FCC Adopts New Foreign Adversary Attestation and Disclosure Rules Impacting Satellite Operators and Submarine Cable Landing Licensee

By Kathryne C. Dickerson and Liam F. Fulling, National Law Review
February 9, 2026

On Jan. 30, 2026, the Federal Communications Commission (FCC or Commission) released a Report and Order (Order) introducing new “Foreign Adversary Control” attestation and disclosure (reporting) requirements for virtually all FCC licensees and authorization holders.

As a result, regulated entities must now determine (and report) whether they are subject to “Foreign Adversary Control,” defined as being “owned by, controlled by, or subject to the jurisdiction or direction of” a “Foreign Adversary” (which, to date, includes China, Cuba, Iran, North Korea, Russia, and Venezuelan politician Nicolás Maduro). For purposes of that determination, “ownership” is defined to include voting or equity interests of 10% or greater. If an entity certifies that it is subject to Foreign Adversary Control, it must disclose (among other required information) all equity and/or voting interests that hold, either directly or indirectly, a 5% or greater interest.

The Order establishes three categories of authorization holders “based on risk to national security” with attestation and disclosure requirements varying based on the category. Satellite, earth station, and submarine cable landing licensees and authorization holders are placed in the highest category, reflecting a “heightened” national security risk, because “any exploitation of such [entities] could directly compromise the integrity of the nation’s communications networks.” As a result, satellite, earth station, and submarine cable landing licensees and authorization holders will be required to make an initial attestation by a to-be-determined deadline, along with new attestations in certain circumstances.

These measures reflect the FCC’s ongoing efforts to address perceived threats foreign adversaries pose and align with broader federal government initiatives to secure critical infrastructure.

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