FCC Adopts New Submarine Cable Licensing Regime

By Sean T. Conway, Jennifer L. Richter, Sharanya Sriram, Alexandra M. Van Cleef and Jacob Nash, Akin
July 13, 2026

Overview

Submarine cable technology has advanced significantly over the past several years. The point of convergence of the optical and electrical signals for submarine cables has moved from solely beach landing points to data centers much further inland, leaving the physical connection point between the subsea and terrestrial networks more vulnerable to attack. Submarine line terminal equipment (SLTE) is the necessary technical equipment that converts optical signals carried on a submarine cable system into electrical signals, and vice-versa. SLTE plays an important role in connecting the internet’s infrastructure. Submarine cables, a critical backbone of the internet, carry the vast majority of transcontinental digital communications, including artificial intelligence (AI). SLTE owners or operators, similar to submarine cable owners, can have a significant effect on a submarine cable system, including by physically disrupting and manipulating the cables and the data carried thereon. The Federal Communications Commission (FCC or the Commission) has expressed concerns about the national security risks presented by foreign adversary entities holding ownership interests or affiliations with entities owning or operating SLTE. In its Second Report and Order released on June 25, the FCC seeks to address these national security concerns, promote the resiliency of submarine cable systems and mitigate threats from foreign adversaries. Specifically, the Second Report and Order does the following:

• Adopts rules to extend FCC oversight over SLTE, creating a blanket licensing regime under the Cable Landing License Act for SLTE operations.
• Imposes numerous new national security-related reporting and compliance obligations.
• Creates a process to streamline and expedite submarine cable applications from trusted applicants.

The new rules are intended to improve the security of submarine cable systems and reduce threats from foreign adversaries without imposing an undue administrative burden on trusted providers and entities.

History of FCC Efforts Related to Submarine Cables and National Security

In 2025, the Commission adopted a First Report and Order to modernize the submarine cable licensing regime. The Commission adopted a presumption against granting certain submarine cable landing license applications filed by entities owned by, controlled by or subject to the jurisdiction or direction of a foreign adversary. Licensees that met the presumptive disqualifying criteria are now required to file a Foreign Adversary Annual Report each year. This First Report and Order also recognized SLTE as part of the overall submarine cable system for the first time.

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