign Base Area; causing limited damage,[13] and the UK flew defensive sorties and, where requested, acted in the collective self defence of regional allies.[14] Ukraine’s Operation Spider’s Web (June 2025) had already shown that 117 first person view drones launched from concealed truck borne containers could strike strategic bomber bases far from any front line, damaging more than 40 aircraft, with some guidance reportedly AI assisted.[15]

A necessary qualification

Not every battlefield lesson maps to the British mainland. The most credible open analysis holds that long range Shahed type strikes on Great Britain would face high attrition because of geography and warning time, while shorter range drones launched from containers or by hostile special forces remain a credible risk to high value assets at home. The policy implication is to discriminate between vectors; not to import foreign assumptions wholesale, and not to dismiss the threat. A refreshed strategy should say so candidly.

2.  Why the 2019 strategy can no longer stand alone

2019 provision Current reality Assessment
Focus on the highest harm illegal use of small aerial drones in the UK. Concern now extends to defence sites, CNI in crisis or conflict, and state launched drones and missiles. Too narrow as a national frame.
Short planning horizon from 2019. Document is c. 6.6 years old; NPSA requires regular review because methods change quickly. Formally stale; refresh overdue.
Empower police and responders. MoD now seeks its own defeat powers at Defence sites because police only authorities are inadequate. Institutionally outdated.
Aerial drones only. New Defence policy extends to land and maritime uncrewed systems. Conceptually outdated.
Counter drone as a discrete problem. NATO now treats small UAS through hypersonic missiles as one integrated air and missile defence continuum.[16] The silo is no longer tenable.

The clearest institutional signal came in February 2026, when the Ministry of Defence reported 266 drone incidents near UK military sites during 2025 (up from 126 in 2024) and sought fresh statutory powers through the Armed Forces Bill; extending beyond aerial drones to land and maritime systems; to allow Defence personnel to defeat drones at their own sites without waiting for police intervention.[6] When the armed forces must legislate around a framework built for policing to protect their own bases, that framework has expired.

3.  The legal framework: developed, but fragmented

Domestic powers have expanded since 2019 but remain complex. The Air Traffic Management and Unmanned Aircraft Act 2021 created bespoke constabulary powers to ground, stop, search, inspect and seize unmanned aircraft, and amended section 93 of the Police Act 1997 to facilitate authorisations for certain counter drone measures.[17][18] In the civil regime, the Civil Aviation Authority’s Direct Remote ID requirements came into force on 1 January 2026 for UK1, UK2, UK3, UK5 and UK6 class drones, with extension to most drones carrying a camera from 1 January 2028.[19]

Yet lawful defeat is markedly harder than detection. Operational use of a jammer is generally an offence under section 68 of the Wireless Telegraphy Act 2006, and Ofcom has no power to authorise operational use; only narrow trial and research licences in shielded conditions.[20] Government is separately examining the enforcement framework around jammers.[21] Kinetic or electronic interference may amount to unlawful property or wireless interference absent proper authorisation; the Act’s own explanatory notes acknowledge as much. Techniques that take over a drone by software may engage the Computer Misuse Act 1990 and the Investigatory Powers Act 2016, and sensing engages the Data Protection Act 2018, the UK GDPR and the Human Rights Act 1998, which requires the state both to protect life from foreseeable threats and to keep its sensing and defeat measures necessary and proportionate. A lawful defeat chain is a designed legal artefact, not an improvisation.

Overseas action sits within international law. The Government’s March 2026 legal position on Iranian regional attacks invoked the collective self defence of allies under Article 51 of the UN Charter, subject to necessity and proportionality and Security Council notification.[14] Once in armed conflict, drones attract no special category: they are governed by the ordinary rules of distinction, proportionality and precaution applicable to all weapons.[22]

4.  Recommendations

The Government should replace the 2019 strategy with a new instrument covering the whole of government. Five propositions should anchor it:

