FCC Proposes Rules to Block Risky Foreign Telecom Gear
Published Date: 12/4/2025
Proposed Rule
Summary
The FCC is tightening rules to keep our communications gear safe from national security risks. Companies making or selling certain equipment will face clearer rules and stronger checks, especially about parts and marketing. Comments on these changes are open until early 2026, so businesses should get ready for possible new costs and steps to follow.
Analyzed Economic Effects
8 provisions identified: 0 benefits, 8 costs, 0 mixed.
SDoC Authorization Blocked for Covered Entities
The FCC requires that no communications equipment produced by entities on the Covered List can obtain authorization through the Supplier's Declaration of Conformity (SDoC). Such equipment must instead go through the certification process with an application reviewed by a Telecommunication Certification Body (TCB) and include new attestations about covered status.
Modular Transmitters: Devices Blocked
The FCC clarifies that modular transmitters listed on the Covered List are covered equipment, and it prohibits authorization of any device that includes a modular transmitter if that transmitter would itself be covered equipment.
Possible Ban on Other Component Parts
The FCC is seeking comment on whether to prohibit authorization of equipment that includes other component parts (beyond modular transmitters) — for example, logic-bearing hardware, firmware, software, semiconductors, GPS/timing modules, and optical transceivers — especially if produced by entities on the Covered List or by persons owned/controlled by a foreign adversary. The FCC asks for estimates on transition periods (examples given: 6 months, 12 months) and on supply-chain costs and availability of replacements.
Stricter TCB and Test-Lab Recognition Rules
The FCC adopted a prohibition on recognizing any Telecommunication Certification Body (TCB), test lab, or laboratory accreditation body owned, controlled by, or subject to direction of a prohibited entity, and expanded reporting and certification requirements, including reporting equity or voting interests of 5% or greater and certifying non-ownership by prohibited entities. The FCC will revoke recognition for false or missing certifications.
Covered Entities Must Disclose Subsidiaries/Affiliates
The FCC requires that each entity named on the Covered List file a report with the Commission identifying its associated but unnamed entities (for example, subsidiaries and affiliates).
Certification Required for Modifications by Covered Entities
The FCC proposes to require submission of a certification for any equipment modification or permissive change sought by an entity identified on the Covered List (for example, class II permissive changes such as software changes or internal circuitry modifications could require certification).
New Definition of 'Critical Infrastructure'
To address a court remand, the FCC proposes defining 'critical infrastructure' using the Patriot Act language: "Systems and assets, whether physical or virtual, so vital to the United States that the incapacity or destruction of such systems would have a debilitating impact on security, national economic security, national public health or safety, or a combination of those matters." This definition would exclude the FCC's prior 'connected to' language and is a precondition for review and approval of compliance plans for certain Covered List companies.
Tighter Marketing Prohibitions and Enforcement
The FCC seeks comment on clarifying what activities count as marketing of equipment and on measures to strengthen enforcement of prohibitions on marketing covered equipment. This would affect companies that advertise, sell, or otherwise market communications equipment identified as covered.
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