Annual Reports Due September 30 For Entities With Licenses Acquired Using Bidding Credits

Licensees, including rural service providers, that acquired spectrum licenses at an FCC auction using bidding credits must file annual reports with the FCC to either confirm their ongoing eligibility for bidding credits or to report changes. The FCC requires additional information in the reports regarding deployment status. The annual reports are due September 30, 2024 for designated entity licenses held as of August 31, 2024.

By September 30 of each year, each designated entity licensee must electronically file an annual report using Form 611-T for each license it holds that was acquired using designated entity benefits and that, as of August 31 of the year in which the report is due, remains subject to designated entity unjust enrichment requirements. The annual report must provide the following information:

• • A list and summary of all agreements and arrangements (including proposed agreements and arrangements) that relate to eligibility for designated entity benefits and the parties (including affiliates, controlling interests, and affiliates of controlling interests) to each agreement or arrangement, and the dates on which the parties entered into each agreement or arrangement.
  • The licensee’s progress in meeting construction requirements for the licenses.
  • The services provided or planned to be provided using the licenses.
  • The number of subscribers served in the license areas.
  • If applicable, any other information that might affect the licensee’s designated entity status.

If a designated entity has assigned or transferred a designated entity license to another designated entity during the reporting period, the designated entity that holds the license on September 30 of the year in which the application for the transaction is filed is responsible for filing the annual report. A designated entity does not need to list and summarize on its annual report the agreements and arrangements otherwise required to be included if it has already filed that information with the FCC, and the information on file remains current. In such a situation, the designated entity must instead include in its annual report both the ULS file number of the report or application containing the current information and the date on which that information was filed.

For more information about the designated entity annual reporting requirement, contact an attorney in our Broadband, Spectrum, and Communications Infrastructure practice group.