Project 2025 Tracker / What’s done, what’s next

28. Federal Communications Commission · Notable

Publish a foreign adversary transparency list of FCC licensees

Partially done

852 28. Federal Communications Commission

“To this end, the FCC should compile and publish a list of all entities that hold FCC authorizations, licenses, or other grants of authority with more than 10 percent ownership by foreign adversarial governments, including the governments of China, Russia, Iran, Syria, or North Korea.”

What has happened

  1. Partially done

    A further concrete step short of the ask, and the clearest evidence yet that publication has not begun. The Commission issued its 60-day Paperwork Reduction Act notice for the new collection: "OMB Control Number: 3060-XXXX. Title: Protecting our Communications Networks by Promoting Transparency Regarding Foreign Adversary Control, Report and Order, (GN Docket No. 25-166, FCC 26-2). Form Number: FCC Form 5655. Type of Review: New information collection. … Number of Respondents and Responses: 18,000 respondents; 18,000 responses." The collection is designed, named and out for comment; the placeholder "3060-XXXX" is the finding, because it means OMB has not concluded its review and assigned a control number, and a collection cannot lawfully begin without one. The notice also records what the data is for: the Order "directed the Commission to establish a new system and procedures for collecting the information from regulated entities", and "[t]he information collected in the Foreign Adversary Risk Report will fill critical information gaps". Still `partial`: the machinery is being built, no attestation has been collected and no list has been published.

  2. Partially done

    Report and Order FCC 26-2 adopted the attestation and disclosure rules (47 CFR part 1, new subpart GG; effective 2026-06-09) and adopted the proposal "to make the attestations and additional disclosures available to the public", delegating to OEA and PSHSB the authority to publish that information and to decide what must be withheld. The mechanism that would produce the Quote's list is therefore in place, but no list has been compiled or published: compliance with the new §§ 1.80003 and 73.1212(j)(8) is deferred until the Commission announces a compliance date in the Federal Register after OMB's Paperwork Reduction Act review. The rule is also framed on control and jurisdiction rather than the Quote's 10-percent ownership test, though the Order discusses five- and ten-percent thresholds as relevant to identifying foreign adversary involvement.

  3. Attempted

    The FCC proposed (GN Docket 25-166) to extend foreign-ownership disclosure from a few license classes to every type of license, permit or authorization, and to go beyond ownership to cover any regulatee owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary. A proposal only: nothing was collected and no list existed.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • Read at govinfo.gov/content/pkg/FR-2026-04-10/html/2026-06992.htm. The operative publication language is a delegation, not a schedule: “we adopt our proposal … to make the attestations and additional disclosures available to the public”, with OEA and PSHSB authorized to “enable the publication of both the information collected by these rules and also of Foreign Adversary Control information more broadly, and to publish the information.” Nothing in the Order fixes a date, and the compliance date for the attestations themselves is still unannounced. When the FCC publishes the collected data, this becomes done.
  • Negative search, 2026-09-03 (read-queue ticket 04), and for once the Federal Register negative is dispositive rather than merely strong. The rule’s own terms require the compliance date to be announced in the Federal Register after OMB’s PRA review, so the Federal Register is the only place the answer could appear. Three API queries, run 2026-09-03: "1.80003" published on or after 2026-04-01 returns three documents, all substantive rules (the 2026-04-10 Report and Order itself; the submarine cable rule 2026-15123 of 2026-07-27; the robocall proposed rule 2026-09134 of 2026-05-08) and no compliance-date notice; "foreign adversary" "compliance date" over the same period returns two, the Report and Order and the 2026 Unified Agenda introduction (2026-16603, 2026-08-14). So as at 2026-09-03 no compliance date has been announced, no OMB control number has been assigned, and no attestation data has been published.
  • The source the read-queue row named does not exist. https://www.fcc.gov/foreign-adversary-control redirects to the FCC’s own not-found page, as does fcc.gov/sitemap.xml, so fcc.gov cannot be enumerated to find the filing system under another slug. www.fcc.gov is otherwise open to the full browser header set. The conclusion that collection has not begun therefore rests on the absent OMB control number rather than on reading a filing-system page — a strong inference, since a collection cannot lawfully begin without one, but an inference.
  • The NPRM’s origin, now dated on an allowlisted page. The FCC’s proposed-rulemakings index (https://www.fcc.gov/proposed-rulemakings, read 2026-09-03) carries FCC 25-28, 2025-05-27, “FCC Lays Groundwork to Identify Foreign Adversary Control in Communications Industry / FCC Seeks Comment on Promoting Transparency Regarding Foreign Adversary Control” — the item behind the 2025-06-20 Federal Register proposal cited above.
  • Do not let this proceeding be borrowed for #2189. FCC 25-28 and FCC 26-2 are titled “Promoting Transparency” and are FCC transparency rules, but they impose ownership-attestation duties on FCC licensees, not disclosure duties on Big Tech platforms. Recorded on #2189 too.
  • The Mandate’s endnote 24 points at H.R. 820 (118th Congress). Its 119th-Congress successors are the Foreign Adversary Communications Transparency Act, H.R. 906 and S. 259, which would put the list on a statutory footing. Neither is enacted: H.R. 906 passed the House by voice vote on 2025-04-28 and was referred to Senate Commerce; S. 259 passed the Senate by voice vote on 2025-10-23 and has been held at the House desk since 2025-10-24. Action histories read from govinfo.gov/bulkdata/BILLSTATUS/119/hr/BILLSTATUS-119hr906.xml and …/s/BILLSTATUS-119s259.xml. This item is not a Requires-Congress ask — the Quote asks the FCC — so the bills are context, not the Status.
  • Adjacent but not this ask: the FCC’s foreign-ownership review for broadcast and common carrier licensees (final rule 2026-06866, 2026-04-09) and the submarine cable landing license rules (2025-19658, 2025-10-27) tighten review of foreign ownership; neither produces a published list.
Action
create
Object
Foreign adversary transparency list
ID
2203