What's New in Wireless - November 2025

The wireless industry has revolutionized the way we connect, from facilitating teleworking, distance learning, and telemedicine to allowing the American public to interact virtually in almost all other aspects of their daily lives.  Leading policymakers – federal regulators and legislators – are making it a top priority to ensure that the wireless industry has the tools and resources it needs to keep pace with this evolving landscape.  This blog provides monthly updates on actions by federal regulatory bodies responsible for communications policy and Congressional efforts to support wireless connectivity.  And this month we highlight several actions taken by the FCC, despite the government shutdown, to secure the U.S. communications supply chain.

Regulatory Actions and Initiatives 

Wireless Networks, Equipment, and Infrastructure

The FCC Takes Several Actions to Secure U.S. Communications Networks.  On October 28, 2025, the FCC adopted a Second Report and Order and Second Further Notice of Proposed Rulemaking that proposes changes to the Commission’s Covered List of communications equipment and services that have been deemed to pose a risk to national security, thereby potentially constraining the U.S. communications supply chain.  In particular, the FCC clarifies that covered equipment includes modular transmitters and, therefore, prohibits the authorization of modular transmitters and devices that include modular transmitters.  In the accompanying Second Further Notice, the Commission seeks comment on whether to extend this prohibition to other component parts produced by entities on the Covered List – including, for example, semiconductors, firmware, software, and logic-bearing hardware like GPS and timing modules or optical transceivers – and, if so, how an expanded prohibition would impact the supply chain for those component parts.  The Commission further seeks comment on ways to strengthen the enforcement of its marketing and importation rules against covered equipment, including by asking whether additional parties, such as online resellers, should be held responsible for ensuring compliance with the rules and, if so, how these parties should be informed of new additions to the Covered List and other equipment authorization restrictions.  Comments and replies are due 30 and 45 days, respectively, after the Second Further Notice is published in the Federal Register. 

In the wake of releasing the draft version of the Second Report and Order and Second Further Notice, the FCC also issued an Advisory reminding the public about the equipment and services currently on the Covered List.  Because the FCC’s Covered List determinations also apply to subsidiaries and affiliates, the Advisory further includes two appendices.  Appendix A includes a list of subsidiaries and affiliates that entities named on the Covered List have identified to the Commission in various filings as producing covered communications equipment and services.  And Appendix B includes entities identified by Zhejiang Dahua Technology Co., Ltd. (“Dahua”) as its subsidiaries and affiliates.

In addition, FCC Chairman Carr announced that the Commission has worked with several leading e-commerce sites to remove several million listings of covered equipment, such as certain Huawei smart watches and Dahua home security cameras.  The Commission also obtained new commitments from those e-commerce sites to both adopt additional best practices and coordinate with the FCC to monitor and prevent the unlawful online sale of Covered List equipment.

Finally, the FCC’s Office of Engineering and Technology (“OET”) initiated proceedings to withdraw the following entities’ recognition as accredited test laboratories:  Chongqing Academy of Information and Communications; CVC Testing and Technology Co., Ltd.; CVC Testing Shenzhen Co., Ltd.; TUV Rheinland-CCIC Ningbo Co., Ltd.; and Telecommunications Technology Labs.  In each Order, OET concluded that each entity failed to demonstrate why OET should not begin proceedings to withdraw that entity’s recognition as an accredited test lab.  The Orders appear to rely on each entity’s admitted level of ownership, control, or direction by the People’s Republic of China as the basis for this conclusion.  Each entity has until November 28, 2025, to file a response demonstrating why the FCC should not withdraw recognition.

Spectrum

The FCC Proposes Changes to Millimeter Wave Spectrum.  In addition to the Second Report and Order and Second Further Notice discussed above, the Commission adopted a Notice of Proposed Rulemaking (“NPRM”) that seeks comment on a range of proposals to facilitate more intensive use of the Upper Microwave Flexible Use Service (“UMFUS”) bands, including the 24 GHz, 28 GHz, upper 37 GHz, 39 GHz, 47 GHz, and 50 GHz bands, which are currently used for commercial mobile wireless services.  The NPRM, however, seeks comment on facilitating greater use of the spectrum for satellite services on a shared basis, including by (i) allowing UMFUS licensees and Fixed Satellite Service operators to enter into agreements, (ii) revising the protection criteria and coordination requirements for earth stations, and (iii) permitting alternatives to the current “first-in-time” licensing framework.  The NPRM also seeks input on streamlining the earth station application process by reducing or eliminating certain technical demonstrations, adopting safe harbor or de minimis exceptions, and employing database-driven automated interference analyses. Comments and replies are due 30 and 60 days, respectively, after the NPRM is published in the Federal Register.

The FCC Proposes Deleting Several Wireless Rules.  Finally, the Commission adopted a Direct Final Rule that seeks to delete hundreds of rules governing wireless services.  The Commission finds that these rules are outdated, duplicative, or unnecessary in light of other Commission rules.  Comments on the Direct Final Rule are due 20 days after Federal Register publication.

Legislative Efforts

The Senate Passes a Bill That Would Require the FCC to Publish a List of Licensees That are Linked to Foreign Adversaries.  On October 23, 2025, the Senate passed the Foreign Adversary Communications Transparency Act, which, if enacted, would require the FCC to publish a list of companies that both hold FCC licenses or authorizations and are owned by foreign adversarial governments, including the governments of China, Russia, Iran, and North Korea.  The bill is now in the House. 

Subscribe To Viewpoints