Sector Thesis 01 · Physical AI

Physical AI: where the value actually accrues

A working compass for how Orien reads embodied intelligence, the mechanism that decides the winners, and the evidence we revisit to know if we are still right.

01The Orien view

One page, stated plainly

Physical AI is the application of learned intelligence to machines that sense and act in the real world. It has crossed from a deep-tech bet into early commercialisation, what the market now calls its "GPT-2.5 moment": the capabilities are real and the scaling laws are visible, but production-grade reliability is not yet here. Capital deployed before that inflection compounds differently from capital deployed after it. That is the reason to have a view now.

Our view rests on one mechanism and one variable, and everything else in this paper hangs off them.

  • The mechanism is integration versus recombination. While the interface between intelligence and hardware is immature, vertical integration wins, you must co-design across the boundary, and deployment data compounds for whoever owns the whole robot. As that interface standardises, the stack unbundles and value migrates to whoever holds the scarce asset.
  • The swing variable is cross-embodiment transfer quality. If intelligence trained on one body keeps transferring to others, and in 2025–26 it demonstrably does, on a measurable scaling curve, then the stack unbundles, data moats weaken, form factor stops mattering, and the intelligence layer captures the margin. If transfer stalls, integration holds and the full-stack leaders compound. We do not have to guess which; we track it.
  • A security and supply-chain overlay bends the whole picture. Because a robot is a sensing-and-data platform, data-exfiltration and IP concerns attach to any deployment in the West, which slows unbundling in exactly the highest-value markets and turns the allied component supply chain into a first-class investment theme, not a footnote.

From those three, our working stance across the sector:

  • Selective  Foundation models / "robot brains." The prize is real but the rounds are enormous and the field is consolidating around a handful of names. We do not try to lead here; we look for teams turning general models into durable, specific advantages.
  • Conviction  Robotics infrastructure & the component supply chain. Picks-and-shovels with physical, capital-intensive moats, actuation, allied magnets and reducers, data and evaluation tooling, sit closest to Orien's edge and are structurally under-supplied in the West.
  • Conviction  Applied autonomy in structured environments. Underwritable on real unit economics today; narrow-task production reliability already clears 99%.
  • Contingent  Full-stack humanoids. First-movers have a real, but time-limited, structural advantage. We own the leaders where we can, and we watch the swing variable to know when the advantage decays.
  • Performance-first  Defense. The one vertical where the buyer pays for capability over unit economics, and, per Bessemer, the likely source of the category's first $50B+ IPOs.
First, a calibration

Physical AI is already a large, revenue-generating business, and almost none of it is humanoid. Roughly 4.66 million industrial robots are at work worldwide, Amazon alone runs more than a million, and warehouses, farms, operating theatres and highways are filling with purpose-built machines that earn their keep today. Against that, on the order of 15,000 humanoids shipped in all of 2025, under half a percent of the deployed robot base. Where this paper leans on humanoid data, it is because the sell-side has quantified that one form factor most thoroughly, and because it is where the marginal capital and the widest range of outcomes sit, not because it is where value is being created and captured right now.

4.66M
Industrial robots operational worldwide today
IFR World Robotics 2025
1M+
Robots in Amazon's fleet alone
Amazon, 2025
~15k
Humanoids shipped in all of 2025
Omdia
<0.5%
Humanoids' share of the deployed robot base
Orien calc.

We treat humanoids, then, as the sector's highest-variance option, the frontier bet whose payoff is enormous if the general-purpose form works, not the base case for where physical AI earns money over the next few years. This is also why our framework insists form factor is second-order: the durable question is which layer captures value as intelligence transfers across bodies, and it is answered the same way whether the winning body turns out to be an arm, a wheeled base, a drone, or a biped.

How to read this document

This is a compass, not a market map, and not a pitch. It takes positions, names the evidence that would overturn them, and ends with a dated signpost dashboard we update. Every figure is sourced to public material as of July 2026. It draws on Orien's earlier internal work but contains no confidential information on any private company.

02Why now

Three curves turned at once: the intelligence became scalable, the hardware became cheap, and the labour it addresses became scarce. Capital followed, faster than most balance sheets have adjusted to.

