Wireless Roundup (February 2026)

Key Wireless Deadlines

Reply Comments Due for Equipment Authorization/Covered List FNPRM: On October 29, the Federal Communications Commission (FCC or Commission) released a Further Notice of Proposed Rulemaking (FNPRM) as part of its ongoing efforts to implement the Secure Networks Act passed in March 2020. The FNPRM seeks comment on what components, if installed in a device, could lead to the same unacceptable risk as covered equipment. The FNPRM also asks for comment on the definition of "critical infrastructure" as used in the Covered List, as well as comment generally on whether to revise the Commission's marketing and importation rules, which could have effects well beyond the FCC's Covered List. Reply Comments are due February 2.

Reply Comments Due for Making Additional Frequency Bands Eligible for Use by NGSO Satellites with ESIMs: In a December 10, 2025 Public Notice, the FCC invited new comments on whether to permit non-geostationary orbit (NGSO) satellite systems to communicate with Earth Stations in Motion (ESIMs) in the 28.35–28.6 GHz band. The call for a refreshed record comes more than five years after the Commission first proposed similar changes in a 2020 FNPRM. Reply Comments are due February 5.

FCC Issues Proposal to Implement Spectrum Allocation Decisions from WRC-2019: On December 9, 2025, the FCC released a Notice of Proposed Rulemaking (NPRM) to implement certain spectrum allocation decisions made at the 2019 World Radiocommunication Conference (WRC-2019) and published in the International Telecommunication Union's WRC-2019 Final Acts. The proposal will modify some spectrum allocations and power limits for both satellite and terrestrial services. Comments are due February 13. Reply Comments are due March 13.

Reply Comments Due for Upper C-Band Spectrum Auction: On November 20, the Commission adopted an NPRM to reconfigure and auction up to 180 megahertz of Upper C-band spectrum (between 3.98 and 4.2 GHz) for terrestrial wireless services. The proposed auction fulfills a statutory mandate in the "One Big Beautiful Bill Act" to free up at least 100 megahertz of Upper C-band spectrum by July 2027. The NPRM proposes bidding procedures and licensing, operating, and technical rules that draw heavily from the Lower C-band auction conducted from 2020 to 2021. Reply Comments are due February 18.

Reply Comments Due for FCC Proposal to Overhaul and Modernize Part 25 Satellite Rules with New Part 100 Replacement: On October 28, the FCC adopted an NPRM that proposes replacing existing satellite communications rules in part 25 of the Commission's rules with an entirely new part 100. The proposal would consolidate and reorganize existing rules, delete unnecessary or outdated ones, and introduce new frameworks meant to streamline the licensing processes for satellites and earth stations. Reply Comments are due February 18.

Reply Comments Due for Enabling More Intensive Use of 24+ GHz Bands Shared between UMFUS and FSS: On October 28, the FCC adopted an NPRM that proposes comprehensive reforms to siting rules for earth stations in the Upper Microwave Flexible Use Service (UMFUS) bands. The proposal also calls for input on how the Commission can encourage more intensive use of the UMFUS bands, which are shared between terrestrial and Fixed Satellite Service (FSS) operators. Reply Comments are due February 18.

Upcoming Meetings and Events

• FCC Open Meeting: The next FCC Open Meeting is scheduled for February 18. Meeting details can be found here. The agenda includes:
• • Strengthening the Integrity of the Lifeline Program Notice of Proposed Rulemaking
  • Maximizing the Potential of the 900 MHz Band Report and Order
  • Proposing Application Limit in Upcoming NCE Reserved Band FM Translator Filing Window Public Notice
  • Reforming Intercarrier Compensation Notice of Proposed Rulemaking
• Full Committee Executive Session: On February 3, the Senate Committee on Commerce, Science, and Transportation will convene a full committee Executive Session to discuss nominations and legislation. More information is available here.
• Brookings Institution's Fireside Chat with Commissioner Trusty: On February 4, the Center for Technology Innovation at the Brookings Institution will host a fireside chat with FCC Commissioner Olivia Trusty. More information can be found here.
• 2026 SOTN Conference: On February 9, the Internet Education Foundation will host the 22nd Annual State of the Net (SOTN) Conference in Washington, DC. Conference details can be found here.
• CPAAC Open Meeting: The Consumer Protection and Accessibility Advisory Committee (CPAAC) will hold an in-person meeting on February 24 at 9:00 a.m. in the FCC's Commission Meeting Room. Meeting details can be found here.
• FTC's 18th Annual Microeconomics Conference: The Federal Trade Commission's (FTC) Bureau of Economics and the Tobin Center for Economic Policy at Yale University will host the 18th Annual FTC Microeconomics Conference on February 24-25 in Washington, DC. Conference details can be found here.
• FTC Workshop: On February 26, the FTC will host a workshop titled "Consumer Injuries and Benefits in the Data-Driven Economy." More information can be found here.

