Client Advisory

Advanced Communications Providers Must File Supply Chain Annual Reports by March 31, 2023

In a recent Public Notice, the Federal Communications Commission (“FCC” or “Commission”) reminded providers of advanced communications services (“ACS”) of their obligation to file Supply Chain Annual Reports by no later than March 31, 2023. The FCC defines ACS carriers as those that “provide high-speed, switched, broadband telecommunications capability that enables users to originate and receive high-quality voice, data, graphics, and video telecommunications using any technology with connection speeds of at least 200 kbps in either direction.” See 47 C.F.R. § 1.50001.

Specifically, ACS providers must report whether they have they have purchased, rented, leased, or otherwise obtained any “covered communications equipment or service” on or after August 14, 2018. Covered equipment and services including those supplied by Huawei Technologies, ZTE Corporation, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, Dahua Technology Company, AO Kaspersky Lab, China Mobile International USA Inc., and China Telecom (Americas), Pacific Network Corp, its wholly-owned subsidiary ComNet (USA) LLC, and China Unicom (Americas) Operations Limited.

The report must cover ACS providers’ information as of December 31, 2022. An ACS provider that does not have any covered communications equipment or services must still file an initial report and certify as such through the FCC’s online reporting portal. But, any ACS provider that certified in 2022 that it does not have covered equipment does not need to file an annual report in 2023 unless the provider has purchased, rented, leased, or otherwise obtained communications equipment or services since then.

If you have any questions regarding your company’s supply chain reporting obligations, please contact Ronald E. Quirk at or 703-714-1305.


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