FCC Locks Down Undersea Internet Cables Against Global Threats
Published Date: 10/27/2025
Rule
Summary
The FCC is updating the rules for companies that own and operate submarine internet cables to better protect U.S. communications from foreign threats. These companies must now file yearly reports, prove they have strong security plans, and avoid using risky equipment. The new rules kick in on November 26, 2025, and aim to keep our underwater internet safe without adding extra paperwork.
Analyzed Economic Effects
9 provisions identified: 2 benefits, 7 costs, 0 mixed.
Foreign-Adversary Grant Bar Presumption
The FCC presumes it will not grant a cable landing application filed after November 26, 2025 by any applicant that is owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary, any entity on the FCC's Covered List, or any entity whose Commission authorization was denied or revoked on national security or law enforcement grounds (including current and future affiliates). The rule's ownership test includes a "dominant minority" threshold of 10% or greater voting or equity interest.
Presumption Against Cable Landings in Adversary Countries
The FCC presumes denial of any application filed after November 26, 2025 that seeks to land a submarine cable in a foreign adversary country, unless the applicant can overcome the presumption with clear and convincing evidence. "Foreign adversary" follows Department of Commerce definitions and currently lists specified governments and persons in 15 CFR 791.4.
20-Year Character Disqualification Presumption
The FCC presumes an applicant lacks the character qualifications to hold a cable landing license if, within the last 20 years, the applicant materially violated the Cable Landing License Act, committed national security-related violations, made materially false statements related to national security, had adjudicated findings of false statements to U.S. agencies, or materially failed to comply with license terms. Applicants can try to overcome this presumption.
Annual Foreign Adversary Reporting
If your company is a submarine cable licensee that meets the rule's foreign-adversary criteria or whose cable lands in a foreign adversary country, you must file a yearly "Foreign Adversary Annual Report" about the licensee, cable ownership, and cable operations. This rule takes effect November 26, 2025.
IRU/Lease Ban That Enables Adversary SLTE Control
Cable landing licensees are prohibited from entering new, or extending existing, IRU (Indefeasible Rights of Use) or lease arrangements that would let an entity owned or controlled by a foreign adversary install, own, or manage Submarine Line Terminal Equipment (SLTE) on a U.S. landing. This prohibition is part of the adopted rules.
Streamlined Capacity Reporting Rules
The FCC eliminates the separate Cable Operator Report and instead requires licensees and common carriers to report domestic and international cable capacity through a single Capacity Holder Report filed by each filing entity. The rules also require certain SLTE information to be included in the Capacity Holder Report.
One-Time SLTE Information Collection
The Commission adopted a one-time information collection requiring licensees to identify who owns or operates Submarine Line Terminal Equipment (SLTE) on licensed cable systems and to disclose use of Covered List equipment or services. The One-Time Information Collection is indefinitely delayed and will become effective only when the Commission publishes a Federal Register notice announcing its effective date.
Security Plan Certification Requirement
Applicants and licensees must certify they have created, updated, and implemented a cybersecurity and physical security risk management plan and will take reasonable measures to protect submarine cable systems. Applicants must also certify that the cable will not use equipment or services on the FCC's Covered List.
Limit on Landing-Station Owner Licensing
The FCC codifies that a cable landing license is required for submarine cables that lie partially outside U.S. territorial waters, and it removes the requirement that entities that solely own (but do not control) a U.S. cable landing station must be applicants or licensees. This change reduces licensing obligations for pure landing-station owners.
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Key Dates
Department and Agencies
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