The short answer
- On October 15, the Fifth Circuit ruled the FCC lacked authority to create USAC. The decision isn't in effect yet, and E-Rate reviews, commitments and payments continue.
- The FCC's proceeding on E-Rate's future drew 3,276 filings; reply comments are due November 12, 2026. A companion proposal would register E-Rate consultants and ban percentage-based fees.
- The FY2027 administrative window opened October 21. The Form 471 window dates haven't been announced.
October 2026
The Fifth Circuit rules the FCC lacked authority to create USAC
On October 15, 2026, a Fifth Circuit panel ruled in Consumers' Research v. FCC (No. 25-60535) that the FCC had no statutory authority to create USAC, and vacated the 38.1% universal service contribution factor for the fourth quarter of 2025. The case went back to the FCC; the court ordered no refunds.
What it means for providers now: the decision isn't in effect yet, and the FCC said it wouldn't take effect for at least two months. Nothing in it tells USAC to stop reviewing applications, issuing commitments or paying invoices. Funds For Learning's read: "We don't see anything in the opinion that should change your FY2026 invoicing or your FY2027 plans." The FCC can ask the full court to rehear the case or go to the Supreme Court, and Congress could authorize USAC directly.
Sources: the opinion (Justia); Funds For Learning; Benton Institute.
E-Rate's future: 3,276 comments, replies due November 12
In June the FCC asked whether E-Rate's mission is complete (WC Docket 26-133). By October 14 it had 3,276 filings; of the 2,514 that took a position, 98.6% urged keeping the program. A companion proposal would define, register and certify E-Rate consultants and ban percentage-based consultant fees. Reply comments are due November 12, 2026. Service providers can file through the FCC's comment system like anyone else.
Source: Funds For Learning, October 15, 2026.
FY2027 administrative window opens
USAC opened the funding year 2027 administrative window on October 21, so applicants can update entity profiles, including enrollment and NSLP data, before the Form 471 window. Those counts feed discounts and Category 2 budgets. The Form 471 window itself is expected early in 2027; USAC hasn't announced the dates.
Source: E-Rate Central, October 19, 2026. See the E-Rate calendar.
FY2026 commitments pass $2.17 billion
Wave 25 for funding year 2026, released October 15, committed $48.7 million. As of that wave USAC had funded 89.0% of FY2026 applications, representing 63.8% of the dollars requested, and total FY2026 commitments stood at $2.17 billion. Committed FRNs that name your SPIN are the ones to invoice; check the invoice deadline rules below.
Source: E-Rate Central, October 19, 2026.
Still in force from earlier in 2026
- SAM.gov banking. Since September 8, 2026, USAC pays invoices only to the bank account linked to your SAM.gov registration. (USAC, July 2026)
- Invoice deadlines. Since June 18, 2026, the deadline is the latest of 120 days after the last date to receive service, 120 days after the FCDL, and the other dates in FCC 26-30. (details)
- Bidding portal from FY2028. Ordered by the FCC; takes effect once the Office of Management and Budget approves it. Form 486 goes away the same year. (FCC 26-30)
Questions providers ask
Does the Fifth Circuit ruling stop E-Rate payments?
Not as of October 30, 2026. The decision isn't in effect yet, and it doesn't direct USAC to stop reviews, commitments or payments. Watch for a rehearing request or a stay.
When is the FY2027 Form 471 window?
Early 2027; USAC hasn't announced the dates. We'll update the calendar and the ACD calculator guidance when it does.
When are reply comments due on the FCC's E-Rate proposals?
November 12, 2026, in WC Docket 26-133.