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FCC Resumes Full Operations
The Federal Communications Commission (FCC) resumed full operations on November 13, 2025, after a record-breaking 43-day government shutdown, though some databases did not fully come back online until Tuesday, November 18. For the most part, FCC deadlines landing during the shutdown were extended to November 18, with certain exceptions enumerated in this Public Notice, and we expect that additional deadlines will be set as the FCC resumes Federal Register publication on a normal schedule.
Key Wireless Deadlines
FCC Proposes to Authorize RF Jamming in Correctional Facilities: The Commission released a Notice of Proposed Rulemaking (NPRM) requesting comment on proposals to authorize, for the first time, non-federal uses of radio frequency (RF) jamming solutions to combat contraband wireless devices in correctional facilities. Comments are due December 26, 2025, and reply comments are due January 12, 2026.
FCC Requests Feedback on Eliminating ILEC Interconnection Obligations: In this NPRM, the FCC seeks comment on proposals to terminate legacy interconnection regulations as part of its effort to accelerate the transition to all-IP voice networks. In particular, the item seeks comment on: (1) a proposal to forbear from incumbent local exchange carrier (ILEC)-specific interconnection obligations and eliminate the Commission's rules implementing those provisions by December 31, 2028; (2) the impact of eliminating the ILEC-specific interconnection regulatory framework; and (3) a new regulatory framework for IP interconnection to replace the current framework under 251(c)(2). Comments are due December 26, 2025, and reply comments are due January 26, 2026.
Upcoming Meetings and Events
- FCC Open Meeting: The next FCC Open Meeting is scheduled for December 18. Meeting details can be found here. The agenda includes:
- FCC Oversight Hearing: On December 17, the Senate Committee on Commerce, Science, and Transportation will convene for a hearing to conduct oversight of the FCC. More information is available here.
Cyber Corner
- NPRM on Cybersecurity Risk Management Withdrawn: On November 20, the Commission voted to approve an Order on Reconsideration rescinding the January 2025 NPRM that proposed to require a wide variety of communications providers to adopt and certify to the FCC that they have cybersecurity and supply chain risk management plans.
- CISA 2015 Extended to January 30: The Cybersecurity Information Sharing Act of 2015 (CISA 2015) expired on September 30, 2025. The continuing resolution (CR) signed on November 12 to reopen the government includes an extension of CISA 2015 authorities until January 30, 2026.
- Telecommunications and Media Subcommittee Hearing: On December 2, the Senate Committee on Commerce, Science, and Transportation's Subcommittee on Telecommunications and Media will hold a hearing titled "Signal Under Siege: Defending America's Communications Networks." More information is available here.
Other Wireless Developments
FCC Proposes Rules for Upper C-Band Spectrum Auction: At its November 20 Open Meeting, the Commission adopted an NPRM to reconfigure and auction off up to 180 MHz of Upper C-band spectrum (between 3.98 and 4.2 gigahertz) for terrestrial wireless services. The proposed auction fulfills a statutory mandate in the One Big Beautiful Bill Act to free up at least 100 MHz of Upper C-band spectrum by July 2027. The NPRM contains bidding procedures and licensing, operating, and technical rules that draw heavily from the Lower C-band auction conducted from 2020 to 2021. Comments will be due 30 days after Federal Register publication, with reply comments due 60 days after Federal Register publication.
Commission Rescinds CALEA Declaratory Ruling: On November 20, the FCC approved an Order on Reconsideration rescinding the January 2025 Declaratory Ruling that interpreted the Communications Assistance for Law Enforcement Act (CALEA) as imposing substantive cybersecurity requirements on telecommunications carriers. The Order determined that the Declaratory Ruling was both unlawful and unnecessary on policy grounds. The FCC also rescinded an accompanying NPRM, discussed above, that was never published in the Federal Register. The item was approved by a 2-1 vote, with Commissioner Gomez dissenting.
FCC Proposes Modernization of TRS: On November 21, the FCC adopted an NPRM seeking comment on reform proposals to facilitate the transition of Telecommunications Relay Services (TRS) from legacy analog services to Internet Protocol (IP)-based alternatives. Comments will be due 30 days after Federal Register publication, with reply comments due 60 days after Federal Register publication.
Commission Approves Direct Final Rule in Delete, Delete, Delete: As a part of the Delete, Delete, Delete proceeding to modernize its regulatory framework, the FCC approved a Direct Final Rule that removes approximately 21 rules and requirements. The draft Direct Final Rule can be found here.
Supply Chain Security Equipment Authorization Final Rule to Take Effect: The Commission published a Final Rule as part of its ongoing efforts to implement the Secure Networks Act of March 2020. The Final Rule (1) clarifies that equipment listed on the Covered List includes modular transmitters; (2) prohibits authorization of devices that include covered modular transmitters, even if that equipment would not otherwise be covered; (3) establishes a procedure to allow the Office of Engineering and Technology (OET) and the Public Safety and Homeland Security Bureau (PSHSB) to limit continued marketing or importation of previously authorized covered equipment; and (4) clarifies and expands the meaning of the term "produced by," as it is used in the FCC's Covered List entries. The Final Rule will take effect December 26, 2025.
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