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 The FCC continues to repeal outdated rules and adopt new rules to streamline its regulatory processes and protect national security by limiting participation of foreign adversaries in the U.S.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 and October agendas include 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 September 30, 2025 Open Meeting

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

Accelerating Wireline Infrastructure Buildout – This Notice of Inquiry examines whether state and local statutes, regulations, and legal requirements have an unlawful prohibitive effect or create excessive burdens on deployment of wireline telecommunications infrastructure. Key areas for comment include delays, fees, and procedural obstacles in using public rights of way and whether such rules may effectively block service deployment in violation of Section 253 of the Communications Act. Comments are due November 17, 2025; reply comments are due December 17, 2025.

Freeing Wireless Infrastructure from Unlawful Regulatory Burdens – This Notice of Proposed Rulemaking (NPRM) is aimed at reducing state and local regulatory constraints on wireless infrastructure deployment. Among the issues for public comment are the definition of “concealment elements,” the role of artificial intelligence in wireless deployment, and potential processes to resolve permitting disputes more rapidly. Comments are due 30 days after publication in the Federal Register and reply comments are due 15 days later.

Phone Jamming Solutions in Non-Federal Correctional Facilities – This NPRM explores regulatory pathways for non-federal deployment of jamming or mitigation solutions in correctional facilities. The proposal considers licensing overlay structures, leasing frameworks, and technical/operational safeguards to ensure such deployments comply with Section 333. Comments are due 30 days after publication in the Federal Register and Reply Comments are due 15 days later.

Modernizing Broadcast Ownership Rules – As part of its quadrennial review, the Commission launched this NPRM to reconsider its broadcast ownership rules. This NPRM seeks comment on whether to retain, modify, or eliminate the Local radio Ownership Rule, the Local Television Ownership Rule, and the Dual Network Rule in light of changing media market dynamics (including streaming, consolidation, and digital platforms). Comments are due 30 days after publication in the Federal Register and reply comments are due 30 days later.

Deleting Obsolete and Duplicative Wireline Rules – This Direct Final Rule removes nearly 400 wireline-related rules and requirements that are considered obsolete, duplicative, or no longer in use. The Direct Final Rule proceeds without full notice and comment under the “Delete, Delete, Delete” initiative, though a 20-day window for comment is provided. Absent adverse comment, the rules will be automatically repealed. Comments are due 20 days after publication in the Federal Register.

Modernizing the E-Rate Program for Schools and Libraries – This Declaratory Ruling clarifies that Wi-Fi (or similar access point technologies) on school buses is ineligible for E-Rate support.

Addressing the Homework Gap through the E-Rate Program – This Order on Reconsideration holds that off-campus Wi-Fi hotspots (for use by students or library patrons) are ineligible for E-Rate support. 

October Filing Requirements

911 Annual Reliability Certifications

• Who: Covered 911 service providers (as defined in Commission Rule 9.19(a)(4)). Covered providers include entities that provide 911 capabilities directly to public safety answering points or emergency authorities.
• What: Must certify annually regarding compliance with the requirement to take reasonable measures to provide reliable 911 service with respect to: (i) 911 circuit diversity; (ii) central office backup power; and (iii) diverse network monitoring.
• When: October 15, 2025.
  • If the government is still shutdown: The FCC has waived the filing deadline until the day after the FCC resumes full operations.
• How: Commission’s online portal.

FCC and Telecom: Next Transmissions

On October 28, the Commission will tentatively consider the following items at its Open Meeting:

Space Modernization for the 21st Century – The Commission will consider a NPRM that would propose overhauling 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 would propose replacing part 25 with a new rule part—part 100—that would create a “licensing assembly line” to process applications. This matter and the following one are part of the Commission’s “Space Month” agenda which is aimed at strengthening the space economy, in part, through streamlined licensing requirements. 

Upper Microwave Flexible Use Service – The Commission will consider a NPRM that solicits 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). 

Protecting Against National Security Threats to the Communications Supply Chain through the Equipment Authorization Program – The Commission will consider a Report and Order and NPRM to take the next important steps in modifying the equipment authorization program to protect United States networks and communications supply chain against national security threats.

Fifth Next Gen TV Further Notice – The Commission will consider a FNPRM that 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.

IP Interconnection – The Commission will consider a NPRM that would examine the interconnection requirements imposed on incumbent local exchange carriers, and seek 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.

Empowering Broadband Consumers Through Transparency – The Commission will consider a FNPRM that would propose to eliminate certain broadband label requirements and seek comment on other ways to streamline the broadband label rules to reduce compliance burdens while preserving their consumer benefit. 

Improving Verification and Presentation of Caller Identification Information – The Commission will consider a FNPRM and Public Notice that would propose to give consumers accurate caller name and other information to help them better understand who is calling and whether to answer the call; propose to simplify, streamline, or eliminate outdated robocalls requirements; and provide notice that the Commission intends to dismiss certain older petitions for reconsideration and applications for review related to the Telephone Consumer Protection Act. 

Incarcerated Persons Calling Services – The Commission will consider a Report and Order, Order on Reconsideration, and NPRM that would establish new interim audio and video IPCS rate caps and correctional facilities rate additives for correctional facility cost recovery, and seek comment on establishing permanent rate caps, permanent rate additives, and continued prohibitions on site commissions and separate ancillary service charges.

Deleting Obsolete and Duplicative Wireless Rules – The Commission will consider as part of the Delete, Delete, Delete proceeding a Direct Final Rule that would move to delete approximately 400 primarily wireless-related 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. 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. 

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