Submarine cables carry the vast majority of the world's internet traffic. On 25 September 2026, the FCC's new security regime for these cables reaches its general effective date.
But for most operators, that date won't actually change much yet — because nearly every provision with real operational weight is delayed indefinitely, pending a separate announcement the FCC hasn't made.
What the FCC adopted
On 25 June 2026, the FCC adopted a Second Report and Order establishing a licensing framework for owners and operators of Submarine Line Terminal Equipment (SLTE) — the equipment at each end of a submarine cable that connects it to onshore networks. The order was published in the Federal Register on 27 July 2026.
The rule, in outline, does three things: brings SLTE owners and operators into the cable landing licensing regime through a blanket license; prohibits certain arrangements with foreign-adversary-linked entities; and creates a fast-track exemption from Executive Branch review for lower-risk applications.
What's delayed — and it's most of the rule
The Federal Register's effective-date notice is explicit: a long list of sections are "delayed indefinitely," pending review under the Paperwork Reduction Act by the Office of Management and Budget. Reading the rule text itself shows what that actually covers:
- The blanket license itself. § 1.70003(b) — the provision that grants SLTE owners and operators their license — is delayed. Its own text ties the effective date to "the effective date of amendatory instruction 8," which hasn't been set.
- The foreign-adversary equipment and third-party restrictions. The relevant certification requirements under § 1.70006 and associated routine-condition amendments under § 1.70007 are among the provisions delayed indefinitely. This includes requirements concerning foreign-adversary equipment, certain third-party service providers and Covered List IRU or capacity-lease arrangements.
- The fast-track exemption. § 1.40001, covering the ten national-security standards that would qualify an application for expedited review, is delayed too.
- Reporting obligations, including the SLTE Foreign Adversary Annual Report (§ 1.70018) and several other notification and disclosure sections.
What takes effect on 25 September is largely foundational or administrative, including definitions, an internal FCC delegation of authority and provisions governing the Commission's ability to share filed information with the Committee. These provisions do not bring the headline SLTE licensing, certification and reporting obligations into operation.
The FCC has committed to announcing the effective date for the delayed sections in a future Federal Register notice — one that doesn't exist yet.
Why this is harder than a single deadline
A single effective date is straightforward: something applies, or it doesn't. This is not that. One part of the same order is nominally "in force" from 25 September, while the provisions that actually require a licensee to do something — get licensed, certify compliance, file a report — are waiting on a second notice with no announced date.
For a compliance or legal team, that means tracking which obligations are genuinely active, which are drafted and approved but not yet required, and having the correct version of each certification and disclosure ready to go the moment the FCC does set a date — for a set of provisions that could activate individually, not necessarily all at once.
How CommsPliant handles this
CommsPliant keeps the approved wording for each certification, disclosure and report as a version-controlled template — reviewed, approved and locked, whether or not the underlying requirement is active yet.
When a provision is delayed, the approved template waits in the system rather than living in a draft folder or an old email thread. When the FCC eventually publishes an effective date, the already-approved version is ready for controlled production and use in the required process — not rewritten under time pressure.
Every version carries its approval history. If a regulator, auditor or internal reviewer asks which version was approved and when, the record is already there.
The practical takeaway
The Second Report and Order has a general effective date of 25 September 2026 — but many of its most operationally significant provisions, including the SLTE licensing framework itself, its certifications, and its reporting requirements, are delayed indefinitely pending further approval and notice.
Operators who treat 25 September as the day the entire regime becomes operational will misstate the legal position. But organisations that ignore the order until a later notice appears may find themselves preparing complex certifications, disclosures and reports under unnecessary time pressure.