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The FCC has proposed—but has not established as final rules—new reporting requirements intended to improve the security of internet routing. The June 6, 2024 proposal would have broadband internet access providers document their Border Gateway Protocol (BGP) security measures. The FCC’s August 2026 Unified Agenda lists the proceeding’s next action as “Undetermined. To Be Determined,” so the proposal should not be treated as a current filing obligation.

What the FCC proposed

On June 6, 2024, the Federal Communications Commission adopted a Notice of Proposed Rulemaking (NPRM) in PS Docket No. 24-146, “Reporting on Border Gateway Protocol Risk Mitigation Progress,” alongside PS Docket No. 22-90, “Secure Internet Routing.” An NPRM invites public comment on proposed rules; it is not a final rule. Comments were due July 17, 2024, and reply comments were due August 1, 2024. The Federal Register notice describes the proposal and its comment schedule.

The proposal centered on BGP security risk management plans. Providers would describe and attest to measures already taken and planned to secure their routing architecture, including practices based on the Resource Public Key Infrastructure (RPKI) and other approaches such as peer-locking. Plans would address registering and maintaining Route Origin Authorizations (ROAs) for routes a provider originates, as well as the status and plans for deploying Route Origin Validation (ROV).

Proposed reporting by provider size

The NPRM proposed different reporting treatment for the nine largest broadband providers and smaller providers. These distinctions describe the proposal, not obligations in force:

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Nine largest broadband providers Prepare and update a risk management plan at least annually, file it confidentially with the FCC, and submit quarterly public data intended to show progress in implementing RPKI-based security measures.
Smaller providers Prepare and update a plan at least annually, but do not routinely file it; make it available to the FCC upon request.

The FCC’s 2024 announcement describes the proposed requirements for the nine largest providers. It does not establish a market-share estimate or a total number of affected providers.

Do broadband providers have to file BGP security plans now?

The proposal alone does not require providers to file plans. The FCC’s August 2026 Unified Agenda entry for the proceeding gives the next action as “Undetermined. To Be Determined” and supplies no date for that action. The available status information therefore supports describing the reporting measures as proposed, not as rules currently in force. The FCC’s Unified Agenda entry records that status.

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The proceeding is time-sensitive: a later FCC action could change its status. The docket and agenda entry are the relevant official places to check for a subsequent order or rule.

What BGP security is meant to address

Border Gateway Protocol is used by independently managed networks to exchange information about which network destinations they can reach. That shared reachability information helps determine how internet traffic travels between networks. The FCC says BGP’s original design, still widely deployed, did not include intrinsic security features that ensure the exchanged information is trustworthy.

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If a network actor falsifies reachability announcements, traffic can be redirected. The FCC says such incidents can lead to misdirection, interception, manipulation, or disruption, potentially exposing personal information, enabling theft or espionage, and affecting services used by the public and critical infrastructure. These are risks identified by the FCC, not quantified outcomes of this rulemaking.

How RPKI, ROAs, ROV, and peer-locking fit in

  • RPKI: A set of mechanisms for improving trust in internet routing information.
  • ROA: A record specifying which network is authorized to originate a route. The FCC proposal discussed providers’ plans to register and maintain ROAs for their own route originations.
  • ROV: A process for checking route-origin information against ROAs. The proposal sought information on deployment status and plans.
  • Peer-locking: Another operator practice referenced in the proposal as a potential security measure.

The NPRM discussed these tools and practices as parts of provider risk management; it did not claim that any one of them would eliminate every routing incident.

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What this means for internet subscribers

The proposed reporting framework concerns broadband providers’ network operations and disclosures to the FCC. It does not create a subscriber-facing filing requirement, and the cited FCC materials do not identify consumer routers or software as a way to comply with the proposal.

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