$18.8B
Robotics VC in H1 2026, already past every prior full-year record
Crunchbase, Jun 2026 (narrow defn.)
~90%
Of humanoid robots shipped in 2025 were made in China
Omdia / IDC; Bessemer
R²=0.998
Fit of the scaling law between human-video data and robot performance
EgoScale, NVIDIA GEAR, Feb 2026
~3×
Cost penalty to build a humanoid without Chinese suppliers
McKinsey, 2026

The intelligence became scalable

For a decade, robot learning was stuck on an island: every robot, task and lab needed its own model, and there was no internet-scale corpus of physical experience to train on. That has changed in a way that rhymes with the language-model story. Between late 2025 and mid-2026, three independent groups published scaling laws for robot policies, showing that performance improves predictably and log-linearly with data, and, crucially, that intelligence trained on one body transfers to others. NVIDIA's EgoScale fit that curve at R²=0.998 across 20,000 hours of human video, with real-robot task completion rising from 30% to 71% as data scaled. Physical Intelligence and Georgia Tech showed the transfer emerges sharply above a diversity threshold, the way abilities emerge in large language models.

The investable reading is subtle but decisive: the question has moved from "does robot learning transfer?" (now settled, yes) to "how much data and diversity buys a target reliability?"

Robot performance now scales with data, predictably
Real-robot task completion vs. hours of egocentric human-video pre-training. Illustrative of the measured log-linear law; endpoints are reported.
Source: NVIDIA GEAR, EgoScale (arXiv:2602.16710, Feb 2026); reported endpoints 30%→71% as data scales 1k→20k hrs, R²=0.998. The absence of saturation at 20k hours is the point.

The hardware became cheap, and concentrated

A capable robot is now mostly a commodity-electromechanical problem. Chinese vertical integration has driven a genuine learning curve: Unitree cut the average selling price of its humanoid from ¥593k in 2023 to ¥168k by 2025, and its G1 now retails from roughly $13,500. Bank of America puts a pilot-stage Western humanoid at $90–100k today, with a Chinese bill of materials already near $35k and falling below $17k by 2030. Cost is no longer the moat. But the cheapness is Chinese cheapness, and that distinction, developed in §05, is where much of our thesis lives.

The humanoid cost curve is real, and bifurcated by geography
Approximate bill-of-materials per unit, full-spec humanoid, US$ thousands.
Source: Bank of America "Physical AI, part 2" (Mar 2026); McKinsey (2026); Unitree disclosures. Western figures are pilot-to-scale estimates; the Chinese curve is partly realised. Cost-down is on track in China; the non-China version of this curve is unproven.

The labour became scarce

The demand pull is structural and demographic, not a technology cycle. Warehousing turnover runs above 100% annually at large operators; manufacturing faces retirements it cannot backfill; the roles most exposed are the unsafe, dull and unfilled ones. This is why the sober institutions now carry very large numbers, though we treat them as directional, and note how much they disagree because they measure different things in different years.

SourceHeadlineHorizonWhat it measures
Morgan Stanley$5T2050Humanoid revenue TAM; >1B units. Genuinely 2025 vintage (China upgraded Jun 2026).
Citi$7T2050Humanoid market (Dec 2024).
ARK Invest~$24Tat scaleRevenue opportunity, household + manufacturing (Sep 2024, treat as aged).
Goldman Sachs$38B2035Humanoid TAM; a 6× upward revision, but dates to Jan 2024.
IFR (primary)4.66M2024 actualInstalled base of industrial robots (+9% YoY); China = 54% of installs.

We deliberately show these as a table, not a chart: putting a $38B-by-2035 estimate on the same axis as a $7T-by-2050 estimate would mislead more than it informs. The signal is not the point estimate, it is that every serious house has revised upward, and that the only genuinely current numbers (Morgan Stanley, IFR) are the largest and the hardest.

Capital followed

Funding roughly doubled in 2025 and, on the same definition, H1 2026 alone has already beaten every prior full year. Bessemer's structural point still holds underneath the surge: over five years only 42 robotics companies raised $30M+ rounds against 745 software companies, this is a category catching up from under-investment, not a bubble inflating from over-investment. The caveat is definitional, and we flag it wherever it matters: "robotics" (narrow) and "physical AI" (broad) differ by roughly 2×.

