Reminder: Federal Communications Commission – March Through April 1st Filings

Each month, Kelley Drye's Communications Group offers this reminder of upcoming filing deadlines that may affect our clients and friends. Please review the deadlines below and contact us if you would like assistance or have any questions.

I. Featured Upcoming Compliance Deadlines

II. Select Ongoing Filing Requirements

I. FEATURED UPCOMING COMPLIANCE DEADLINES

The following are reminders for upcoming Federal Communications Commission ("FCC") reports and compliance requirements:

A. Revisions to February 2, 2026, Form 499-Q Quarterly Telecommunications

Reporting Worksheet (due March 19, 2026)

Carriers and providers of interstate and international telecommunications that seek to revise their February 2, 2026, Form 499-Q filing must do so within 45 days of the Form 499-Q filing deadline (which, in 2026, was February 2 because February 1 was a Sunday).

As a reminder, Form 499-Q filers are required to submit the form electronically through USAC's E-File system, available at https://www.usac.org/service-providers/.

B. Supply Chain Annual Reporting (due March 31, 2026)

Pursuant to Section 5 of the Secure and Trusted Communications Networks Act of 2019 and §1.50007 of the Commission's rules, providers of advanced communications service are required to submit their annual Supply Chain Annual Report (unless exempted as described below). In this submission, due by March 31, 2026, for information as of December 31, 2025, providers must report and certify whether they have purchased, rented, leased, or otherwise obtained any covered communications equipment or service on the list of covered communications equipment and services (the "Covered List") on or after August 14, 2018. Providers with such covered communications equipment or service must submit information annually "including the type, location, date purchased, rented, leased or otherwise obtained, and any removal and replacement plans." (47 C.F.R. § 1.50007). Filings are required from:

• Providers that reported and certified such covered communications equipment and/or services in 2025; and
• Providers reporting the presence of newly obtained covered equipment or services (since their last report).

Providers that do not have any covered communications equipment or services are only required to submit an initial report and certification. Therefore, aprovider that made, or relied upon, such a certification for the 2025 report and that still has no covered communications equipment or services (as currently included in the Covered List) is not required to make a filing this year.

Providers are reminded that the Covered List is subject to change. Should the Commission subsequently add equipment and/or services to the Covered List (as it did in March 2022, September 2022, July 2024 and December 2025 (updated Jan. 2026)), providers with such equipment or services must report on these within 60 days of the change to the Covered List.

Instructions for the submissions, access to the filing portal, and more extensive materials regarding the Supply Chain Annual Reporting requirement are located at https://www.fcc.gov/supplychain.

C. Quarterly Sec. 63.10(c) Dominant International Carrier Reports (due March 31, 2026)

• International telecommunications service providers that are classified as dominant are required to submit (i) a quarterly international traffic and revenue report and (ii) a quarterly provisioning and maintenance report. These reports are due within 90 days from the end of the preceding calendar quarter.
• Facilities-based international telecommunications service providers that are classified as dominant also are required to file a quarterly circuit status report. This report is due within 90 days from the end of the preceding calendar quarter (i.e., March 31, 2026).

D. Quarterly Section 1.767(l) Submarine Cable Licensee Reports (due March 31, 2026)

Submarine cable licensees that are, or are affiliated with, carriers with market power in any of the submarine cable's destination countries are required to file a provisioning and maintenance report and a circuit status report within 90 days from the end of the preceding calendar quarter (i.e., March 31, 2026).

E. Submarine Cable Circuit Capacity Holder Report (due March 31, 2026)

Each year the FCC collects data regarding capacity held on international submarine cable facilities by cable landing licensees and common carriers. In a 2025 report and order revising the regulatory framework for submarine cable licensees, the FCC adopted changes to the traditional pair of circuit capacity reports, eliminating the Cable Operator Report and consolidating reporting obligations into the Capacity Holder Report. As explained in a February 27, 2026, Public Notice, cable landing licensees and common carriers that hold capacity on the U.S. end of submarine cable systems between the United States and foreign points, as of December 31, 2025, must report available capacity held via cable ownership, indefeasible right of use, or inter-carrier lease on the U.S. end of such systems.

The circuit capacity report is due March 31, 2026, and must be submitted via the online filing portal. Filers should be sure to review the FCC's updated Section 43.82 filing manual for further details regarding the reports.

F. Form 499-A Annual Telecommunications Reporting Worksheet (due April 1, 2026)

All intrastate, interstate, and international providers of telecommunications within the United States, including, but not limited to, telecommunications common carriers, inter connected VoIP providers, telecommunications providers that provide services on a non-common carrier basis, and payphone providers that are aggregators are required to file FCC Form 499-A with the Universal Service Administrative Company ("USAC") each year with limited exceptions. In addition, non-interconnected VoIP providers with interstate end-user revenues subject to Telecommunications Relay Service ("TRS") contributions must file the Form 499-A to report the revenues.

The Form 499-A is used to determine a company's required contribution to the Universal Service Fund ("USF"), as well as to the Local Number Portability Administration ("LNPA"), North American Numbering Plan Administration ("NANPA") and TRS funds. The Form 499-A is also the basis for a carrier's annual FCC regulatory fee (i.e., the Interstate Telecommunications Service Provider ("ITSP") Fee). For new providers, the Form 499-A also serves as a carrier's FCC registration.

The Form 499-A worksheet, reporting CY 2025 revenues, must be filed by April 1, 2026. Filers are required to submit the Form 499-A electronically through USAC's available at https://www.usac.org/service-providers/. Additional guidance is available in the FCC's December 16, 2025, release of the 2026 Form 499-A and associated 2026 Form 499-A Instructions.

