Welcome to our monthly update on significant FCC actions and filing deadlines. The FCC continues to repeal outdated rules and adopt new rules to protect national security. The FCC is also focused on modernizing the telecommunications relay service to reflect current technology. New and proposed rules may significantly affect your business. Please let us know if you want additional details about compliance requirements or would like to file comments on proposed rules to protect and promote your company’s interests.

Latest Signals from the FCC

FCC November 20, 2025 Open Meeting

The following items were approved at the November Open Commission Meeting:

Freeing Up Large Swath of Upper C-band Frequencies – This NPRM  explores options for reconfiguring the Upper C-band (3.98 GHz to 4.2 GHz) in the contiguous United States. The Notice seeks comment on a range of issues associated with repurposing some portion of the Upper C-band, including reallocation of the 4.0–4.2 GHz band, competitive bidding procedures for an eventual auction, licensing, operating, and technical rules for any new wireless services, transitioning incumbent FSS operations, and promoting co-existence with adjacent band radio altimeters. Comments are due January 5, 2026; reply comments are due February 3, 2026. 

Modernizing Telecommunications Relay Services – This NPRM initiates a proceeding to modernize telecommunications relay services (TRS). It seeks  comment on terminating the mandatory status of TTY-based relay service for state-based TRS programs, facilitating the transition of analog TRS users to Internet-based forms of TRS, recognizing IP Speech to Speech Relay Service as a compensable form of TRS, exploring certifying a national analog relay provider, streamlining TRS provider certification and data collection processes, updating or eliminating obsolete rules, and closing an outdated docket. Comments are due 30 days after publication in the Federal Register; reply comments are due 30 days later.  

Delete, Delete, Delete – This Direct Final Rule moves to delete approximately 21 rules and requirements that have sunset by operation of law, govern an expired event, regulate an obsolete technology, are no longer used in practice by the FCC or licensees, or are otherwise duplicative, outdated, or unnecessary. Comments are due 20 days after publication in the Federal Register. 

Protecting the Nation’s Communications Systems from Cybersecurity Threats – This Order on Reconsideration advances an agile and collaborative approach to protecting the nation from cyberattacks by rescinding an unlawful and ineffective January 2025 Declaratory Ruling and NPRM. 

Upcoming Filing Requirements

Revisions to November 3, 2025, Form 499-Q Quarterly Telecommunications Reporting Worksheet (December 18, 2025)

• Who: Carriers and providers of interstate and international telecommunications that seek to revise their November 3, 2025, Form 499-Q filing

• How: Submit the form electronically through USAC’s E-File system, available at https://forms.universalservice.org/portal/login.

Quarterly Section 1.767(I) Submarine Cable License Reports (December 29, 2025)

• Who: Submarine cable licensees that (i) are, or are affiliated with, carriers with market power in any of the submarine cable licensee’s WTO Member destination countries, such as those licensees identified as being dominant along certain routes in their grants of cable landing authority; and (ii) have sought streamlined processing of a cable landing license

• What: Required to file a provisioning and maintenance report and a circuit status report within 90 days from the end of the preceding calendar quarter pursuant to section 1.767 of the Commission’s rules.

• How: File in International Communications Filing System (ICFS)

Quarterly Sec. 63.10(c) Dominant International Carrier Reports (December 29, 2025)

• Who: International telecommunications service providers that are classified as dominant along routes to one or more destination markets

• What: Required to submit (i) a quarterly international traffic and revenue report and (ii) a quarterly provisioning and maintenance report.  These reports are due within 90 days from the end of the preceding calendar quarter.

  • Facilities-based international telecommunications service providers that are classified as dominant also are required to file a quarterly circuit status report.  This report is due within 90 days from the end of the preceding calendar quarter.

• How: File in International Communications Filing System (ICFS)

FCC Form 855 (February 2, 2025)

• Who: Service providers who offer handset models for sale or use in the United States are required to annually file this form.

• What: Commission requires wireless service providers to file FCC Form 855 certifications to ensure compliance with the Commission’s wireless hearing aid compatibility rules.

  • The FCC Form 855 certification filing window will open Friday, January 2, 2026 and close on Monday, February 2, 2026)

• How: https://apps.fcc.gov/cores/userLogin.do

FCC and Telecom: Next Transmissions

On December 18, the Commission will tentatively consider the following items at its Open Meeting:

Updating Rules to Curb Robocallers’ Access to Phone Numbers – The Commission will consider a Third Report and Order and Third Further Notice of Proposed Rulemaking to strengthen and modernize the Commission's requirements applicable to all providers of Voice over Internet Protocol service authorized to have direct access to telephone numbers and to protect consumers from illegal robocalling. In the Report and Order, the Commission would require existing authorization holders to file updated robocall-related and other certifications regarding compliance with Commission rules and to file ownership and control information. In the NPRM, the Commission would seek comment on ways to further bolster numbering resource protections as bad actors continue to seek new and creative methods for exploiting consumers and causing harm. 

Advancement of the Low Power Television, TV Translator and Class A Television Service – The Commission will consider a Report and Order amending its rules to provide regulatory certainty and clarity to LPTV broadcasters and reflect changes in the broadcast industry since the establishment of the LPTV service. 

Delete, Delete, Delete – The Commission will consider a Direct Final Rule that would continue the Commission’s efforts to modernize its regulatory framework by eliminating approximately 35 obsolete, outdated, and unnecessary rules from Parts 2, 15, and 18, totaling 11,970 words or approximately 25 pages of the Code of Federal Regulations.

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