From satellites to medical devices, wireless networks to printers, a new national security regulator has come to town: the Federal Communications Commission (FCC). Leveraging its traditional authorities as a regulator of spectrum, communications services, and consumer protection, the FCC has increasingly used its ability to govern entry into those sectors to impose new national security requirements for doing business in the U.S. in recent years. Parties who intentionally emit radiofrequency communications—everyone from satellites to Bluetooth devices—and those who unintentionally do so—i.e., makers of electronic devices of all stripes—should take heed.

Under Chairman Brendan Carr, these initiatives have been formalized through the creation of the FCC’s Council on National Security (Council), which aims to elevate the FCC’s role in countering risks posed by certain “foreign adversaries”—primarily the People’s Republic of China (PRC), but also Russia, Iran, North Korea, Cuba, and Venezuela under the Maduro regime (collectively, Foreign Adversaries).

Why It Matters: These developments are not just policy shifts. While the FCC’s actions are aimed at limiting the influence of Foreign Adversaries in U.S. communications networks, virtually all entities holding FCC licenses or other FCC-regulated assets should prepare for heightened diligence and compliance obligations, as well as increased regulatory scrutiny of their supply chains and ownership structures. In particular, many of these actions impact makers of electronic devices—the aforementioned unintentional radiators—who may not even fully appreciate the importance of FCC approval to marketing their devices within the U.S. When it comes to electronics manufacturers with a PRC-based supply chain, for example, these rules may have far-reaching impacts.

This client advisory explains how the Council functions as the FCC’s national security hub, reviews the initiatives shaping its mandate, and highlights the implications for certain companies operating in telecom, technology, and critical infrastructure sectors.

The FCC’s Council on National Security: What It’s All About

The Council’s work is organized around a three-part strategy that underpins the FCC’s national security agenda:

1. Tech and Telecom Supply Chain Security—Reducing the American technology and telecommunications sectors’ trade and supply chain dependencies on foreign adversaries.
2. Cyber, Espionage, and Surveillance Threats—Mitigating America’s vulnerabilities to cyberattacks, espionage, and surveillance by foreign adversaries.
3. U.S. Strategic Leadership in Critical Technologies—Ensuring the U.S. prevails in the strategic competition with the PRC over critical technologies, such as 5G and 6G, artificial intelligence, satellites and space, quantum computing, robotics and autonomous systems, and the Internet of Things (IoT).

Operationalizing the Mandate: A Look at the Initiatives Shaping the FCC’s National Security Agenda

• “Bad Labs” Proceeding. The FCC adopted rules (effective September 8, 2025) prohibiting certain equipment test labs and telecommunications certification bodies (TCBs) with ties to Foreign Adversaries from participating in the FCC’s equipment authorization program. The FCC has also proposed broader jurisdiction-based restrictions on all test labs and TCBs subject to any Foreign Adversaries jurisdiction. By targeting certification pathways, the FCC is asserting itself as a gatekeeper not only of market access but also of national security in the technology supply chain.
  
  Client Impact: Companies that manufacture or import electronic devices—including smartphones, IoT equipment, network gear, and medical devices—should evaluate whether their certification processes rely on labs subject to new restrictions. Many companies may need to shift testing to U.S.-based or other trusted labs and update supply chain diligence and recordkeeping practices accordingly.
• Adding Connected Vehicles to the FCC’s Covered List. The FCC issued a Public Notice seeking comment on whether to expand its “Covered List” to include connected vehicle technologies supplied by Chinese- and Russian-controlled entities. This action follows a Final Rule issued by the U.S. Department of Commerce’s Bureau of Industry and Security, which found that such technologies pose “undue or unacceptable risks to national security and U.S. persons” and represents the first time the FCC has proposed adding an entire product category—such as advanced driver assistance systems, connected vehicles, and vehicle communication systems—rather than equipment produced by specific companies. Once added to the Covered List, equipment is barred from receiving new FCC authorizations and being imported into the U.S. market.
  
  Client Impact: Automakers and vehicle technology suppliers should prepare for the possibility that connected vehicle components sourced from PRC- or Russia-linked companies may soon be ineligible for authorization or face heightened FCC scrutiny. Companies should begin assessing exposure across their supply chains and, if necessary, consider diversifying sourcing strategies to mitigate future compliance and supply chain disruptions.
• Identifying Foreign Adversary Ownership Stakes in FCC-Regulated Assets. The FCC proposed rules aimed at identifying entities that hold FCC licenses, authorizations, or other regulated assets that are “owned by, controlled by, or subject to the jurisdiction or direction of” Foreign Adversaries. If adopted, the new rules could impose new certification requirements on virtually all FCC license, permit, and equipment certification applicants (rather than only certain specific licenses, as is currently required). Entities that respond affirmatively would be required to disclose all (both foreign and non-foreign) ownership interests of five percent or greater to the FCC.
  
  Client Impact: All entities holding FCC-regulated assets should monitor the Notice of Proposed Rulemaking (NPRM) and proactively assess whether they have minority ownership stakes or other ties to foreign adversaries that could trigger the proposed ownership reporting requirements.
• Securing and Accelerating Investment in Undersea Cable Infrastructure. The FCC adopted an Order and NPRM that, among other things, took measures to prevent and mitigate national security risks from Foreign Adversaries to submarine cable systems. Specifically, the rules adopt a presumption of denial for cable landing license applicants with certain ties to Foreign Adversaries and other entities whose FCC license or authorization was denied or revoked on national security grounds, prohibits agreements giving foreign adversaries control over submarine line terminal equipment on U.S. landings, and adopts new certification and disclosure requirements on cable system details, foreign adversary service providers, cybersecurity and physical security plans, and FCC Covered List compliance.
  
  Client Impact: Given that submarine cables carry more than 95 percent of all U.S.- international voice, data, and internet traffic, including civilian and military—and demand is expected to grow—tech and telecom industry participants and investors should assess whether these rules could impact existing operations, planned partnerships, or expansion strategies.

Looking Ahead

The FCC’s actions underscore its growing role as a national security regulator and align with broader federal efforts to safeguard critical infrastructure. Aligned with the White House’s “America First Investment Policy,” the FCC is taking a hard line on adversarial threats while streamlining processes for trusted U.S. and allied stakeholders.

Companies holding FCC-regulated assets or operating in the telecom, technology, or critical infrastructure sectors should anticipate heightened diligence and compliance obligations, increased scrutiny of supply chains and ownership structures, and new requirements tied to equipment testing and certification procedures. Stakeholders should closely monitor upcoming rulemakings and enforcement actions as the FCC’s national security agenda continues to evolve.

Please reach out to Joshua Gruenspecht or Sophia Galleher, or another member of Wilson Sonsini’s National Security and Trade practice or Communications practice with questions regarding any of the matters discussed above.