FCC Enhances Equipment Authorization Integrity and Security

Approximately a year ago, the FCC initiated a Notice of Proposed Rule-making on the integrity and security of its equipment authorization program. 

Building upon this, the FCC released a Report and Order and Further Notice of Proposed Rule-making on May 1, 2025, that will be addressed at the May 2025 Open Commission meeting on May 22, 2025. These actions signal potentially significant upcoming changes to equipment authorization processes in the United States.

The FCC will adopt rules through this Report and Order to bolster the integrity of entities involved in the Commission’s equipment authorization program.

Key aspects of the Report and Order:

• Prohibition of Entities: The FCC will prohibit the recognition of, and withdraw existing recognition from, Telecommunications Certification Bodies (TCBs) or test laboratories owned or controlled by a "prohibited entity."
• Definition of "Prohibited Entity": This term will encompass any entity identified on various government lists related to national security threats. These lists include, but are not limited to, the FCC Covered List, the Department of Defense Chinese Military Company List, and the Executive Branch’s list of "foreign adversaries."
• Ownership and Control Reporting: The FCC will implement reporting and certification requirements to facilitate the determination of ownership and control of relevant entities.
• Subsidiary and Affiliate Information: Any entity specifically named on the Covered List will be required to provide information regarding all of its subsidiaries and affiliates.
• Strengthening TCBs and Test Labs: Several additional rules will be adopted to enhance the integrity of TCBs, test laboratories, and laboratory accreditation bodies.

Key aspects of the Further Notice of Proposed Rule-making:

• Expansion of Prohibitions: The FCC seeks comments on whether to extend the newly adopted prohibitions to entities under the jurisdiction of a foreign adversary. It also seeks input on expanding the definition of "prohibited entities" to include additional lists from federal agencies or statutes.
• Encouraging Domestic and Allied Testing: The FCC requests further comment on methods to facilitate and encourage more equipment authorization testing to be conducted at test laboratories located within the United States or in allied countries.
• TCB Post-Market Surveillance: The FCC proposes revisions to TCB post-market surveillance procedures.
• TCB-Test Lab Relationships: The FCC proposes to restrict relationships between TCBs and the test laboratories for which the TCB reviews applications.
• Accredited Labs for Supplier's Declaration of Conformity: The FCC proposes to mandate the use of FCC-recognized accredited test laboratories for authorizations based on a Supplier’s Declaration of Conformity.

References:

• https://www.fcc.gov/May2025
• https://www.fcc.gov/document/safeguarding-equipment-authorization-process-bad-labs
• https://www.fcc.gov/document/fcc-proposes-national-security-protections-equipment-program-0
• https://docs.fcc.gov/public/attachments/DOC-411202A1.pdf
• https://www.emcrules.com/2024/05/fcc-vote-on-bad-labs-ban-proposal.html

Europe Radio Equipment Cybersecurity update

On January 30, 2025, EN 18031-1, -2 and -3 were listed in the Official Journal of the European Union thus now harmonized to give "presumption of conformity" with the essential requirements set out under articles 3.3 d, e, and f, of the Radio Equipment Directive, however with some conditions and limitations.

These standards where originally released on September 2, 2024.

EN 18031-1:2024 (Common security requirements for radio equipment - Part 1: Internet connected radio equipment)

EN 18031-2:2024 (Common security requirements for radio equipment - Part 2: radio equipment processing data, namely Internet connected radio equipment, childcare radio equipment, toys radio equipment and wearable radio equipment)

EN 18031-3:2024 (Common security requirements for radio equipment - Part 3: Internet connected radio equipment processing virtual money or monetary value)

It's important to note that these are framework standards defining common security requirements and assessment methods, not test standards.

 REF:

 Commission Delegated Regulation (EU) 2022/30

Document 32025D0138 

 

FCC requirements to protect the nation’s networks and supply chains from certain equipment

August 28, 2024 - FCC publishes a revision to Knowledge Database (KDB) document titled “Protecting Against National Security Threats to the Communications Supply Chain through the Equipment Authorization Program.” The document provides staff-level authorization guidance on how FCC 22-84 affects the equipment authorization process.

Changes include adding new guidance item 2a, “How should TCBs address applications for authorization of equipment that includes cybersecurity and anti-virus software produced or provided by Kaspersky Lab, Inc. or any of its successors and assignees?” as well as removing obsolete data from the introduction, and adding clarifying language to item 1.a.ii.

Ref:

KDB 986446 D01 Covered Equipment Guidance v03

FCC Amends Equipment Authorization Program

FCC - Validation of test sites for radiated emission testing

Posted Aug. 22, 2024, a Petition for Rule-Making requesting to incorporate the newly adopted ANSI/USEMCSC C63.25.2-2024 standard, rules for the validation of test sites used for radiated emission testing between 30 MHz and 1 GHz., into FCC Title 47 Part 2 and Part 15.

The C63.25 standard series will consolidate site validation methods into a standard series for reference from within various test method standards (i.e. C63.4, C63.10 etc.). The series addresses the appropriate and required site validation for sites used when performing tests related to the applicable frequency range of measurement.

