The FCC has recently released Public Notices reminding providers of their obligations regarding annual filing requirements related to Customer Proprietary Network Information (CPNI) and Supply Chain equipment. Please note the following:
CPNI Annual Certification Filing
* On February 14, 2025, the FCC’s Enforcement Bureau issued a Public Notice reminding telecommunications carriers and interconnected VoIP providers of their obligation to file their annual compliance certification related to CPNI. Part 64 of the FCC’s rules requires providers to file the annual certification by March 1 of each year, however, since March 1, 2025 falls on a Saturday, this year’s certification is due on March 3, 2025. Per the Public Notice the Commission’s rules seek to ensure that CPNI is protected from unauthorized access, use, or disclosure. Providers that fail to comply with the CPNI rules, including the annual certification requirement, may be subject to enforcement action including monetary penalties.
* The CPNI rules require providers to establish and maintain systems designed to protect their subscribers’ CPNI. Further, the rules also require providers to obtain customer approval to use, disclose, or allow access to their CPNI and providers must apprise customers of their right to restrict access to their CPNI. In addition, providers must take reasonable steps to discover and protect against unauthorized access and must notify law enforcement and affected customers of any breach of CPNI. Finally, the rules require providers to file an annual certification of their compliance with the rules as well any complaints or problems that have occurred during the period from the last compliance filing.
* The annual certification filing must include a compliance certificate signed by an Officer of the Company, a statement by the Officer that he or she has personal knowledge that the Company has established procedures that ensure compliance with the CPNI rules, and a written statement explaining how the Company’s procedures ensure compliance with the CPNI rules. In addition, the annual filing must include an explanation of any actions taken against data brokers and a summary of all consumer complaints received in the prior year related to unauthorized access to CPNI. The Enforcement Bureau Public Notice includes a suggested template for the annual filing as well as filing instructions.
Supply Chain Annual Report
* The FCC issued a Public Notice on February 18, 2025, reminding providers of advanced communications services that the filing deadline for the Supply Chain Annual Report is March 31, 2025. The Commission has defined advanced communication service as high-speed, switched, broadband telecommunications capability that enables users to originate and receive high quality voice, data, graphics, and video telecommunications using any technology with connection speeds of 200 kbps in either direction.
* Section 5 of the Secure and Trusted Communications Act of 2019 directed the Commission to require providers to report annually and certify whether they had purchased or otherwise obtained communications equipment and services from certain vendors identified on the Covered List. The initial Covered List of equipment, software, or service providers was created in March, 2021. Subsequently, additional equipment and services providers have been added to the Covered List most recently in July, 2023. The Public Notice advises providers that the Covered List (https://www.fcc.gov/supplychain/coveredlist) is subject to change and it is the responsibility of providers to be aware of further notices announcing changes to the Covered list.
* Any provider that reported in their 2023 annual filing that it had purchased or otherwise obtained equipment and services from an entity on the Covered List or obtained equipment or services from such entity during 2024 must submit an annual report on or before March 31, 2025 providing information as of December 31, 2024. A provider that has previously certified that it does not have any covered equipment and is not receiving services from an entity on the Covered List does not need to file a report on March 31, 2025 unless they purchased equipment and/or services from an entity on the Covered List at some point during 2024. Additional information regarding the Covered List and filing instructions is available on the FCC’s website.
If ICORE can be of assistance to your Company regarding these filing requirements, please contact Chris Ulmer at 610-928-3903 or at culmer@icorellc.com .
