Human Responsibility and Accountability – Compliance Challenges and the Industrial Impact of the GGE Framework

What does the UN’s latest framework on lethal autonomous weapon systems mean for the companies building them? 

Lethal autonomous weapon systems (LAWS) are irreversibly changing the way wars are waged. They can identify, select, and engage targets with limited to no human intervention. 

This potential for independent decision-making of LAWS, along with the AI boom and diverging national interests among investing nation-states, raises fears of an autonomous weapons arms race that has the same tangible impact as the 20th-century nuclear race. 

Yet effective and internationally aligned guardrails for their development, modification, and deployment remain incomplete.  

The United Nations’ (UN) Group of Government Experts (GGE) tried to come up with a solution for this. In their 2026 report, they outline a foundational “set of elements” to govern the future development and military deployment of autonomous weapon systems. They did so in accordance with different stakeholders. However, the resulting final framework provides limited direct guidance for, or obligations on, defence manufacturers.  

How effective is this “set of elements” then? And what does the UN’s latest framework on lethal autonomous weapon systems mean for the companies building them? 

The new report of HCSS, Human Responsibility and Accountability: Compliance Challenges and the Industrial Impact of the GGE Framework, challenges certain aspects of the GGE’s report by examining its implications for the companies designing, developing, and supplying LAWS. HCSS Strategic Analysts Hans Horan, Davis Ellison, and Paul Spangenberg argue that the adopted framework places its obligations primarily on states, rather than directly on manufacturers. 

This creates a critical gap, where the final text is principally an instrument for states, not manufacturers. It neither establishes what a lawful LAWS must be (and mustn’t be) capable of doing, nor what evidence manufacturers must provide to demonstrate compliance. Furthermore, the GGE report has omitted or weakened provisions on system reliability, predictability, and renewed review after significant modifications of LAWS. 

To address these concerns, this report puts forward the following recommendations:  

1. Put back the requirement for review when a system changes; 

2. Decide whether the new rules not only cover the weapon itself, but also the software, data, sensors and systems that determine how it operates autonomously; 

3. Create a technical input route for the people who build these systems and the watchdogs who monitor them; 

4. Recognise that if the UN does not set the standard, procurement will; 

5. Consider an International Code of Conduct for Autonomous Weapon Manufacturers. 

The paper underscores the need for a broader shift in governance approaches: from deliberations conducted predominantly among states and civil society towards more inclusive and empirically grounded engagement with the full spectrum of actors implicated in the development and deployment of autonomous military technologies. 

Authors: Hans Horan, Davis Ellison and Paul Spangenberg. 
Contributors: Ali Aydogdu and Sofia Romansky.  
Quality assurance: Michel Rademaker.  

The research and production of this report were conducted with the generous support of the Future of Life Institute (FLI). Responsibility for the contents and for the opinions expressed rests solely with the authors and does not constitute, nor should it be construed as, an endorsement by the FLI.