Robotics venture funding is inflecting
Global robotics VC, US$ billions. Narrow definition (Crunchbase); H1 2026 is a half-year figure.
Source: RRE Ventures (2024 base); Crunchbase News (Jun 2026). On Dealroom's broader "physical AI" definition, H1 2026 reads ~$55.8B. State the definition before quoting the number.

03The stack & the map

Physical AI is not the SaaS stack. Value is contested at distinct layers, each with its own bottleneck, and the same technology reads differently depending on which end-market it points at. We separate the two axes deliberately.

The horizontal layers (where the technology is built)

  • Bodies, actuators, reducers, sensors, structure, batteries. Commoditising fast; China-concentrated.
  • Brains, vision-language-action models and world models. Capital-intensive arms race.
  • Simulation & data, world models as data engines, synthetic environments, teleoperation. The scalable substrate.
  • Infrastructure & MLOps, fleet orchestration, evaluation/QA, safety validation. Defensible, software-like.

The end-markets (where the technology is sold)

Each is a different application of the same stack, with a different buyer, form factor, unit economics, security profile and regulatory regime, and therefore a different verdict on where value accrues. This is why the thesis fans out into eight deep-dives rather than issuing one blanket call. The two horizontal layers (foundation models, robotics infrastructure) get their own treatment; the six end-markets, defense, industrial robotics, autonomous vehicles, consumer robotics, climate & agriculture, and health / life sciences, each get theirs.

The organising claim

The master thesis supplies the lens; each deep-dive applies it and reaches a market-specific answer. When the verdicts differ, and they do, sharply, between defense and industrial, that is the framework working, not contradicting itself.

04The central mechanism

Integration versus recombination

The oldest pattern in technology economics decides this sector. When the interface between two layers is immature and messy, the integrated firm wins, because performance requires co-designing across the boundary. When the interface standardises, the stack modularises and value flows to whoever holds the scarce component. Physical AI is living through exactly that transition, in real time.

Today favours integration. The interface between a learned policy and a physical body is still bespoke. To make a robot work you tune the model to the hardware and the hardware to the model, and every hour of deployment generates data that improves your stack on your body. That is the structural advantage a first-mover like Figure genuinely holds right now: not a patent, but a compounding loop that a modular competitor cannot yet assemble.

But every force in the sector pushes the interface toward standardisation. Hardware is commoditising below $20k. Cross-embodiment transfer is working. Open-source pipelines are maturing. The moment intelligence and body decouple cleanly, the integrated player's great strength, owning everything, becomes a cost disadvantage against best-of-breed recombination, and the deployment-data moat leaks, because data collected on any body starts to benefit models on every body.

The swing variable. One measurable quantity resolves nearly every debate in this paper at once: how well intelligence transfers across robot bodies. It is not a matter of opinion, it is published, curve-fitted, and improving. So we do not pick a world. We state which world the evidence currently favours, define what we would own in each, and watch the transfer curve to know when the world is switching.
World A, Integration holds
If transfer stalls or saturates
  • Per-body deployment data stays the moat
  • Full-stack leaders (Figure, Tesla) compound their lead
  • Form factor and hardware quality matter enormously
  • Own: the integrated leaders; their captive suppliers
World B, Recombination wins
If transfer keeps improving on its curve
  • Best model + commoditised body + integrator beats the monolith
  • Value migrates to the intelligence layer and to scarce components
  • Data moats weaken; first-mover advantage has a shelf life
  • Own: the model layer's durable niches; the supply chain

The sharpest near-term version of World B is not exotic. It is best-in-class model + commoditised body + systems integrator, a Physical Intelligence-class brain, which already runs across many platforms, dropped onto a body that costs a fraction of a bespoke Western one. The much-discussed "a frontier lab buys a model company and plugs it into someone else's hardware" scenario is one instance of this. Notably, it does not require Tesla to do anything out of character: Tesla will never outsource the brain, because the brain is its thesis, which is also why Tesla's intelligence problem and its manufacturing strength are not easily combined with anyone else's opposite profile.

Orien's reading, July 2026

The evidence tilts toward World B on a multi-year horizon, three scaling laws in nine months is a strong signal, but the security overlay in §05 slows the switch precisely in the West's highest-value markets. So the honest synthesis: the largest single outcomes will still be full-stack, and we own the leaders where we can; but the better risk-adjusted entries sit in the layers that win in both worlds, the intelligence layer's durable niches, and the physical supply chain that every body needs regardless of who wins.

