On April 10, 2026, the Federal Communications Commission (FCC or Commission) published a Report and Order (Order) in the Federal Register that categorizes virtually all entities holding FCC licenses and authorizations “based on risk to national security” and subjects them to varying attestation and disclosure requirements. Accordingly, the Order will take effect on June 9, 2026.
As we discussed in greater detail here, the new rules adopted in the Order consider an entity to be under “Foreign Adversary Control” if it is “owned by, controlled by, or subject to the jurisdiction or direction of” a “foreign adversary,” with “ownership” defined to include voting or equity interests as low as 10%. If an entity certifies that it is subject to Foreign Adversary Control, the Order requires that it disclose all equity and/or voting interest holders who directly or indirectly hold a 5% or greater interest, among other required information. The Order also establishes ongoing reporting
