The 'Humanoid ROBOT Act' Blocks Federal Use of AI Robots From 'Countries of Concern' and Tightens Investment Rules

The Humanoid ROBOT Act of 2025 is a national security measure designed to keep advanced robotics developed by certain foreign nations out of the U.S. federal government and its supply chain. Essentially, the bill says that if you’re a federal agency or a contractor working for the government, you can’t buy or use a humanoid robot—defined as an AI-integrated, human-shaped machine capable of interactive communication—if it was designed, tested, developed, or manufactured by a “covered entity.” These covered entities are broadly defined, mostly linking back to governments and companies associated with what the U.S. deems "countries of concern."

Who Gets Banned and Why?

This isn't just about government purchases; it hits contractors, too. If your company has a federal contract, you can’t use a restricted humanoid robot to fulfill or support that work. The bill gives the Federal Acquisition Regulatory Council 180 days to update the rulebook, meaning that within six months of enactment, every prime contractor will need to ensure their subcontracts follow the same restrictions. For government contractors, especially those in manufacturing or logistics who might be eyeing these advanced bots for efficiency, this means a significant new layer of supply chain scrutiny. If you’re a logistics firm using an advanced bot to move federal supplies, you’ll need to prove its origin is clean, or face potential contract termination. The only loophole is for the Secretary of Defense, who can grant a waiver if a specific robot is absolutely necessary for national security or research purposes.

CFIUS Now Watches Robot Investors

Perhaps the biggest change for the tech industry is how the bill treats foreign investment. Currently, the Committee on Foreign Investment in the United States (CFIUS) reviews foreign deals that could give an overseas entity control over a sensitive U.S. business. This bill expands that authority significantly for the humanoid robot sector. It mandates CFIUS review for any investment—even a small, minority stake that doesn't grant control—into a U.S. business that designs, tests, develops, or manufactures these robots, provided the investment comes from an entity linked to a "covered nation." This is a major shift. For a U.S. robotics startup looking for cash, this means that taking even a non-controlling investment from a venture capital firm with headquarters in, say, a country of concern, will now trigger a mandatory, time-consuming national security review. This could easily chill foreign direct investment in a rapidly growing, capital-intensive sector, potentially forcing U.S. companies to rely solely on domestic funding sources.

The Data Security Mandate

Beyond procurement restrictions, the bill requires the Secretary of Defense to produce a comprehensive report within one year. This report must analyze the national security threats posed by these robots, specifically focusing on how countries of concern are developing them, how they might bypass U.S. export controls, and, critically, the threat posed by data collection. The DOD must analyze the privacy and data security risks associated with data collected on U.S. persons by these robots and how that data might be accessed by foreign governments. If you buy a consumer-grade humanoid robot in the future, this report is the government’s way of figuring out if that machine is a potential spy on your home network. This section acknowledges that the real risk isn't just the hardware, but the sensitive data these AI systems collect and process, which could be exploited for economic espionage or intelligence gathering.