05The security & supply-chain overlay

The recombination story has a hole in it, and closing the hole is where a lot of our thesis lives. "Commoditised body" quietly assumes the body is a neutral commodity. It is not. A robot is a sensing-and-data platform, cameras, microphones, LIDAR, edge compute, connectivity, and in the West, data-exfiltration and IP concerns attach to any such platform, across every vertical, not just defense.

Decompose the body

The resolution is to stop treating "the body" as one thing. A robot is muscles-and-skeleton (actuators, reducers, screws, structure), a nervous system (sensors, edge compute, connectivity), and a brain (the model). The security concern lives almost entirely in the nervous system and the brain, the parts that perceive and transmit. The cost, and China's dominance, lives in the muscles.

So the only version of a modular robot that survives a Western high-value deployment is: trusted model + Western-controlled sensing / compute / connectivity + allied-or-reviewed actuation. You may buy the muscles wherever is cheapest and allied; you cannot let the eyes and the radio be adversary-controlled. That does two things. It narrows the modular challenger's cost advantage, because the security-sensitive sensing layer is exactly the part you must rebuild rather than buy cheaply. And it makes the security overlay a friction on unbundling, one that bites hardest in the most valuable markets, extending the full-stack incumbent's runway in the West beyond what the raw technology curve implies.

The dependency is quantified, and uncomfortable

This is not a hypothetical. Actuation, the muscles, is over half the bill of materials and the hardest thing to source outside China, and the single cleanest statistic in the sector is McKinsey's: building Tesla's Optimus without Chinese suppliers costs roughly three times more, with the bill of materials rising from about $46k to about $131k.

China's grip on the physical layer
Estimated Chinese share of the humanoid component supply chain, by category (%).
Source: McKinsey (2026); CSIS on rare-earth processing. Magnets and rare earths are the tightest chokepoint, and, as it happens, the layer where allied capacity is scaling fastest.
The cost of building China-free
Approximate humanoid bill of materials, with vs. without Chinese suppliers (US$ thousands).
Source: McKinsey (2026), Tesla Optimus basis. This ~3× penalty is simultaneously the hardest constraint on Western scaling and the clearest investment opening beneath it.

Two supply chains, and the geography of unbundling

Put security and cost together and the market does not resolve into one global commoditised hardware layer. It splits into two parallel chains: Chinese bodies for China, the Global South, and cost-tolerant, low-sensitivity uses; allied bodies for the West and for anything security-sensitive. That means unbundling proceeds at different speeds in different places, fast where buyers are relaxed about provenance (open-field agriculture, domestic Chinese deployment), slow where they are not (Western defense, in-home consumer, IP-rich factories). Which is why the allied supply chain, actuators, reducers, ball and roller screws, tactile sensors, and the rare-earth magnets beneath them, is a first-class theme rather than a sidebar. The magnet layer is already capitalising fast (MP Materials, Vulcan Elements, rare-earth-free Niron); reducers, screws and frameless motors remain far thinner ex-China, and that gap is the opportunity.

Policy note

The American Security Robotics Act (Cotton–Schumer, introduced March 2026, not yet enacted) is procurement protectionism modelled on the drone precedent, not a safety mandate, it belongs to this overlay, and it points the same direction: in the West, provenance will be priced.

06Humanoids: the case study

Humanoids are where the framework is easiest to see, and where the popular debate is most confused. The popular debate is about form factor, bipeds versus wheels versus specialised arms. We think the swing variable demotes that debate to a second-order question.

Why form factor matters less than everyone thinks. If intelligence transfers across bodies, and it does, then the value does not accrue to whoever guessed the right body. It accrues to whoever accumulates the most useful deployment data and the best model, on any body. Cross-embodiment results mean data collected on an arm improves a humanoid; a form-factor bet is no longer a bet-the-company decision, because the intelligence survives the hardware generation. That is why we read the shipment data below as a story about manufacturing and supply chain, not about who picked the winning shape.

Who actually shipped humanoids in 2025
Units shipped, by manufacturer and country. Total ≈ 13,000–18,000 (Omdia: 13,318, +~480% YoY).
Source: Bessemer (Apr 2026); Omdia / IDC. Western platforms shipped ~150 units each; Unitree and AgiBot shipped 5,000+ each. Western factory capacity (Figure BotQ 12k/yr, Agility RoboFab 10k/yr, Tesla 1M/yr) is announced, not realised.

