On July 23, 2026, the FCC released a Report and Order (“Order”) updating the broadband label requirements in an effort to simplify the display and eliminate requirements that the Commission views as exceeding its statutory mandate under the 2021 Infrastructure Act. The item was adopted at the July Open Meeting.
The following changes were made to the Commission’s prior broadband label approach, compliance with most of which was required beginning in 2024:
- Point-of-Sale Display
- 2024: Providers were required to display the full broadband consumer label at each point of sale (including websites, retail stores, and other sales channels) with the label appearing directly alongside the advertised plan.
- 2026: Providers may instead use a hyperlink or icon in lieu of the full label, provided it: (1) connects directly to the customer’s specific plan label (not a general landing page); (2) appears in close proximity to the advertised plan; and (3) is clearly identified as leading to the label so consumers are not left guessing what it links to. This same hyperlink/icon approach also now applies to customer account portals and providers no longer need to display the full label there so long as the link or icon takes customers directly to the label for their current plan.
- Phone Sales
- 2024: Rules required providers to read/display full label content to consumers during telephone sales, with prescriptive requirements for what and how information had to be disclosed.
- 2026: Phone sales representatives no longer have to read the label verbatim. Instead, they must orally summarize a defined set of fields during the sales call: monthly price inclusive of monthly fees (including introductory rate and duration, if applicable), typical download/upload speeds, latency, data allowance, contract term duration (if applicable), and early termination fees (if applicable). No mandatory script is required, and providers are not required to offer to transmit the full label via text, email, or mail, although the FCC encourages (but does not mandate) directing consumers to the label on the provider’s website.
- Machine-Readable Files
- 2024: Providers had to make label content available separately in a machine-readable format (e.g., CSV, JSON, or XML) hosted at a dedicated URL.
- 2026: This separate machine-readable/spreadsheet-file requirement is eliminated entirely. Note: this does not affect the independent obligation that labels remain accessible to consumers with disabilities (e.g., compatible with screen readers). That accessibility requirement is retained and treated as separate from the now-eliminated machine-readability mandate.
- Label Archiving
- 2024: Providers had to archive every label for at least two years after a plan was no longer available to new customers and had been removed from the website/sales channels.
- 2025: This two-year archiving requirement is eliminated.
- Affordable Connectivity Program (“ACP”) Disclosure
- 2024: Labels were required to include a field referencing the ACP.
- 2026: The ACP field is eliminated because the program ended on June 1, 2024.
- Passthrough Fees
- 2024: Providers had to itemize each individual passthrough fee (e.g., state/local right-of-way fees, pole attachment fees) separately, which could require generating different labels for different jurisdictions where fees varied by location.
- 2026: Providers may instead disclose pass-through fees in the aggregate, using either (1) a single “up to” maximum figure representing the highest total a subscriber could be charged anywhere in the provider’s service territory for that plan, or (2) an exact, location-specific total. Providers choosing the “up to” option must break the total into two sub-amounts, the maximum attributable to government-imposed costs and the maximum attributable to non-governmental third-party costs, and must identify the types of fees within each category (though not a separate “up to” figure per individual fee type). The label must also link to a webpage with plain-language descriptions of each fee type. Disclosed amounts must never understate what a consumer will actually be charged. Providers may still choose to itemize fees individually if they prefer.
- Label Template Removed from the Code of Federal Regulations (“C.F.R.”)
- 2024: The visual label template (the actual label format/figure) was codified directly in the C.F.R. at § 8.1(a)(1), fig. 1.
- 2026: The template is removed from the C.F.R. and will instead be maintained at fcc.gov/broadbandlabels, with version control and a publicly accessible revision history. The Consumer and Governmental Affairs Bureau (“CGB”) is delegated authority to make non-substantive visual/formatting updates to the template (which will be announced via Public Notice before taking effect), but it cannot make substantive content changes without full Commission action. As part of this, the outdated “fcc.gov/consumer” reference in the template is updated to “fcc.gov/broadbandlabels.”
- Removal of Obsolete Compliance-Deadline Provision
- 2024: 47 C.F.R. § 8.1(a)(7) set forth the original phased compliance deadlines: April 10, 2024, for providers with more than 100,000 subscriber lines, and October 10, 2024, for smaller providers.
- 2026: This provision is removed as moot, since both deadlines have already passed and all providers are now subject to the label requirements.
The following provider obligations remain unchanged from the Commission’s prior broadband label approach:
- Multilingual Labels
- 2024: Providers are required to display labels in English and in any other language(s) used to market the service.
- 2026: Requirement retained unchanged.
- Accessibility Obligations
- 2024: Labels are required to be easily accessible to consumers with disabilities, including compatibility with screen readers/assistive technology.
- 2026: Requirement retained unchanged and treated as independent of the elimination of the machine-readability rule. The FCC also directs the CPAAC to report every four years (first report due within two years of publication) on, among other things, the extent to which labels remain accessible to consumers with disabilities and what further steps might be needed.
Effective Dates:
- The amendments to 47 C.F.R. § 8.1(b) (definitions, including “passthrough fee”) will take effect 30 days after Federal Register publication. However, the amendments to § 8.1(a) (the substantive label display/content changes) will not take effect until the Office of Management and Budget completes Paperwork Reduction Act review, and CGB will announce that effective date by subsequent Public Notice.
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