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United States of America
Regulation
Proposal
FCC Third Report and Order: Promoting the Integrity and Security of Telecommunications Certification Bodies, Measurement Facilities, and the Equipment Authorization Program
Affects:
Certification Process
Testing
Executive Summary
The FCC has adopted new rules to bolster supply chain integrity by restricting the recognition of Test Laboratories, Telecommunications Certification Bodies (TCBs), and laboratory accreditation bodies to entities located in the U.S. or 'Reciprocal Economies.' A uniform transition period ending December 1, 2028, has been established for these new requirements.
Last Updated
14-OCT-26
This summary is based on the FCC Fact Sheet and the Third Report and Order (ET Docket No. 24-136).
Scope
The FCC is introducing new requirements under its Equipment Authorization Program to improve the security and reliability of the communications supply chain.
Under these changes, the FCC will only recognise Test Laboratories (Test Labs), Telecommunications Certification Bodies (TCBs), and laboratory accreditation bodies located in the United States or in countries with a Mutual Recognition Agreement (MRA) or similar reciprocal agreement with the US. These are referred to as "Reciprocal Economies."
Key Requirements
- Geographic restrictions: From 1 December 2028, the FCC will stop recognising Test Labs, TCBs and accreditation bodies located in non-Reciprocal Economies.
- Restrictions on testing and certification activities: The rules also apply to organisations based in the US or a Reciprocal Economy if they carry out covered activities in a non-Reciprocal Economy.
- Test Laboratories: Activities covered by the rules include setting up and carrying out tests, taking measurements, analysing results, and preparing or approving test reports.
- TCBs: The restrictions cover application assessments, technical reviews, certification decisions, and post-market surveillance activities.
- Accreditation Bodies: The restrictions apply to assessments and technical evaluations carried out as part of laboratory accreditation for FCC recognition.
- Activities not affected: Pre-compliance testing and R&D testing are not affected, provided the results are not used for certification. General administrative activities such as sales, accounting and scheduling are also excluded. Facilities that operate completely separately from FCC-recognised activities are not covered.
- Transition period: Organisations have until 1 December 2028 to comply. Existing recognitions will remain valid during this period, while new recognitions for organisations in non-Reciprocal Economies will only be granted up to that date.
- Legal Entity Identifier (LEI): The FCC is also seeking feedback on whether Test Labs, TCBs and accreditation bodies should be required to obtain an LEI to help verify their ownership.
- Compliance and enforcement: The FCC can refuse or withdraw recognition if an organisation does not meet the required standards for technical competence, independence or reliability. This also applies where an organisation is owned or controlled by a prohibited entity under existing FCC rules.
Overall Impact
The main change is that FCC-recognised testing, certification and accreditation activities will need to take place in the US or a Reciprocal Economy from 1 December 2028.
This means organisations currently carrying out these activities in non-Reciprocal Economies will need to review their operations and make any necessary changes before the deadline.
The restrictions are not limited to where a company is registered or headquartered. The location where the actual testing, technical review or certification work takes place will also be important.
Attached Documents & Source Files
FCC Fact Sheet: Integrity of Equipment Authorization Program
Author / Agency: Federal Communications Commission (FCC)
Published:
2026-10-08
Language:
English
Key Regulatory Timeline & Dates
Oct 08, 2026
Date Published
Date on the FCC Fact Sheet.
Dec 01, 2028
Compliance Deadline
Effective date for the prohibition of non-Reciprocal Economy Test Labs, TCBs, and laboratory accreditation bodies.
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