Why humanoids exist at all, the honest case. A purpose-built machine beats a humanoid on any single task's ROI. The humanoid's argument is not per-task efficiency; it is flexibility-weighted return. A humanoid at 80–90% of a specialist's productivity across twenty tasks can beat twenty specialists, because capital amortises across applications, changeover cost falls toward zero, and one platform is maintained instead of fifteen. For the right operator, mixed tasks, brownfield facility, acute labour shortage, sacrificing 10–20% task efficiency to buy that flexibility and those fleet-level economies of scale is rational. So the answer is not "humanoids or specialists." It is coexistence: specialists win high-volume narrow tasks; humanoids win the larger mixed-task, brownfield, labour-substitution universe. The form is second-order; the intelligence and the economics are first-order.

07Subsector verdicts

The framework applied across the eight subsectors. Each row is the headline; each has its own deep-dive that reruns the full analysis. The verdicts differ on purpose, the buyer, the security profile and the unit economics change the answer.

SubsectorBuyer pays forWhere value accruesOrien stance
Foundation modelsGeneralisationA few names + scarce data; hard to enter lateSelective
Robotics infrastructureReliability, uptime, complianceWorkflow lock-in; software-like marginsConviction
Component supply chainTrusted, scaled actuationPhysical, capital-intensive moats; allied scarcityConviction
Industrial / warehouseUnit economics, ROIApplied autonomy, RaaS; proprietary task dataConviction
DefenseCapability / missionFull-stack platforms; first $50B+ IPOsPerformance-first
Autonomous vehiclesSafety at scaleFleet data + capital; near-consolidatedContingent
Consumer roboticsTrust, price, safetyLatest, most privacy-bound; teleop todayContingent
Climate & agricultureCost per acre / outputPurpose-built ROI; cost-tolerant on provenanceSelective
Health / life sciencesOutcomes, regulationHigh-value, regulation-gated; slow but stickySelective
Deep-dives

Each subsector has its own deep-dive that reruns this framework end to end. The four live now are below; the remaining four are in progress.

Note the shape of the table: our two conviction calls are the layers that win in both worlds of §04, infrastructure and the supply chain, plus applied autonomy, which pays for itself today. Defense is the deliberate exception to every unit-economics rule in the document, because its buyer is.

08What breaks the thesis

The four risks we take most seriously. Each is a place the compass could be pointing wrong, and each maps to something we can watch.

The reliability gap may not close on schedule

Narrow, structured tasks already reach production-grade reliability, Amazon's Vulcan picking is above 99%, DYNA folded 200,000+ towels at 99.4% over a 24-hour continuous run. But general, long-horizon, open-world tasks are nowhere close, and the last stretch from 80% to 99.9% is non-linear, Bessemer's view is that it needs fundamentally different approaches, not just more data. The most credible 2026 counter-evidence is Physical Intelligence's π*0.6, whose on-robot reinforcement learning cut failure rates by more than half and ran a coffee station for an 18-hour day. The gap is closing in narrow domains via a real method; it is not closing broadly.

The reliability gap is task-shaped, not uniform
Reported task success rates, 2026. The dashed line is the ~99.9% unattended-production threshold.
Source: Epoch AI, Where Autonomy Works (2026); company disclosures. Production reliability exists today for narrow tasks; general reliability is a 2027+ question. Every 2026 "deployment" still carries human oversight or teleoperation fallback.

Edge inference economics are unproven

A language model serves many users from one data-centre pipeline; a robot must generate world-state every few milliseconds, on its own body, on battery. Whether per-robot inference cost follows the ~1,000×-in-three-years curve that LLM serving did is genuinely unresolved, and it swings long-run gross margins, especially in consumer. The favourable signs are real (NVIDIA's Jetson Thor puts data-centre-class compute at 40–130W for $3,499; small on-device models like SmolVLA run on a laptop; dual-system architectures split a slow cloud brain from a fast on-body controller). But there is no demonstrated cost-decline curve yet. This is the clearest open economic risk in the stack, and a differentiation axis for whoever solves it.