Cyber Corner

• NIST Releases Draft Cyber AI Community Profile: On December 16, 2025, the National Institute of Standards and Technology (NIST) released for comment the preliminary draft of the Cyber Artificial Intelligence (AI) Profile. Comments were due January 30, 2026. NIST held another workshop to discuss the draft profile on January 14, 2026.
• CISA and UK NCSC Issue OT Guidance: On January 14, 2026, the Cybersecurity and Infrastructure Security Agency (CISA) and the United Kingdom (UK) National Cyber Security Centre published Secure Connectivity Principles for Operational Technology (OT).
• NIST Releases Preliminary Draft of 800-53 "Control Overlays" for AI Systems (open for comment): On January 8, 2026, NIST released an Annotated Outline of the control overlays for one of the three identified use cases (Predictive AI). The draft identifies for each proposed control overlay the relevant 800-53 control, the AI lifecycle phase, assumptions, and control tailoring, along with references to NIST's AI 100-2e2025 publication. Comments on the outline and preliminary overlay are due February 13.
• CISA Releases PQC Publication: On January 23, 2026, CISA released Product Categories for Technologies That Use PQC Standards, a listing of product categories and example products for products that support Post-Quantum Cryptography (PQC) and are "widely available." Executive Order 14306, released on June 6, required CISA to publish and update such a list to aid in PQC adoption.
• OMB Rescinds Secure Software Development Practices Attestation Form Requirement: On January 23, 2026, the Office of Management and Budget (OMB) issued M-26-05, Adopting a Risk-Based Approach to Software and Hardware Security. The memo rescinds the mandate for federal agencies to obtain from contractors an attestation of secure software development practices (as mandated by M-22-18), but permits agencies to elect to require the attestation by contract, and/or to require a software bill of materials.

Other Wireless Developments

FAA Proposes New Performance Requirements for Aircraft Radio Altimeters: On January 7, 2026, the Federal Aviation Administration (FAA) proposed new minimum performance requirements for all aircraft radio altimeters, which operate in the 4.2-4.4 GHz frequency band. The new standards are meant to ensure altimeters will continue to operate effectively once the FCC authorizes additional wireless signals in the neighboring Upper C-band. Commercial aircraft regulated under Part 121 and aircraft regulated under Part 129 with 30+ passenger seats or a payload capacity of 7,500+ pounds would need to be equipped with compliant altimeters by the date the FCC authorizes wireless services in the Upper C-band, while all other aircraft would need to comply within two years of such date. Comments are due March 9.

FCC Issues Exemptions, Clarifications for Sweeping Prohibition of Foreign-Made Drones: On January 7, 2026, the FCC issued two exemptions to the sweeping listing the Commission issued in December 2025 that effectively prohibited any foreign-produced uncrewed aircraft system (UAS) or foreign-produced UAS critical component part from receiving an FCC equipment authorization. The first exemption applies to UAS and UAS critical components that appear on the Defense Contract Management Agency's Blue UAS list. The second exemption applies to UAS and UAS critical components that quality as "domestic end products" under the "Buy American Standard." Both exemptions apply only through January 1, 2027, though they could be renewed in the future. The FCC also released additional compliance resources that include a fact sheet with a list of answers to frequently asked questions and a guidance document on how to seek "conditional approval" for products or classes of products. More details are available in this Wiley client alert. The Commission also issued a waiver on January 21 allowing Class I permissive changes for "software and firmware updates that mitigate harm to U.S. consumers for UAS and UAS critical components authorized prior to the December 22, 2025, Covered List addition."

House E&C Subcommittee on Communications and Technology Holds FCC Oversight Hearing: On January 14, 2026, FCC Chairman Brendan Carr and Commissioners Anna Gomez and Olivia Trusty testified before the House Energy and Commerce Subcommittee on Communications and Technology.

Commission Approves Operation of Geofenced Variable Power Unlicensed Devices in 6 GHz Band: At its January 29 Open Meeting, the FCC adopted a Report and Order (R&O) that will authorize geofenced variable power (GVP) unlicensed devices to operate in the 5.925-7.125 GHz band. The R&O allows GVP devices to operate with significantly greater power than existing 6 GHz band unlicensed portable devices, but will prohibit GVP devices from operating in exclusion zones specified by a geofencing system. The Commission also issued an FNPRM seeking comment on whether to adjust the power limits managed by automated frequency coordination systems in the 6 GHz band and to allow unlicensed 6 GHz band low power indoor access points to operate on cruise ships. The R&O will be effective 60 days after publication in the Federal Register. Comments and Reply Comments on the FNPRM proposals will be due 30 days and 60 days after publication in the Federal Register, respectively.

FCC Approves Two Rulemakings Related to Foreign Adversary Control and Foreign Ownership of Licenses and Licensees: At its January 29 Open Meeting, the Commission adopted two separate Orders related to foreign control and influence over FCC-granted licenses and authorizations. The first Foreign Adversary Control Order imposes tailored attestation and disclosure requirements for three separate categories of license and authorizations "based on risk to national security of Foreign Adversary Control." The Foreign Adversary Control Order will be effective 60 days after publication in the Federal Register. The second Foreign Ownership Order codifies and clarifies the definitions underlying the foreign ownership rules and the FCC's practices for reviewing Section 310(b) petitions for declaratory ruling. The Foreign Ownership Order will be effective 30 days after publication in the Federal Register.

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