Submarine Cable First Report and Order
The FCC modernizes and streamlines submarine cable landing-license rules while adopting new presumptions, certifications, reporting duties, and restrictions aimed at foreign-adversary and national-security risks.
What it does The Report and Order updates rules for submarine cable licensing, ownership, applications, transfers, renewals, capacity reporting, and license revocation or termination. It adopts Commerce-aligned definitions of “foreign adversary” and entities owned by, controlled by, or subject to a foreign adversary. New applicants can be presumptively disqualified if they meet those criteria, appear on the FCC Covered List, or have relevant prior FCC authorization denials or revocations. The FCC also presumptively disqualifies new cable landings in foreign-adversary countries, restricts certain IRUs and capacity leases involving foreign-adversary entities’ submarine line terminal equipment, requires cybersecurity and physical-security certifications, and establishes a Foreign Adversary Annual Report. The accompanying Further Notice seeks comment on licensing SLTE owners and operators and additional trusted-technology measures.
Who it affects Cable landing-license applicants, licensees, capacity holders, SLTE owners and operators, service providers, and entities with qualifying ownership or control interests are affected. The rules specifically identify risks associated with China Mobile USA, China Telecom Americas, China Unicom Americas, Pacific Networks, and ComNet, among others.
Why it matters This is the FCC’s first comprehensive submarine-cable rule update since 2001 and links cable licensing more directly to the Covered List, Commerce’s ICTS framework, and Team Telecom review.
Key dates and numbers
- Adopted August 7, 2025; released August 13, 2025.
- Initial comments are due 30 days after Federal Register publication; replies 60 days after publication.
- The FCC retains a 25-year license term, a 5% licensee threshold for certain owners, and a 10% reportable-interest threshold.
- Character presumptions generally examine conduct during the preceding 20 years.