C63.25.1 - Validation Methods for Radiated Emission Test Sites, 1 GHz to 18 GHz

C63.25.2 - Validation Methods for Radiated Emission Test Sites, 30 MHz to 1 GHz

C63.25.3 - Validation Methods for Radiated Emission Test Sites, 18-40 GHz

The content of C63.25.2 consists of the traditional normalized site attenuation methods used for years and the addition of two new methods, a site comparison method (SCM) and delta NSA (DNSA) method. For more information and details on the new methods see reference below or obtain a copy of C63.25.2.

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Ref:

https://www.fcc.gov/ecfs/search/search-filings/filing/108210752429140

Citizens Broadband Radio Service Rules FCC Seeks Comment on Updates

On August 16, 2024, the FCC issued a Notice of Proposed Rule-making and Declaratory Ruling, allowing for a 30-day comment period following publication in the federal register.

This NPRM reflects the Commission's ongoing dedication to developing spectrum sharing models that create opportunities for expanded use of the airwaves, aligning with the recent comprehensive government approach to spectrum policy. 

The FCC is working in conjunction with federal partners to explore the next generation of spectrum sharing models and aims to uphold and improve the Citizens Broadband Radio Service, the only band where a sharing model allows licensed non-federal users and federal operators to coexist within the same geographic areas.

The topics covered in the notice include Federal Protection and Coordination, CBSD Information, Out of Band Emissions Limits, Base Station (CBSD) and End User Device (UE) Power, SAS Connectivity and/or Outages, Time Division Duplex (TDD) Synchronization (in-band and adjacent band), FSS Protection, Grandfathered Wireless Broadband Licensees, Certified Professional Installation, Private Networks and Low Power Indoor Facilities, and GAA User Coexistence.

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Ref:

NPRM GN DocketNo. 17-258

Statement of Commissioner Geoffrey Starks

Statement of Commissioner Anna Gomez

 

 

 

 

 

 

 

 

Request to reconfigure the 902-928 MHz band

August 6, 2024 -  FCC releases public notice related to a petition for rule making from NextNav to reconfigure the 902-928 MHz band allocations.

The public notice is an invitation for comment on NextNav’s petition for changes to spectrum allocation within the LMS bands (Location and Monitoring Service). The LMS bands exist between 902 to 928 MHz. For more specific details see §90.353

The 902 to 928 MHz band is relatively crowded, used by Government Radio location, fixed and mobile radio-location, LMS, Amateur radio 33-cm and a significant number of unlicensed Part 15 devices.

 Being that Part 15 devices are unlicensed, they don’t generally receive interference protection from incumbents, and must operate without interference to incumbents of the spectrum (i.e. licensed spectrum holders). However, under §90.353(d) an LMS license will be conditioned upon the licensee’s ability to demonstrate their systems do not cause unacceptable levels of interference to Part 15 devices, and properly certified unlicensed devices are insulated from claims of interference to M-LMS systems.

Band plan: a) current, b) current showing NextNav holdings (NN) and c) proposed.

Current state:

“Amateur radio operations are allocated on a secondary basis to LMS. Part 15 unlicensed devices also operate in the band, are not typically afforded interference protection, and may not cause harmful interference to LMS licensees, amateur operations, or other licensed systems. However, Commission rules intended to ensure coexistence between services require M-LMS licensees to demonstrate through field tests that their systems do not cause unacceptable levels of interference to part 15 devices.”

“Also, users of part 15 devices conforming to specified technical conditions under a safe harbor rule are insulated from claims in the band that they cause harmful interference to M-LMS systems.”

 

Proposed changes:

“NextNav indicates that it will work with all the incumbents in the band, including federal (radio-location, fixed, and mobile), ISM, non-M-LMS, amateur, and unlicensed part 15 device users, and suggests that the Commission could place conditions on a newly issued NextNav license to ensure protection” (proposes a rule generally requiring interference protection to primary incumbents) (i.e. not part 15 devices)

“The Petition recognizes that there currently are unlicensed part 15 devices operating in the Lower 900 MHz Band, but it is unclear regarding the extent to which the proposed reconfiguration would impact potentially millions of such devices. With respect to part 15 devices, NextNav states that it is completing technical analyses and “will work with unlicensed users to understand their spectrum requirements.” NextNav does, however, seek the removal of the current requirement that it not cause unacceptable levels of interference to part 15 devices”

 

Questions in the public notice:

“What services are being provided by part 15 devices and amateur operations in this band? Can they be accommodated in other spectrum bands? What are the costs for relocation and how long would it take? We also seek comment on the status of any outreach with part 15 device users and amateur licensees.”

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Ref:

Petition for Rule Making

https://nextnav.com/wp-content/uploads/2024/04/Petition-for-Rulemaking-of-NextNav-Inc.pdf

FCC Public Notice – comments due Sept. 5, 2024

https://docs.fcc.gov/public/attachments/DA-24-776A1.pdf

Historical

WT Docket No.06-49; FCC 14-79

FCC Decides Not to Adopt New Rules Affecting 902-928 MHz Band 

Additional information on 902-928 MHz;

Why Unlicensed Spectrum Dominates the Smart Grid

Public Safety Related Spectrum Issues in the 902-928 MHz Band

Location Service Deployment May Constrain 902-928 MHz Amateur Use