What FCC filings does a broadband-only ISP have?

Mainly three: Broadband Data Collection availability data plus Form 477 subscription data twice a year (due March 1 and September 1), broadband consumer labels for every stand-alone plan, and a CALEA System Security and Integrity plan filed before service starts and updated within 90 days of changes.

Is FCC Form 477 still required in 2026?

The subscription part is. Form 477 deployment data was sunset in December 2022 and replaced by the BDC, but facilities-based providers still report broadband connections in service, filed in the BDC system on the same twice-yearly schedule. Since July 24, 2026 it uses the same broadband definition as the BDC.

Do ISPs have to file a CPNI certification?

If you provide interconnected VoIP or other telecommunications service, yes: the annual certification is due March 1. Broadband internet access alone is classified as an information service after the Sixth Circuit's January 2025 decision, so confirm with counsel whether any carrier obligations apply to your services.

Do ISPs contribute to the Universal Service Fund?

Not on broadband revenue: broadband internet access revenue is not currently in the USF contribution base. If you sell interconnected VoIP or other telecommunications, you file Form 499-A annually and usually Form 499-Q quarterly, and contribute on that revenue unless you qualify as de minimis.

Does Inerxia file FCC reports?

No. Inerxia does not prepare or submit FCC filings. It keeps the underlying data on one subscriber record, including service addresses, plans, provisioning, invoices and tickets, so subscription counts and served locations come from the same source as billing.

FCC Reporting Requirements for ISPs: A 2026 Checklist

Which FCC filings apply to an ISP?

Requirement	Who it applies to	Cadence	What you provide
Broadband Data Collection (BDC)	Facilities-based fixed and mobile broadband providers with at least one connection in service	Twice a year: Dec 31 data due March 1, June 30 data due September 1	Location-level broadband availability
Form 477 subscription data	Facilities-based broadband providers (and voice providers for voice subscriptions)	Same twice-yearly cycle, filed in the BDC system	Connections in service (subscriptions)
Broadband consumer labels	Providers of mass-market broadband internet access	Ongoing, for every stand-alone plan offered	A label at each point of sale and in customer portals
CALEA System Security and Integrity (SSI) plan	Facilities-based broadband providers and interconnected VoIP providers	Before starting service; re-file within 90 days of changes	SSI plan filed electronically in CEFS
CPNI annual certification	Telecommunications carriers and interconnected VoIP providers	Annually, due March 1 (March 2 in 2026)	Certification of CPNI compliance
FCC Form 499-A / 499-Q	Telecommunications providers, including interconnected VoIP	499-A annually (April 1, 2026); 499-Q quarterly unless de minimis	Revenues for USF and related contributions
Network outage reporting (NORS)	Wireline, cable, satellite, wireless, interconnected VoIP and SS7 providers	Per qualifying outage	Outage notifications and reports

This is orientation, not legal advice. Obligations depend on your services, your network and your state; confirm with telecom counsel, and check the FCC for changes after September 2026.

What does the Broadband Data Collection require?

Facilities-based providers of fixed or mobile broadband with one or more end-user connections in service on the “as of” date must file availability data in the BDC system twice a year. Data as of December 31 is due March 1; data as of June 30 is due September 1. The filings feed the National Broadband Map, and BEAD performance testing samples from the locations in them.

Availability is reported per location, keyed to the FCC's Broadband Serviceable Location Fabric. That makes the quality of your service-address records the real work behind a clean filing: every served address needs to map to a Fabric location, with the technology and speeds you actually deliver there.

Is Form 477 still required?

Partly. The FCC sunset Form 477 deployment data in December 2022, when the BDC replaced it. Form 477 subscription data — the number of broadband connections in service, and voice subscriptions for voice providers — is still collected, and it is filed in the BDC system on the same schedule.

An FCC order effective July 24, 2026 aligned the two collections further: Form 477 now uses the same definition of broadband as the BDC, so the connections you count for subscriptions match the service you report as available.

What about broadband consumer labels?

Every provider of mass-market broadband must display a broadband consumer label for each stand-alone plan it offers: price and fees, typical speeds and latency, data allowance, contract terms and policy links. The compliance deadlines passed in 2024, and the FCC adopted simplifying changes in July 2026, most of which are still awaiting an effective date. The details are in our guide to FCC broadband labels.

What does CALEA require from an ISP?

The FCC applies the Communications Assistance for Law Enforcement Act to facilities-based broadband internet access providers and interconnected VoIP providers, and since 2006 it has required them to file a System Security and Integrity (SSI) plan, just as telecommunications carriers do. In practice: your network must be able to support lawful intercept requests, and the SSI plan must be on file before you start offering service.

The SSI plan describes how you comply and who the FCC and FBI should contact. It is filed electronically in the CALEA Electronic Filing System (CEFS), required since June 29, 2023, and you must re-file a complete updated plan within 90 days of any change to the information in it.

What changes if you also sell voice?

Many ISPs bundle phone service, often as interconnected VoIP. That brings in obligations a broadband-only provider generally does not have:

CPNI certification: Telecommunications carriers and interconnected VoIP providers must file an annual certification with the FCC Enforcement Bureau that they protect customer proprietary network information. It is due March 1 each year; in 2026 it was March 2 because March 1 fell on a Sunday.
FCC Form 499: Providers of telecommunications, including interconnected VoIP, file Form 499-A each year (due April 1, 2026) and Form 499-Q each quarter unless de minimis. VoIP providers have no exemption from registering and filing the 499-A. Broadband internet access revenue itself is not currently assessed for USF.
Outage reporting: Interconnected VoIP is among the services that must report qualifying outages in the FCC's Network Outage Reporting System (NORS). NORS reporting does not currently extend to broadband internet access networks.

Why the split? In January 2025 the Sixth Circuit held in Ohio Telecom Association v. FCC that broadband internet access is an information service, not a telecommunications service, which vacated the FCC's 2024 order that had reclassified it. Rules written for telecommunications carriers therefore attach to your voice service rather than to broadband alone.

What does the filing calendar look like?

1.February 1, May 1, August 1, November 1 — Form 499-Q, if you file quarterly.
2.March 1 — BDC and Form 477 subscription data as of December 31; CPNI certification if you sell voice.
3.April 1 — Form 499-A annual revenue report, if you provide telecommunications or interconnected VoIP.
4.September 1 — BDC and Form 477 subscription data as of June 30.
5.Ongoing — broadband labels for every plan, SSI plan updates within 90 days of changes, outage reports as they occur.

Check	Why it matters
Every served address maps to an FCC Fabric location BDC availability is reported per location.	BDC availability is reported per location.
Subscription counts come from the same record as billing Form 477 connections should match who you actually bill.	Form 477 connections should match who you actually bill.
Each plan you sell has a current label Labels are required at every point of sale.	Labels are required at every point of sale.
Your SSI plan reflects current contacts and network Changes must be re-filed within 90 days.	Changes must be re-filed within 90 days.
Voice-related filings sit on the same calendar CPNI, 499 and NORS apply once you sell interconnected VoIP.	CPNI, 499 and NORS apply once you sell interconnected VoIP.

Where does Inerxia fit?

Inerxia does not file FCC reports for you. What it does is keep the data those filings draw on in one subscriber record: service addresses, plans, provisioning and equipment, invoices and tickets. When the subscriber count, the served addresses and the plans all come from the same place as billing, the twice-yearly filings stop being a reconciliation exercise.

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Sources

Checked September 24, 2026. Not legal advice; confirm your obligations with telecom counsel.

FCC reporting requirements for ISPs What the FCC expects from an ISP, and when.