New Disaster Reporting Requirements Take Effect for Voice Service Providers

In January 2024, the Federal Communications Commission adopted new rules requiring voice service providers – including all cable, wireless, and wireline voice service providers and interconnected VoIP providers – to file reports on their infrastructure status in the FCC’s Disaster Information Reporting System (DIRS). On January 21, 2025, the FCC announced that the new mandatory disaster reporting rules will go into effect on February 20, 2025.

The FCC typically activates DIRS in anticipation of or immediately following a major emergency, such as a hurricane, large-scale wildfire, or other disaster. The FCC announces DIRS activations by issuing public notices that list the specific counties covered. DIRS requirements remain in effect for the affected geographic area until the FCC issues a separate public notice announcing that it has deactivated DIRS for that area. It is important to note that the reporting requirements from DIRS are different than the FCC’s other network outage reporting requirements, and all voice service providers covered by a DIRS activation are required to file DIRS reports regardless of whether or to what extent they are actually experiencing a network outage.

Under the new rules, voice service providers will be required to file reports on their infrastructure status in DIRS when the FCC activates DIRS in the geographic areas where they provide service. Specifically, providers will be required to:

    • Provide daily reports on their infrastructure status from the start of DIRS activation until DIRS has been deactivated, even when their reportable infrastructure status has not changed from the previous day; and
    • Provide a single, final report to the FCC within 24 hours of the FCC’s deactivation of DIRS detailing the state of their infrastructure at the time of DIRS deactivation and an estimated date of resolution of any remaining outages.

To reduce the potential burden of mandatory DIRS reporting, service providers that are covered by a DIRS activation will not be required to file reports in the FCC’s separate Network Outage Reporting System (NORS) of system outages that arise during DIRS activation as long as they have been timely reported in DIRS.

If you have questions or would like more information about DIRS and the FCC’s disaster reporting requirements, contact an attorney in our Broadband, Spectrum, and Communications Infrastructure practice group.