As the federal government ends its record-length shutdown and agencies resume operations, E-rate program operations have remained steady and uninterrupted. While the Federal Communications Commission (FCC) suspended most of its activities beginning October 1, the Universal Service Administrative Company (USAC) continued processing forms, reviewing applications, and issuing funding commitments as usual.
Because the Universal Service Fund is supported by carrier contributions, not annual appropriations, USAC operations were not affected by the lapse in federal funding. As a result, Form 470 filings, EPC access, Program Integrity Assurance (PIA) reviews, and invoice payments all continued without disruption. The FY2026 EPC Administrative Window opened on schedule on October 15, allowing schools and libraries to update their profiles ahead of the next Form 471 filing window.
What Was Affected During the Shutdown
The FCC itself was hit hard by the funding lapse. More than 80% of agency staff were furloughed, and policy, oversight, and rulemaking work related to E-rate came to a standstill. This included:
- Processing of appeals and waiver requests
- Development of the final FY2026 Eligible Services List (ESL)
- Coordination on newer initiatives, such as the Cybersecurity Pilot Program
The FY2026 ESL proceeding includes both an initial round of comments and a subsequent reply‑comment period. Both of those deadlines originally fell during the shutdown, meaning none of that feedback could be fully considered until after the FCC returned to normal operations.
According to FCC Public Notice DA 25-922, any filings or deadlines that fell during the shutdown are automatically extended to the first business day after the agency reopens. In a follow-up “Additional Operations Guidance and Extension of Filing Deadlines” notice issued November 13, the FCC further extended all filings that were originally due between October 1 and November 17 to at least Tuesday, November 18, with additional program-specific guidance still to come. In practical terms, the comment and reply deadlines for the FY2026 ESL proceeding will now fall into this post-shutdown window rather than expiring while the agency was closed.
What to Expect as the FCC Reopens
As FCC staff return, they face a sizable backlog of filings and procedural deadlines accumulated over more than six weeks of limited operations. The FY2026 ESL, which clarifies treatment of software, remote configuration services, and the distinction between BMIC and MIBS, is expected to be finalized later than usual, likely sometime in December or early January, after the extended comment and reply periods close and staff have time to review the record.
While that timing could tighten internal schedules, it is not expected to significantly alter the traditional mid-January to late-March Form 471 filing window. Applicants should plan as if the Form 471 window will open on a similar timeline to FY2025, and view any extra time as a bonus rather than a delay to count on.
As part of its phased return to normal operations, the FCC has indicated that the November 18 date is an initial catch-up point and that it may further tailor deadlines for specific systems and programs. For E-rate, the reopening will restart:
- Review and release of pending E-rate appeals and waiver decisions (though some decisions may take longer while the agency catches up)
- Implementation and outreach related to the updated Category Two budgets for FY2026–2030 (adopted in June 2025)
- Post-review activities for the Cybersecurity Pilot Program, including USAC’s review of pilot applications and, ultimately, issuance of the first FCDLs
The Bottom Line for Schools and Libraries
For applicants, the message is reassuring:
- E-rate funding remains stable and secure.
- USAC operations have continued without interruption.
- The main effects are timing-related, particularly the release of the FY2026 ESL and the pace of FCC appeal decisions.
- There is still a full opportunity to participate in the FY2026 ESL proceeding through both comments and reply comments; the shutdown shifted the calendar, not the process.
As normal operations resume in Washington, Funds For Learning will continue to monitor developments and provide updates on FCC actions, filing deadlines, and the FY2026 funding cycle.
