FCC Mandates Electronic Filing of CALEA SSI Plans

On May 15, 2023, the Public Safety and Homeland Security Bureau (“Bureau”) released an Order amending the FCC’s rules to mandate the electronic filing of new and updated System Security and Integrity Policies and Procedures (“SSI Plans”) by covered entities under the Communications Assistance for Law Enforcement Act (“CALEA”).  The new rule, 47 CFR § 1.20005(c), will become effective 30 days after it is published in the Federal Register.  Thus, all covered entities that update their SSI Plans or file new SSI Plans after that time will be required to do so electronically via the CALEA Electronic Filing System (“CEFS”), available at: https://www.fcc.gov/cefs.  A Public Notice will be also released announcing the specific date for mandatory electronic filing of SSI Plans.

Voluntary filing in CEFS began on December 12, 2022 to give covered entities time to familiarize themselves with the systems and obtain any necessary credentials.  Trusted Third Parties that file SSI Plans on behalf of multiple clients will still be able to do so in CEFS.  Parties can continue to file SSI Plans in paper until mandatory electronic filing begins and covered entities that have already filed SSI Plans by paper are not required to re-file them in CEFS, unless and until the SSI Plan needs to be updated.

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