President Trump Issues Executive Order Freezing Regulatory Rulemakings

President Trump Issues Executive Order Freezing Regulatory Rulemakings 

President Trump issued an Executive Memorandum (Memorandum) on January 20, 2025, implementing a regulatory freeze across executive departments and agencies, including the Federal Communications Commission (FCC or Commission). This action requires review of pending and recently issued rules by newly appointed agency heads.

The Memorandum requires immediate withdrawal of unpublished rules from the Office of Federal Register. Rules that have been published but have not yet taken effect may be postponed for 60 days to allow for review of questions of fact, law, and policy. During this period, affected rules may be opened for additional comment periods. The Memorandum allows the Office of Management and Budget (OMB) Director to exempt rules deemed necessary for emergency situations or those subject to statutory or judicial deadlines.

Impact on Recent FCC Actions

The regulatory freeze affects several recent FCC orders, notices, and regulations. The following section outlines key FCC actions that may be subject to review under this order. The non-exhaustive list of items below may be postponed, opened for additional comment, or undergo further evaluation:

Recently Adopted Rules Pending Publication

• Broadband Serviceable Location Fabric Use for High-Cost Obligations (DA 25-32)
• FCC Application Fee Schedule (FCC 24-137)
• Modifications to Letter of Credit Requirements for High-Cost Recipients (FCC 24-127)

Rules with Upcoming Compliance Deadlines

• 911/988 Outage Reporting Obligations (DA 24-1260)
• 988 Geo-routing Requirements for Non-nationwide Wireless Providers (FCC 24-111)

Pending Actions and Proposals

• Cybersecurity Requirements (FCC 25-9)
  • Declaratory Ruling is Still in Effect
• Rip and Replace Funding Notification (DA 24-1279)
• FCC Review of Submarine Cable Landing Licenses (FCC 24-119)

Rules Awaiting OMB Approval or Publication in the Federal Register

The regulatory freeze Memorandum impacts several FCC rules that were previously adopted but are either pending OMB approval or awaiting Federal Register publication. The following is a non-exhaustive list of impacted rules:

Next Generation 911 Rules

• Rule §9.31: Establishes requirements for handling valid requests to deliver 911 traffic in IP-based formats
• Rule §9.34: Details how NG911 requirements can be modified through mutual agreement between parties

Network and Service Rules

• Rule §1.717: Expands informal complaints process to include broadband services
• Rule §4.18: Implements mandatory reporting requirements through the Disaster Information Reporting System (DIRS)
• Rule §52.37: Creates new wireless number portability requirements including customer notifications for port-out requests, account locks, and fraud prevention measures
• Rule §54.205: Requires additional FCC notification for ETC designation relinquishment, expanding beyond current state-only notification requirement

Customer Proprietary Network Information (CPNI) and Privacy Rules

• Rule §64.2010: Establishes new requirements for handling SIM card change requests
• Rule §64.2011: Updates requirements for customer breach notifications
• Rule §64.1200: Provides new clarifications on “prior express written consent” for Do Not Call List compliance

Next Steps

The Memorandum’s regulatory freeze and review period may affect implementation timelines and compliance deadlines for recent FCC actions. During this period, providers should maintain their current compliance programs while awaiting further guidance on rules with upcoming deadlines. We anticipate many of these regulatory holds will be temporary as rules complete their required reviews under Chairman Carr.

JSI will monitor developments as this review process moves forward and track which FCC actions may receive exemptions. We can assist clients in understanding potential impacts on their operations and preparing comments if additional comment periods are opened. For questions about specific rules or regulations affected by this freeze, please contact Brett Hallagan.