Updated December 4, 2025.  Originally posted November 26, 2025.

In November, the Federal Communication Commission (“FCC”) released a Second Further Notice of Proposed Rulemaking (“FNPRM”) proposing to eliminate or modify various broadband label rules for Internet Service Providers (“ISPs”).  The FCC’s primary rationale for these proposed changes is that the rules are cumbersome for ISPs to implement and offer little, if any, benefit to consumers.  The FNPRM seeks to “streamline the rules to reduce the compliance burden on providers while preserving the benefit to consumers.”

Specifically, the FNPRM seeks comment on several proposals to amend the broadband label transparency rules, including:

Eliminating Certain Requirements for ISPs.  To better effectuate its congressional directive under the Infrastructure Investment and Jobs Act, the FNPRM seeks comment on whether the following requirements should be eliminated:

  1. That ISPs read the entire label to consumers shopping for broadband service over the phone.  
  2. That ISPs itemize state and local passthrough fees, such as right-of-way fees, which are not determined by ISPs and differ by location.
  3. That ISPs share information with consumers about the inactive Affordable Connectivity Program (commonly referred to as ACP), which ended in June 2024.
  4. That ISPs display labels about a customer’s plan in their account portals. 
  5. That ISPs make labels available on their websites and in a machine-readable format.
  6. That ISPs “archive labels for at least two years after a service is no longer offered to new customers.”

Multilingual Display Requirement.  The FNPRM seeks comment on whether ISPs should be required to provide consumers with service labels in languages other than English.

Broadband Label Template.  The FNPRM seeks comment on amending the rules for the broadband label template by: (1) removing the template from the Code of Federal Regulations and replacing it with a link to the FCC’s website, and (2) updating the current label template link from “fcc.gov/consumer” to “fcc.gov/broadbandlabels.”  

Streamlining the Label Requirements.  To further streamline the rules, the FNPRM seeks comment on additional ways to improve broadband labels in a manner that benefits consumers without imposing undue burdens on providers.

Initial comments may be filed on or before January 2, 2026 and reply comments may be filed on or before February 2, 2026, as set forth in the Federal Register.

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Photo of Yaron Dori Yaron Dori

Yaron Dori has over 25 years of experience advising technology, telecommunications, media, life sciences, and other types of companies on their most pressing business challenges. He is a former chair of the firm’s technology, communications and media practices and currently serves on the…

Yaron Dori has over 25 years of experience advising technology, telecommunications, media, life sciences, and other types of companies on their most pressing business challenges. He is a former chair of the firm’s technology, communications and media practices and currently serves on the firm’s eight-person Management Committee.

Yaron’s practice advises clients on strategic planning, policy development, transactions, investigations and enforcement, and regulatory compliance.

Early in his career, Yaron advised telecommunications companies and investors on regulatory policy and frameworks that led to the development of broadband networks. When those networks became bidirectional and enabled companies to collect consumer data, he advised those companies on their data privacy and consumer protection obligations. Today, as new technologies such as Artificial Intelligence (AI) are being used to enhance the applications and services offered by such companies, he advises them on associated legal and regulatory obligations and risks. It is this varied background – which tracks the evolution of the technology industry – that enables Yaron to provide clients with a holistic, 360-degree view of technology policy, regulation, compliance, and enforcement.

Yaron represents clients before federal regulatory agencies—including the Federal Communications Commission (FCC), the Federal Trade Commission (FTC), and the Department of Commerce (DOC)—and the U.S. Congress in connection with a range of issues under the Communications Act, the Federal Trade Commission Act, and similar statutes. He also represents clients on state regulatory and enforcement matters, including those that pertain to telecommunications, data privacy, and consumer protection regulation. His deep experience in each of these areas enables him to advise clients on a wide range of technology regulations and key business issues in which these areas intersect.

With respect to technology and telecommunications matters, Yaron advises clients on a broad range of business, policy and consumer-facing issues, including:

Artificial Intelligence and the Internet of Things;
Broadband deployment and regulation;

IP-enabled applications, services and content;
Section 230 and digital safety considerations;
Equipment and device authorization procedures;
The Communications Assistance for Law Enforcement Act (CALEA);

Customer Proprietary Network Information (CPNI) requirements;

The Cable Privacy Act
Net Neutrality; and
Local competition, universal service, and intercarrier compensation.

Yaron also has extensive experience in structuring transactions and securing regulatory approvals at both the federal and state levels for mergers, asset acquisitions and similar transactions involving large and small FCC and state communication licensees.

With respect to privacy and consumer protection matters, Yaron advises clients on a range of business, strategic, policy and compliance issues, including those that pertain to:

The FTC Act and related agency guidance and regulations;
State privacy laws, such as the California Consumer Privacy Act (CCPA) and California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Virginia Consumer Data Protection Act, and the Utah Consumer Privacy Act;
The Electronic Communications Privacy Act (ECPA);
Location-based services that use WiFi, beacons or similar technologies;
Digital advertising practices, including native advertising and endorsements and testimonials; and

The application of federal and state telemarketing, commercial fax, and other consumer protection laws, such as the Telephone Consumer Protection Act (TCPA), to voice, text, and video transmissions.

Yaron also has experience advising companies on congressional, FCC, FTC and state attorney general investigations into various consumer protection and communications matters, including those pertaining to social media influencers, digital disclosures, product discontinuance, and advertising claims.

Photo of Travis Cabbell Travis Cabbell

Travis Cabbell is an associate in the firm’s Washington, DC office. He is a member of the Commercial Litigation Group and the Technology and Communications Regulation Practice Group.