The FCC released a Small Entity Compliance Guide to assist small businesses, providers, and other entities with understanding and complying with the January 2026 Foreign Adversary Control Report and Order, which adopted new attestation and disclosure requirements for or holders of, and applicants for, Commission-granted licenses, leases, authorizations, grants, permits, and other approval to improve the FCC’s ability to assess foreign adversary control.
The compliance guide provides an overview of the objectives of the new rules, new compliance requirements, and new recordkeeping and reporting requirements of the new attestation and disclosure requirements for all FCC Regulatees. Importantly, it provides definitions for the key terms of the rules, information on the three new Covered Authorization categories, an overview of the attestations required under the new rules, and the procedures for non-compliance.
The compliance guide further explains that the new rules codified at 47 CFR § 1.80001 to 47 CFR § 1.80004, except for the new rules at 47 CFR § 1.80003, became effective June 9, 2026. The new rules at 47 CFR § 1.80003 and amendments to 47 CFR § 73.1212(j)(8) require approval from the Office of Management and Budget (OMB).
