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The Federal Communications Commission (FCC) has mandated that all digital mobile service providers subject to FCC Rule 20.19, including mobile virtual network operators (MVNOs) and resellers, file the annual Hearing Aid Compatibility (HAC) Certification (Form 855) by January 31, 2026. The certification requires providers to confirm their compliance with HAC rules, report any non-compliance, and disclose the percentage of HAC-compliant handsets offered during the covered period (January 1, 2025 – December 31, 2025).
Who Must File & How
FCC Form 855 applies to all digital mobile service providers, including MVNOs, resellers, and providers offering only eSIM-based services. According to FCC specialists, all wireless service providers—regardless of whether they offer handsets—must file FCC Form 855. The FCC has clarified:
"Section 20.19(e)(1)(i) states that service providers that offer two or fewer handsets in an air interface in the U.S. are exempt from the requirements of this section in connection with that air interface, except with regard to the reporting requirements in paragraph (i). Section (i) addresses reporting requirements for all service providers, including MVNOs. The two sections read together require all service providers to file FCC Form 855, even if the service provider did not offer any handset models during the reporting period."
The filing requires service providers to:
- Certify compliance with HAC requirements for the covered calendar year.
- Report on the percentage of HAC-compliant handsets offered during the year.
- Explain any instances of non-compliance and the corrective actions taken.
- Provide a link to their publicly accessible HAC webpage with handset details.
- For providers that did not offer any physical handsets during the reporting period (including E-SIM-only providers), you should check 'yes' for the first question in the de minimis section and enter zero for the percentage question.
The certification must be filed electronically via the FCC's Form 855 online portal by February 2, 2026 (the deadline has been extended to Monday, February 2 because January 31 falls on a Saturday). Failure to comply can result in FCC enforcement actions and penalties.
If you have any questions regarding your filing obligations, require clarification on how to complete the form, or need assistance with FCC Form 855 compliance, please contact your assigned attorney immediately. Our team is available to guide you through the filing process and ensure compliance with FCC regulations before the deadline.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
