Each fall, the release of the draft Eligible Services List (ESL) for the upcoming E-rate funding year draws attention from schools, libraries, and service providers alike. Much like dancing the Cha Cha—two steps forward, one step back—the ESL process often feels like movement within familiar rhythms. The list rarely undergoes sweeping revisions. Each year it sets the framework for what products and services applicants may seek support for in the next funding cycle.
I originally crafted this article pre-release, but as luck has it, the Public Notice came out yesterday. I didn’t anticipate major structural changes this year, and that proved true. Category One services continue to cover the familiar suite of broadband and transport services, while Category Two remains focused on internal connections, basic maintenance, and managed services. Applicants preparing their Form 470s can move forward with confidence that the core services they rely on remain eligible.
One issue loomed large: however, the FCC’s vote on the eligibility of off-campus Wi-Fi services for school buses and hotspots. These services were made eligible during the pandemic to address the ongoing need for remote connectivity, but as anticipated, the Commission has reversed course. The FY2026 ESL represents a “reset” of sorts—limiting support once again to on-campus connectivity. While most stakeholders disagree with this outcome, few were surprised.
Surprisingly, and long overdue in my opinion, is the push to consolidate all eligible software or remote-based services (e.g., bug fixes, security patches, software updates, online tech support) under Internal Connections, rather than splitting them with Basic Maintenance. This change should reduce errors and confusion that often-plagued applicants trying to track these costs across multiple funding years.
Taking together with the FCC’s request for comments on Managed Internal Broadband Services (MIBS), these shifts highlight why carefully reviewing the release—and submitting feedback where appropriate—remains critical.
For applicants, the practical takeaway is straightforward: plan FY2026 procurement around the traditional, campus-focused E-rate model. If your organization has relied on bus Wi-Fi or hotspots, now is the time to work with providers on alternatives or contingencies outside the program.
Like the Cha Cha, the ESL gives us steps both forward and backward—but the dance itself continues. By staying proactive and informed, schools and libraries can maintain their footing and position themselves for another successful year of participation in the E-rate program.