  1. Integrate, do not append. A single Counter Uncrewed Systems and Air Threat Resilience Strategy spanning the Home Office, MoD, Cabinet Office resilience, CAA, Ofcom, NPSA, the intelligence community, prisons and CNI operators, aligned to NATO’s integrated air and missile defence framework.[16]
  2. Consolidate the law. A statutory code (or, at minimum, statutory guidance) defining who may detect, disrupt and defeat uncrewed systems, where, against which threat category, under what authorisation, with what recording and what review after an incident — differentiating urban areas, prisons, airports, defence sites and overseas operations.
  3. Adopt a layered baseline that is alert to cost. Use NPSA’s site specific, threat informed model as the national spine,[23] plugging into a wider air and missile defence architecture for higher end threats, and prioritising defeat options that are low in collateral, deep in magazine and economically rational. A missile fired at every cheap drone is not a strategy; it is a budgetary confession.
  4. Treat industry and export control as readiness. Link procurement, export licensing, sanctions intelligence and sovereign industrial strategy, with secure by design and open architecture requirements across C-UAS procurement. A state that cannot source the components of its own counter drone systems is not strategically autonomous.
  5. Compliance and oversight by design. Require a written legal basis, data minimisation, retention limits and human oversight for every C-UAS deployment by a public authority; subject identification by AI to documented necessity and a review of error rates; and provide Parliament an annual ministerial statement on C-UAS powers, deployments, tests, safety incidents, rights compliance and lessons learned, with NPSA and the ICO involved where domestic surveillance is concerned.

5.  Conclusion

None of this discards the 2019 strategy’s best inheritance; its insistence on layered intervention over an optimism founded on gadgets, an instinct NPSA’s later guidance has only reinforced.[5] The task is not to repudiate 2019 but to lift its sound protective security spine into an architecture wide enough for the threat that now exists: a spectrum of low cost, autonomous and electronically contested uncrewed systems, ranging from nuisance to war. The 2019 strategy answered the question of its decade. It is time to ask the question of this one.

About the author. Mr Richard Ryan is a barrister of Blakiston’s Chambers..

Footnotes & sources (23)

