The FCC is considering a major expansion of its “Equipment Authorization Program” that could draw software developers, firmware providers, design houses and other technology suppliers into the agency’s regulatory system for the first time.
Under a Third Further Notice of Proposed Rulemaking adopted July 22, applicants could be required to submit signed hardware and software bills of materials (SBOMs) covering the hardware, software and firmware in a device. The disclosure would be required to identify: the component producer, where components were designed, developed or manufactured, and the percentage of component value associated with each production location. Grantees could also be required to update the information within 30 days of material changes.
Because the FCC’s proposed definition of production includes design and development, the information may need to be collected from suppliers far removed from the company filing the application, including design houses and IP licensors with no direct relationship to that applicant.
Eric Greenwald, General Counsel, Finite State had this comment:
“The FCC’s proposal would turn equipment authorization from a product review into a supply-chain transparency exercise. Applicants would file a signed HBOM and SBOM covering every component, including hardware, software and firmware, along with information about each component’s producer, place of production and share of value.
“The applicant would be responsible for the filing, but the information would have to be collected from dozens of suppliers, including design houses and IP licensors with no direct relationship to the filer. That process would be onerous, and the results would not necessarily be reliable. Anyone submitting an application for FCC certification will need a way to verify independently what is actually in the device, down to the firmware.”
This is a good start, but this needs to be enforced strictly. Only then will we see meaningful changes.
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This entry was posted on July 29, 2026 at 12:55 pm and is filed under Commentary with tags FCC. You can follow any responses to this entry through the RSS 2.0 feed.
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FCC proposal could force tech suppliers into equipment authorization rules
The FCC is considering a major expansion of its “Equipment Authorization Program” that could draw software developers, firmware providers, design houses and other technology suppliers into the agency’s regulatory system for the first time.
Under a Third Further Notice of Proposed Rulemaking adopted July 22, applicants could be required to submit signed hardware and software bills of materials (SBOMs) covering the hardware, software and firmware in a device. The disclosure would be required to identify: the component producer, where components were designed, developed or manufactured, and the percentage of component value associated with each production location. Grantees could also be required to update the information within 30 days of material changes.
Because the FCC’s proposed definition of production includes design and development, the information may need to be collected from suppliers far removed from the company filing the application, including design houses and IP licensors with no direct relationship to that applicant.
Eric Greenwald, General Counsel, Finite State had this comment:
“The FCC’s proposal would turn equipment authorization from a product review into a supply-chain transparency exercise. Applicants would file a signed HBOM and SBOM covering every component, including hardware, software and firmware, along with information about each component’s producer, place of production and share of value.
“The applicant would be responsible for the filing, but the information would have to be collected from dozens of suppliers, including design houses and IP licensors with no direct relationship to the filer. That process would be onerous, and the results would not necessarily be reliable. Anyone submitting an application for FCC certification will need a way to verify independently what is actually in the device, down to the firmware.”
This is a good start, but this needs to be enforced strictly. Only then will we see meaningful changes.
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This entry was posted on July 29, 2026 at 12:55 pm and is filed under Commentary with tags FCC. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.