E-rate Update: May 22, 2026

Executive Summary

This brief highlights critical changes including the upcoming August 2026 mandatory SAM.gov and UEI integration for all BEAR invoice filers, significant FY2028 program reforms by the FCC introducing a competitive bidding portal and eliminating Form 486, and disaster relief provisions for areas impacted by Typhoon Sinlaku. Timely response to PIA inquiries and Form 486 filing for FY226 are also critical.

Important Deadlines & Dates

  • June 30, 2026: Last day to receive recurring services for FY2025.
  • July 1, 2026: Begin invoicing for FY2026 recurring services.
  • August 2026: Mandatory transition to SAM.gov banking information for all Universal Service Fund invoices. All BEAR filers must have an active SAM.gov account with a UEI on their FCC Form 498. Payments will be held for non-compliance.
  • May 22, 2026 – September 11, 2026: E-Rate “Summer Deferral” period for PIA inquiries. Applications contacted for the first time on or after May 22 without a response will be deferred until after September 11.
  • September 21, 2026: Deadline for disaster-affected applicants (Typhoon Sinlaku) to submit Requests for Review/Waiver and FCC Forms 486, 472, 474.
  • September 30, 2027: Extended FY2025 non-recurring service implementation deadline for disaster-affected applicants.

Critical Updates

Invoicing Method Modification for FY2026

  • Before FCDL: Submit a Receipt Acknowledgment Letter (RAL) Modification Request.
  • After FCDL: Use the new “Invoicing Method” change request via FCC Form 500. This must be done before any invoice submission for the FRN.
  • BEAR to SPI Change: Requires documentation of service provider agreement for the change.

Mandatory SAM.gov and UEI Requirement for FCC Form 498

  • Effective August 2026: All service providers and E-Rate applicants using BEAR invoicing (FCC Form 472) must have an active SAM.gov account with a Unique Entity Identifier (UEI) on their FCC Form 498.
  • USAC will use SAM.gov banking information for all disbursements; existing FCC Form 498 banking information will no longer be used.
  • Failure to update your FCC Form 498 with a UEI and maintain an active SAM.gov account will result in held payments.
  • An e-learning module on filing/modifying FCC Form 498 for applicants is available.

Service Provider Annual Certification (SPAC) – FCC Form 473

  • Required for FY2026: Service providers must file and certify their FCC Form 473 as soon as possible.
  • USAC cannot pay invoices (FCC Form 472 or FCC Form 474) until both the FCC Form 486 and FCC Form 473 (SPAC) are certified and approved.
  • Failure to submit SPAC forms will lead to referral to the FCC Enforcement Bureau.

Interim SPIN Usage for FY2026 Applications

  • Applicants who used the interim SPIN 143666666 for FY2026 funding requests must submit a RAL modification request to provide the actual SPIN.
  • USAC will not issue an FCDL until the interim SPIN is updated.

FCC Adopts E-Rate Competitive Bidding Portal and Program Rule Changes (FCC 26-30)

The FCC has adopted a Report and Order (FCC 26-30) introducing significant changes, primarily effective in FY2028:

  • Competitive Bidding Portal (FY2028):
    • Mandatory USAC-managed portal for service providers to submit bids.
    • Applicants must upload bid evaluations, vendor selections, and contracts to the portal.
    • Will serve as a document repository.
    • Mandatory portal use for competitive bidding communications, including bidder questions and applicant responses.
  • Service Transition Process:
    • A future process will allow post-commitment requests to change service start/end dates and potentially increase commitment amounts for transitioning services, subject to OMB approval and specific criteria.
  • Cost Allocations:
    • The 90% ancillary use presumption now applies to all Category One (C1) services (e.g., data transmission, WAN, Ethernet). If 90% of a recurring C1 service is for an eligible purpose at eligible locations, cost allocation for the remaining ineligible use is not required.
  • Competitive Bidding Exception (Bandwidth Increase):
    • A limited exception allows service substitution requests to increase bandwidth during the funding year at the existing commitment amount. A new FCC Form 470 will be required for subsequent funding years.
  • Elimination of FCC Form 486 (FY2028):
    • The requirement to file FCC Form 486 will be eliminated starting in FY2028. CIPA certifications will move to FCC Form 471.
    • Crucial Note: FCC Form 486 is still required for FY2026 and FY2027, and for any prior year open commitments or approved appeals.
  • Invoice Filing Deadline Relief:
    • A single 120-day extension from USAC is now permissible if requested within 15 days of the original deadline.
    • A one-time 60-day grace period for resubmitting corrected versions of timely-filed but rejected invoices.

Disaster Relief for Typhoon Sinlaku Affected Areas (DA 26-396)

For applicants and providers in areas affected by Typhoon Sinlaku:

  • Deadline Extensions:
    • Up to 150 calendar days (until September 21, 2026) to submit requests for review/waiver and FCC Forms 486, 472, 474.
    • FY2025 non-recurring services implementation deadline extended to September 30, 2027.
  • Service and Equipment Substitutions:
    • Waiver of the “same functionality” requirement, allowing greater flexibility for substitutions. Submit a Service Substitution request to USAC.
  • Document Retention:
    • Waiver for records destroyed by the weather events, provided certification of destruction.

Filing the FY2026 FCC Form 486

  • File FCC Form 486 after receiving a positive FCDL and services have started (or can be filed early under specific conditions).
  • Certifies service start and CIPA compliance.
  • Consortium members must provide their FCC Form 479 (CIPA Certification) to the consortium leader before the consortium can file the FCC Form 486.

Current Status

  • FY2026 Commitments: As of May 20, 2026, over $1.05 billion has been committed, with Waves 1, 2, and 3 already released.

E-Rate Outreach and Training

  • June 9, 2026: Beginning E-Rate Services Webinar (2-3 PM ET).
  • June 16, 2026: Open Data Webinar Part 1: Open Data Overview (2-3 PM ET).
  • June 18, 2026: E-Rate Invoicing Applicant and Service Provider Webinar (2-3 PM ET).
  • June 25, 2026: Open Data Webinar Part 2: Creating Reports and Visualizations (2-3 PM ET).
  • September 15, 2026: In-person E-Rate Training in Phoenix, AZ.
  • September 24, 2026: In-person E-Rate Training in Washington, D.C. (also live on FCC’s YouTube).