Welcome to our monthly update on significant FCC actions and filing deadlines. The FCC continues to repeal outdated rules and adopt new rules to streamline its regulatory processes and protect national security by limiting participation of foreign adversaries in the U.S. market. 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.

Government Shutdown Advisory

Due to the federal shutdown, licensing, consumer complaint response, consumer protection and other enforcement, and equipment authorization operations have been suspended at the FCC.

The FCC will continue operations necessary to protect life or property and a variety of other operations including spectrum auctions, the Supply Chain Reimbursement program, international treaty related work, certification of Universal Service Fund and Telecommunications Relay Services disbursements, and certain OIG operations. Although the FCC is currently affected by the government shutdown, its September, October, and November agendas included numerous proposed actions, making for a busy period once funding resumes.

Please see our recent Client Advisory for more specifics.

Latest Signals from the FCC

FCC October 28, 2025 Open Meeting

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

Space Modernization for the 21st Century – This NPRM proposes an overhaul of the Commission’s rules for licensing space and earth stations to increase speed, predictability, and flexibility in order to drive innovation and support the American space economy. The Notice proposes replacing part 25 with a new rule part—part 100—that will create a “licensing assembly line” to process applications. This matter is part of the Commission’s “Space Month” agenda which is aimed at strengthening the space economy, in part, through streamlined licensing requirements. Comments are due 45 days after publication in the Federal Register; reply comments are due 30 days later.  

Upper Microwave Flexible Use Service – This NPRM seeks comment on a variety of ways to encourage more intensive use of spectrum bands above 24 GHz that are shared between the terrestrial Upper Microwave Flexible Use Service (UMFUS) and the Fixed-Satellite Service (FSS). Comments are due 30 days after publication in the Federal Register; reply comments are due 30 days later.  

Protecting Against National Security Threats to the Communications Supply Chain through the Equipment Authorization Program  – This Report and Order and FNPRM adopts new rules to close loopholes in the FCC’s Covered List and secure America’s communications networks against devices determined to post an unacceptable risk to national security. The rulemaking notice seeks comment about certain components of covered equipment, the definition of “critical infrastructure” on the Covered List, whether a modification to an authorized device requires a new certification application, and the activities that constitute marketing equipment. Comments are due 30 days after publication in the Federal Register; reply comments are due 15 days later.  

Fifth Next Gen TV Further Notice – This FNPRM seeks comment on steps to support and accelerate the nation’s ongoing voluntary, market-based broadcast television transition to Next Gen TV by removing regulatory obstacles and giving flexibility to broadcasters. Comments are due 60 days after publication in the Federal Register; reply comments are due 30 days later.  

IP Interconnection – This NPRM examines the interconnection requirements imposed on incumbent local exchange carriers. It seeks comment on ways the Commission can facilitate a successful transition to all-IP interconnection for voice services while retaining critical oversight in areas of public safety and consumer protection. Comments are due 30 days after publication in the Federal Register; reply comments are due 30 days later.  

Empowering Broadband Consumers Through Transparency – This FNPRM proposes to eliminate certain broadband label requirements and seeks comment on other ways to streamline the broadband label rules to reduce compliance burdens while preserving their consumer benefit. Comments are due 30 days after publication in the Federal Register; reply comments are due 30 days later.  

Improving Verification and Presentation of Caller Identification Information – The FNPRM portion of this item proposes steps to ensure that providers present consumers with accurate, verified caller identity information, proposes measures to identify and combat illegal calls originating from overseas, and seeks to eliminate or modify certain Telephone Consumer Protection Act (TCPA) rules. The Public Notice portion of the item seeks to dismiss TCPA Petitions and Applications which have been pending before the Commission for an extended period of time. The deadline for responses to Public Notice is 45 days after publication in the Federal Register. Comments on the FNPRM are due 30 days after publication in the Federal Register; reply comments are due 60 days after publication in the Federal Register.  

Incarcerated Persons Calling Services – This  Report and Order, Order on Reconsideration, and NPRM establishes new interim audio and video IPCS rate caps and correctional facilities rate additives for correctional facility cost recovery, and seeks comment on establishing permanent rate caps, permanent rate additives, and continued prohibitions on site commissions and separate ancillary service charges. Comments are due 30 days after publication in the Federal Register; reply comments are due 30 days later.  

Deleting Obsolete and Duplicative Wireless Rules – In this Direct Final Rule the Commission moves to delete nearly 400 primarily wireless-related rule provisions that govern obsolete technology, are no longer used in practice, or are otherwise duplicative, outdated, or unnecessary. These rules pertain to a wide variety of now-defunct topics including regulatory reporting requirements, technology that is no longer used, and dates pertaining to transition plans, cost-sharing obligations, pilot programs, equipment requirements, and registration procedures that have long ago passed. Comments are due 20 days after publication in the Federal Register. 

Upcoming Filing Requirements 

Annual DTV Ancillary/Supplementary Services Report

• For the 12-month period ending on September 30, 2025
• Who: Commercial and noncommercial full-power TV stations, Class A TV stations, and LPTV stations (including those operating on Channel 6) that have fee-based, non-broadcast revenues from their digital transmission capabilities..
• What: If TV stations earned fees for data transmission or other non-broadcast services, they must file the report and pay the fees.
• When: December 1, 2025.
  • If the government is still shutdown: The FCC has waived the filing deadline until the day after the FCC resumes full operations.
• How: FCC’s Licensing and Management System (LMS) on Form 317.

FCC and Telecom: Next Transmissions 

On November 20, the Commission will tentatively consider the following items at its Open Meeting:

Freeing Up Large Swath of Upper C-band Frequencies – The Commission will consider a NPRM that explores options for reconfiguring the Upper C-band (3.98 GHz to 4.2 GHz) in the contiguous United States. The Notice will seek 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.

Modernizing Telecommunications Relay Services – The Commission will consider a NPRM that would initiate a proceeding to modernize telecommunications relay services (TRS). It will seek 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.

Delete, Delete, Delete – The Commission will consider as part of the Delete, Delete, Delete proceeding a Direct Final Rule that would move 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.

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

Navigating the FCC’s rules and latest moves?  Dial into our expertise and let’s discuss your next steps.