On 8 January 2026 the US Federal Communications Commission (FCC) released FCC-CIRC2601-02 under GN Docket No. 25-166, entitled "Protecting Communications Networks Through Enhanced Transparency of Foreign Adversary Control". The new rules address the national security risks posed by FCC licences and authorisations held by entities controlled by foreign adversaries.

Core requirements

The rules require holders of a broad range of licences, authorisations and approvals to report whether they are owned or controlled by, or subject to the jurisdiction or direction of, a foreign adversary, and if so to disclose additional information about that control. Based on factors such as national security risk and reporting burden, the FCC will divide the relevant authorisations into Category A, B and C lists and establish a single reporting process.

Reporting framework

Category A: higher-risk authorisations whose holders must report whether they are subject to foreign adversary control.

Category B: holders must report only if they are subject to foreign adversary control.

Category C: holders are exempt from the initial reporting obligation, generally covering authorisations with lower risk or sufficient existing regulatory coverage.

Scope

The rules cover a wide range of communication services and facilities, including wireless services (particularly geographic 4G and 5G broadband licences), satellite earth station and space station authorisations, broadcast licences, submarine cable landing licences, domestic and international Section 214 authorisations, direct access number authorisations for VoIP, equipment certification, data network identification codes, international signalling point codes and recognised operating agencies.

Implementation and enforcement

The FCC will establish a single Foreign Adversary Control System (FACS) to receive filings. Most regulated entities must file within 60 days of the announcement launching the FACS, with 120 days for small entities. The FCC Enforcement Bureau and the relevant bureaus and offices will take enforcement action against violations, including streamlined licence revocation procedures where consistent with the law. The FCC leadership was to discuss and vote on the draft at an open meeting on 29 January 2026; if adopted, the report and order proceeds to final rule drafting and publication.