G. Accessibility Recordkeeping Compliance and Contact Information Reporting Requirement (due April 1, 2026)

Telecommunications service providers, providers of advanced communications services ("ACS") like electronic messaging, in-app voice calls and video conferencing, interconnected VoIP providers (collectively, "service providers") and equipment manufacturers, subject to sections 255, 716, or 718 of the Communications Act (as amended by the Twenty-First Century Communications and Video Accessibility Act ("CVAA")) are required to comply, subject to certain exceptions, with recordkeeping requirements to demonstrate that services and equipment are accessible by individuals with disabilities.

Service providers, providers of ACS, and equipment manufacturers must submit an annual certification that records are being kept in accordance with the rules. The certification must state that the service provider or manufacturer has established operating procedures to ensure compliance with the recordkeeping requirements and that records are being kept accordingly. An authorized officer with personal knowledge of the representations in the certification must submit an affidavit or declaration, executed under penalty of perjury, verifying the truth and accuracy of the certification. The certification also must include contact information for the person(s) responsible for resolving consumer complaints and the agent designated for service of formal and informal complaints.

The certification must be submitted by April 1, 2026 utilizing the Federal Communications Commission's online filing system which can be found at https://apps.fcc.gov/rccci-registry/. Additional guidance for filers is available here.

II. SELECT ONGOING FILING REQUIREMENTS

Pro Forma Assignments and Transfers

Assignments of Authorization and Transfers of Control can be filed either as pro forma applications or non-pro forma applications.

A pro forma assignment or transfer is one in which the form of ownership changes but actual control of the license remains with the same entity or person. Most pro forma assignments and transfers may be approved under streamlined Forbearance procedures in the case of most telecommunications carriers (e.g., Section 214 authorization holders, wireless licensees (excluding those with installment payment or designated entity issues) and earth station licensees). Unlike non-pro forma assignments and transfers of control, where there is a substantial change in direct or indirect ownership or control, i.e., a de jure or de facto change introducing a new party or person with a controlling interest, requests regarding pro forma changes where the ultimate control and ownership remains the samedo not require prior FCC approval provided that the parties notify the FCC of the change within 30 days. Note that private licenses are not subject to forbearance such that FCC advance approval generally is required for pro forma transfers and assignments of private licenses.

Additional Requirements for International Section 214 and Subsea Cable Landing License Applications for Authority or Involving Substantive Assignments, Transfers of Control, or Modifications of such Authority, and for Section 310(b) Petitions

Pursuant to an August, 2024, Public Notice, additional requirements are now in effect for all applications for international Section 214 authorizations and submarine cable landing licenses as well as any applications for assignment, transfer of control or modification, in connection with such authorizations and licenses, where applicants have direct or indirect foreign ownership above threshold levels (generally 10% or more equity or voting interests, or based upon other FCC-recognized indicia of control). The requirements also apply to petitions for declaratory ruling related to foreign ownership under section 310(b) of the Communications Act. Parties making such filings must submit responses to a set of "Standard Questions" to the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (the "Committee") prior to, or concurrent with, filing their application with the FCC and also must submit a copy of their FCC application to the Committee within three business days after filing. Additional information and the Standard Questions (which vary by category of applicant) are available on the Office of International Affairs ("OIA") dedicated webpage.

Additionally, specified certifications and point of contact information must now be included in all applications involving international Section 214 authorizations or submarine cable landing licenses (regardless of ownership) as well as petitions for declaratory ruling relating to foreign ownership. Details for this required content are available at the OIA dedicated webpage.

Change in FCC Form 499 Filer Information

Filers must update their registration information, including a DC Agent for Service of Process in accordance with these instructions to the FCC Form 499-A. Filers must file updated information within one week of the contact information change. Filers wishing to update Preparer information, headquarters address, billing contact information, or DC Agent for Service of Process, can submit either an FCC Form 499-A or an FCC Form 499-Q or, for billing-related matters only, email USAC's billing department. Filers wishing to update any other information must submit a revised FCC Form 499-A. For more information, see https://www.usac.org/service-providers/contributing-to-the-usf/making-revisions/.

Filers that cease providing telecommunications must deactivate their Filer ID with USAC by submitting a letter with termination date and information on their successor entity to USAC. Filers must also update their CORES ID information with the Commission

Filers must file within 30 days of the date that the company ceases to provide telecommunications service or telecommunications.

FCC: https://apps.fcc.gov/cores/userLogin.do

USAC: www.usac.org/service-providers/contributing-to-the-usf/manage-your-499-id

Change in Robocall Mitigation Plans

Voice service providers, gateway providers, and non-gateway intermediate providers are required under the FCC's Caller ID Authentication rules (47 C.F.R. § 64.6300 et sec.) to implement an appropriate robocall mitigation program and remit information about that program in the FCC's Robocall Mitigation Database ("RMD"). Providers are required to update their filings in the RMD within 10 business days of any change to the information provided, including the following:

• Certification as to the implementation of STIR/SHAKEN in the provider's network;
• The extension(s) that apply to the provider's implementation of the STIR/SHAKEN framework;
• The specific reasonable steps the provider has taken to avoid originating, carrying, or processing illegal robocall traffic as part of a robocall mitigation program;
• The provider's commitment to respond to all traceback requests and law enforcement requests for information on illegal robocalling; and
• The provider's business name, d/b/a name(s), former name(s), its legal address and contact information for one person within the company responsible for addressing robocall mitigation-related issues.

Companies now have an obligation to re-certify their RMD filings annually by March 1 of each year. Additionally, companies must update their information in the CORES database within 10 business days of any changes.

The link for remitting the required RMD filing is available here.

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.