  1. UK Counter-Unmanned Aircraft Strategy, CP 187, presented to Parliament 21 October 2019 (GOV.UK). https://www.gov.uk/government/publications/uk-counter-unmanned-aircraft-strategy
  2. UK Counter-Unmanned Aircraft Strategy (HTML version), GOV.UK, published 21 October 2019. https://www.gov.uk/government/publications/uk-counter-unmanned-aircraft-strategy/table
  3. Defence Drone Strategy — the UK’s approach to Defence Uncrewed Systems, GOV.UK, published 22 February 2024. https://www.gov.uk/government/publications/defence-drone-strategy-the-uks-approach-to-defence-uncrewed-systems/defence-drone-strategy-the-uks-approach-to-defence-uncrewed-systems
  4. The Strategic Defence Review 2025 — Making Britain Safer, GOV.UK, published 2 June 2025. https://www.gov.uk/government/publications/the-strategic-defence-review-2025-making-britain-safer-secure-at-home-strong-abroad
  5. NPSA, “Counter Uncrewed Aerial Systems (C-UAS)” specialised guidance. https://www.npsa.gov.uk/specialised-guidance/uncrewed-aerial-systems/counter-uncrewed-aerial-systems-c-uas
  6. Ministry of Defence, “New powers for Defence personnel to defeat drones following doubling of incidents near bases” (266 incidents in 2025, up from 126), GOV.UK, 2 February 2026. https://www.gov.uk/government/news/new-powers-for-defence-personnel-to-defeat-drones-following-doubling-of-incidents-near-bases
  7. “Russia launched 656 drones and 73 missiles” — figures attributed to the Ukrainian Air Force; CBS News, 2 June 2026. https://www.cbsnews.com/news/russia-ukraine-war-major-attacks-missile-drone-kill-several-wound-dozens/
  8. NPR, “Russian attack on Ukraine kills at least 14”, 2 June 2026 (corroborating launch and interception figures). https://www.npr.org/2026/06/02/nx-s1-5844071/russian-attack-ukraine
  9. Chornobyl New Safe Confinement struck by a Geran-2 (Shahed type) drone, 14 February 2025: Greenpeace Ukraine mission report, 20 March 2025. https://www.greenpeace.org/ukraine/en/news/3504/fifty-percent-of-north-roof-structure-of-chornobyl-new-safe-confinement-shelter-severely-damaged/
  10. IAEA assessment (December 2025) that the New Safe Confinement had lost its primary safety functions, including confinement (reported via United24/Reuters). https://united24media.com/latest-news/iaea-chornobyls-new-safe-confinement-can-no-longer-contain-radiation-after-russian-drone-attack-14067
  11. Drone strike causing a generator fire at the UAE’s Barakah nuclear plant, 17 May 2026: Al Jazeera, 17 May 2026. https://www.aljazeera.com/news/2026/5/17/drone-strike-sparks-fire-at-uaes-barakah-nuclear-power-plant
  12. NPR, “Drone strikes UAE nuclear plant”, 18 May 2026 (IAEA: one reactor on emergency diesel generators). https://www.npr.org/2026/05/18/g-s1-122534/drone-strikes-uae-nuclear-plant
  13. Reuters, “Iranian-made drone hits British air base in Cyprus” (RAF Akrotiri runway strike, limited damage), 2 March 2026. https://www.aol.com/articles/iranian-made-drone-hits-british-121630466.html
  14. Summary of the UK Government legal position: the legality of defensive action in respect of Iranian regional attacks, GOV.UK (10 Downing Street), March 2026. https://www.gov.uk/government/news/summary-of-the-uk-government-legal-position-the-legality-of-defensive-action-in-respect-of-iranian-regional-attacks
  15. CSIS, “How Ukraine’s Operation Spider’s Web Redefines Asymmetric Warfare” (117 drones; 40+ aircraft struck; some AI assisted guidance). https://www.csis.org/analysis/how-ukraines-spider-web-operation-redefines-asymmetric-warfare
  16. NATO Integrated Air and Missile Defence Policy, 13 February 2025 (threat spectrum “from small… UASs to all types of cruise and ballistic missiles, including hypersonic”). https://www.nato.int/cps/en/natohq/official_texts_233084.htm
  17. Air Traffic Management and Unmanned Aircraft Act 2021 (c. 12), legislation.gov.uk. https://www.legislation.gov.uk/ukpga/2021/12/contents/enacted
  18. Explanatory Notes to the Air Traffic Management and Unmanned Aircraft Act 2021 (kinetic/jamming measures may amount to unlawful interference; amendment of s. 93 Police Act 1997). https://www.legislation.gov.uk/ukpga/2021/12/pdfs/ukpgaen_20210012_en.pdf
  19. UK Civil Aviation Authority, “Remote ID (RID)” — Direct RID in force from 1 January 2026 for UK1, UK2, UK3, UK5 and UK6 drones; extension from 1 January 2028. https://www.caa.co.uk/drones/regulations-consultations-and-policy-programmes/policy-programmes/remote-id-rid/
  20. Ofcom, “GPS jamming exercises” — operational use of a jammer is an offence under s. 68 Wireless Telegraphy Act 2006; Ofcom cannot authorise operational use. https://www.ofcom.org.uk/spectrum/frequencies/gps-jamming-exercises
  21. DSIT, “Possession of radiofrequency jammers and the relevant legal framework” (call for evidence), GOV.UK, 2026. https://www.gov.uk/government/calls-for-evidence/possession-of-radiofrequency-jammers-and-the-relevant-legal-framework/possession-of-radiofrequency-jammers-and-the-relevant-legal-framework
  22. ICRC, “FAQ: international humanitarian law and the use of drones in armed conflict” (distinction, proportionality, precaution). https://www.icrc.org/en/article/faq-international-humanitarian-law-drones-armed-conflict
  23. NPSA, “Countering Threats from Uncrewed Aerial Systems — Making Your Site Ready”. https://www.npsa.gov.uk/resources/c-uas-making-your-site-ready