The soft-body wall, and liability

Robots are good at rigid bodies and bad at deformable ones, cloth, cables, food, tissue. Precision insertion collapses to ~50% success; the physics of soft-material contact is computationally brutal. Whoever cracks real-time soft-body manipulation unlocks healthcare, agriculture and domestic robotics. Separately, because learned policies are probabilistic, no one can yet mathematically certify what a robot will do in an edge case, and, as our regulatory work found, no standard yet exists to certify a non-deterministic learned policy. The firm that turns physical-AI safety into an auditable, insurable artifact becomes a gatekeeper; until then, liability is an unpriced overhang.

Capital intensity and the China cut-off

Hardware-heavy companies return to the capital markets repeatedly and dilute early investors; a heavy-hardware bet for an independent fund is often a trap unless the path to a low bill of materials is clear. And the supply-chain dependency runs both ways: the same Chinese components that make bodies cheap can be export-controlled, as the 2025 rare-earth and magnet restrictions showed when they visibly hampered Optimus. Both risks argue for the same posture, favour the layers where intelligence scales faster than capex, and treat allied supply as a feature, not a cost.

09The signpost dashboard

This is the living part. Each row is a dated, falsifiable claim whose movement tells us which world we are in. We update the "current reading" every review; when a reading flips, the thesis above changes with it.

SignpostPoints to World A (integration)Points to World B (recombination)Reading · Jul 2026
Cross-embodiment transferCurve saturates; transfer plateausLog-linear scaling continuesWorld B still improving; no saturation at 20k hrs
Third-party model licensingOEMs keep models in-houseOEMs license external brains at scaleMixed BD×Gemini yes; Figure went in-house
A modular combo wins bigIntegrated players win the marquee dealsModel+body+integrator takes a major deploymentNot yet integrated leaders still winning
Unattended reliabilityStuck at demo-grade broadly99.9% reached beyond narrow tasksWorld A narrow-only; no MTBF disclosed
Western BoM cost-downStays $50k+; China-free penalty holdsApproaches $20–30k at Western scaleWorld A ~$90–100k pilot; 3× penalty intact
Allied component supplyRemains China-bound; no ex-China scaleAllied actuation/magnets reach volumeEarly magnets scaling; reducers/screws thin
Safety-validation regimeNo certifiable standard; liability overhangStandards + tooling create a real layerInflecting Machinery Reg 2027; NVIDIA Halos live
Net reading

The science points to World B; the economics and security of the West still sit in World A. That tension is the investable moment: it is why we can own full-stack leaders and the supply chain beneath them at the same time without contradiction, and why the review cadence matters more than the point-in-time call.

10Method & sources

Data current as of 23 July 2026. Figures are sourced to public material; where a widely-cited number is stale (Goldman 2024, ARK 2024, Citi 2024), we date-stamp it rather than present it as current. Funding totals are definition-sensitive, we state "narrow" (Crunchbase robotics) or "broad" (Dealroom physical AI) at the point of use. This paper draws on Orien's earlier internal research but contains no confidential information on any private company; all company facts are re-sourced to public disclosures, filings, and reporting.

Primary & research: NVIDIA GEAR, EgoScale (arXiv:2602.16710); Physical Intelligence & Georgia Tech, Emergence of Human-to-Robot Transfer (2025); Embodiment Scaling Laws (CoRL 2025); Open X-Embodiment / RT-X (2023); Google DeepMind RT-2 & Gemini Robotics 1.5; Meta V-JEPA 2; Physical Intelligence π*0.6 / RECAP; Epoch AI, Where Autonomy Works (2026); the World Action Models survey (arXiv:2605.12090).

Market & industry: Bessemer, Robotics and Physical AI (Apr 2026); Morgan Stanley Humanoid BluePaper (2024) & $5T update (2025–26); Citi, Embodied Intelligence (Dec 2025); ARK Big Ideas 2025; RRE Ventures, Physical AI Parts I–II (2025); Bank of America, Physical AI part 2 (Mar 2026); McKinsey humanoid supply-chain (2026); CSIS rare-earth analyses (2025–26); IFR World Robotics 2025; Crunchbase & Dealroom funding data (2026); Omdia / IDC shipment data.

Regulatory: EU AI Act (Reg. 2024/1689) & Digital Omnibus (Jun 2026); EU Machinery Regulation 2023/1230; ISO 10218:2025, ISO 25785-1 (draft); NVIDIA Halos (Jun 2026); American Security Robotics Act (Mar 2026).