This post was written by Andy Regitsky and originally published on CCMI’s blog.
When looking back at 2025, there is no doubt that historians will say that it was the beginning of the end of the telecommunications regulatory state. Whether it was the end of 1996 ILEC interconnection rules, the enhanced phaseout of time division multiplexed wireline networks, the loosening of broadband regulations or the end of Net Neutrality, the Trump FCC made it clear where it stands on most regulations. In our look back at the year, it started quickly with the end of Net Neutrality.
On January 2, 2025, the Sixth Circuit Court of Appeals in Cincinnati released an Opinion in Docket 24-52, rejecting the FCC’s Safeguarding and Securing the Open Internet Order and ended Net Neutrality forever since opponents chose to avoid certain defeat at the Supreme Court. As we mentioned in January, while it is possible that Congress could someday codify some of the principles of Net Neutrality, including forbidding the blocking, throttling or prioritizing of Internet traffic, there is no chance Congress would order Broadband Internet Access Providers to be regulated as if they were Title II common carriers or utilities. Thus, ISP pricing will not be regulated nor will be their so-called “Internet Conduct.”
The Commission also began 2025 by granting AT&T permission to replace its traditional copper home phone lines with a new wireless landline technology called AT&T Phone-Advanced (AP-A) for 52 customers in nine small service areas in Oklahoma. While the number of customers was small, this represented a significant step forward for AT&T and other providers as they work to eliminate their copper networks by 2030. The agency further helped speed the end of copper networks by removing many of the testing requirements for technology transition discontinuance and network change applications filed under section 214(a) of the Telecommunications Act. Such requirements delayed the move to broadband by months if not years.
The FCC also went out of its way to make life easier for broadband Internet access providers in 2025. For example, in August, the current FCC determined that the previous Commission erred in its 2024 section 706 inquiry by including extraneous universal service goals such as adoption, affordability, availability, and equitable access to broadband throughout the United States as the metrics for determining whether broadband deployment was sufficient. The new Commission decided that this change in focus was wrong and has decided to use only broadband deployment as the sole measure of meeting the section 706 requirements.
At about the same time the FCC decided that slamming and cramming of customers was no longer a significant problem and proposed a single, streamlined rule that ensures consumer protection against unauthorized switches of their chosen providers while eliminating the current prescriptive requirements on providers. It also proposed to eliminate many outdated Truth-in-Billing rules, including those that address placement of third-party charges on carrier bills.
In November, the Commission took aim at the labels that ISPs are required to display to enable a consumer to determine whether the offered price for a broadband service is an introductory rate and, if so, the price the consumer will be required to pay following the introductory period. It chose to eliminate most broadband labeling requirements such as; read the label to consumers over the phone; itemize state and local pass-through fees that vary depending on location of the consumer; provide information about the now-concluded Affordable Connectivity Program; display labels in customer account portals; make labels available in machine readable format; and, archive labels for at least two years after a service is no longer offered to new customers. As you might guess, consumer advocates have been very critical of this FCC for all its deregulatory efforts.
Perhaps the biggest impact to the industry will come from the FCC’s October proposal to forbear from the interconnection and related obligations imposed on the time division multiplexed network of incumbent LECs under sections 251(c)(2) and (c)(6) of the Telecommunications Act, and the Commission’s rules, implementing those provisions by a sunset date of December 31, 2028. This includes the rules that incumbent LECs provide, for the facilities and equipment of any requesting “telecommunications carrier,” direct interconnection with its network “for the transmission and routing of telephone exchange service and exchange access” at “any technically feasible point within the carrier’s network” that is at least equal in quality to that provided by the LEC to itself or its subsidiaries, on rates, terms, and conditions that are just, reasonable, and nondiscriminatory. Without such requirements and no such requirements on ISPs, increasingly the industry will turn to the Internet and packet switching
Finally, 2025 will be remembered for one other event. On June 27, 2025, the U.S. Supreme Court released an Opinion in the Case of “Federal Communications Commission v Consumers Research” which reversed the Fifth Circuit Court of Appeals and found the Universal Service Fund (USF)to be lawful. If the High Court had found otherwise, it would have led to chaos in the industry, so we should all be thankful for this decision.
What should we expect in 2026? The most important is the Commission’s clear intent to do away with the switched access and tariffing system for inter-carrier compensation that has governed the telecom industry since 1984. Will this be replaced with bill-and-keep with no inter-carrier compensation? We will soon find out.
