Adopted, Eliminated, Mandated, Readopted, and Now Revised: Fifteen Years of Consumer Broadband Labels

If you shop for home internet service in the coming months, something on the screen may look different. For the past two years, providers have had to show you a standardized "broadband label"—a black-and-white box modeled on the nutrition panel on a cereal box, listing the monthly price, what happens when the introductory rate expires, the typical speeds, the latency, the data allowance, and each fee added on top. The label had to sit right next to the advertised plan.

In a saga that goes back over 15 years now, consumer broadband labels have been adopted, eliminated, mandated by Congress, adopted again, and now revised. Each turn came with a stated reason. The labels were built so consumers could compare offers side by side. They were discarded because the format was said to cost providers too much for the little uptake it generated. Congress ordered them back. They have now been trimmed because, the FCC says, they were confusing.

On July 22, 2026, the Federal Communications Commission (FCC) adopted an order changing the contents and placement of consumer broadband labels. [FCC 26-48] Broadband internet access service providers may now:

• Replace the label at the point of sale with an icon or a link.
• Replace the itemized list of location-based fees with a single "up to" figure.
• No longer have to publish label data in a spreadsheet format that researchers and comparison-shopping tools can read.
• No longer have to keep old labels on file for two years after a plan is retired.

The FCC says these changes make the label a better shopping tool. Whether they do is something the FCC will not attempt to measure for at least the next two years.

Looking at the arc of proposals and revisions to the labels may be the clearest way to judge the effectiveness of these latest changes.

Where the Consumer Broadband Labels Came From

The FCC's broadband transparency rule dates back to 2010, when it was first adopted as one of three "open internet" rules. At the time, “open internet” was the FCC's term for a platform that, in its words, enables "consumer choice, end-user control, competition through low barriers to entry, and the freedom to innovate without permission." The other two rules barred providers from blocking lawful content, applications, services, and devices, and from unreasonably discriminating against lawful traffic. Transparency was the disclosure piece, and at first, it was not built solely for shoppers. Disclosure would promote competition, the FCC said, "in at least five ways":

1. Letting consumers make informed choices;
2. Building the confidence that drives broadband adoption and, in turn, investment;
3. Giving startups and other edge providers the technical information they need to build and maintain online services;
4. Deterring providers from violating open internet principles by letting "the Internet community" identify problems and suggest fixes; and
5. Letting the FCC collect what it needed to assess, report on, and enforce its other open internet rules.

Informing "end users, edge providers, and the Commission," the FCC concluded, was a necessary step toward preserving an open internet.

The rule the FCC wrote in 2010 addressed two audiences: end users and edge providers. Providers had to publicly disclose accurate information about their network management practices, performance, and commercial terms—enough for consumers to make informed choices, and enough "for content, application, service, and device providers to develop, market, and maintain Internet offerings." Elsewhere in the order, the FCC named a third group: a key purpose of the rule, it said, was to enable independent engineers and consumer watchdogs to monitor and evaluate what providers were doing.

When the D.C. Circuit struck down most of the FCC's 2010 open internet rules in Verizon v. FCC, the court left the transparency rule standing. In 2015, the FCC strengthened that rule and added something new: a format. The FCC found that consumers needed a simple way to compare offerings across providers, and wanted the disclosure to be "clear and easy to read—similar to a nutrition label." Rather than design the format itself, the FCC handed the job to its Consumer Advisory Committee (CAC), a body that included both industry and consumer representatives.

CAC’s Disclosure Task Force met more than twenty times to decide what that label would look like. The full CAC approved two labels—one for fixed service, one for mobile—unanimously. On April 4, 2016, three FCC bureaus approved them, with modifications, finding that the format conveyed what consumers needed to know "in plain language that is easy to understand without overwhelming consumers with too much information."

One detail from 2016 matters for everything that follows: the labels were a safe harbor, not a mandate. A provider that used them was presumed to satisfy the format requirement. A provider that did not was free to disclose the same information in some other way.

Why the Labels Disappeared

In December 2017, the FCC adopted the Restoring Internet Freedom Order, reclassifying broadband as an information service. The FCC kept the transparency rule and eliminated the safe harbor for the label.

At the time, the FCC offered three reasons for its move.

1. Conforming to the format could require some providers to spend substantial resources.
2. Limited take-up—caused by those same burdens—would reduce the value of having a uniform format at all.
3. Requiring every provider to disclose the same information, regardless of format, would still allow consumers to compare offerings.

The 2017 FCC also narrowed the rule's second audience. Where the 2010 rule spoke of "content, application, service, and device providers," the 2017 version spoke of "entrepreneurs and other small businesses." The consumer clause was left alone.

The order offered no consumer evidence to support the third claim. And the disagreement between the 2017 FCC and the 2022 FCC is precisely about whether uniform information without uniform presentation is enough to let consumers compare broadband service offerings.

Congress Brings Back Broadband Labels

In November 2021, Congress settled the question in Section 60504 of the Infrastructure Investment and Jobs Act. The provision is short and specific. Within one year, the FCC "shall promulgate regulations to require the display of broadband consumer labels, as described in the Public Notice of the Commission issued on April 4, 2016."

Congress pointed directly at the labels the FCC had previously approved and then, under a different chairman, discarded. Congress also added one requirement of its own—the label must state whether a price is introductory and what the consumer would have to pay afterward—and directed the FCC to rely on label price information for its broadband data collection.

Congress also added an obligation that has largely dropped out of the conversation. Subsection (c) required the FCC to hold public hearings to assess how consumers actually evaluate broadband plans and whether existing disclosures are "available, effective, and sufficient."

The 2022 Label

After the enactment of the Infrastructure Investment and Jobs Act, the FCC held three public hearings,[1] returned to the CAC for advice on defining "point of sale," and received comments from more than 70 parties. In November 2022, the FCC adopted an order creating a label closely modeled on the 2016 design, down to the typeface and white space. The 2022 FCC developed its label in consultation with the Consumer Financial Protection Bureau.

Four requirements from the 2022 order are still especially noteworthy today:

1. The full label at the point of sale. Providers had to display the actual label—"not simply an icon or a link"—in close proximity to the advertised plan. The FCC reasoned that consumers should not have to navigate a provider's website or toggle between an advertisement and a separate page to compare the two.
2. Machine-readable data. Providers had to publish label contents in a spreadsheet format at a dedicated web address so a) third parties could build comparison-shopping tools, b) researchers could study the broadband market at scale, and c) the FCC itself could collect data and monitor compliance.
3. Itemized fees. Every monthly fee not folded into the base price had to be listed separately.
4. Two-year archiving. Providers had to keep labels for two years after a plan was withdrawn, and produce them to the FCC or an affected customer upon request so that complaints about inaccurate labels could be investigated.

There was also a phone requirement that, notably, lived in a footnote: if a consumer shopped by telephone, the provider had to read the entire label aloud.

In August 2023, ruling on three petitions for reconsideration, the FCC affirmed that providers must itemize the fees they add to base monthly prices, including fees tied to government programs—universal service, regulatory fees—that providers choose to pass through. Clear itemization of all fees, the FCC wrote, "is essential to our goal of empowering consumers to make good purchase decisions." The FCC rejected the industry proposal to substitute a single maximum figure on the grounds that a ceiling would leave consumers "unable to reliably predict the cost of particular plans for purposes of comparison shopping." A maximum dollar figure, the FCC concluded, "does not sufficiently disclose to consumers what they will be charged for and how those fees compare to another provider's service offerings."

July 2026 Changes

In October 2025, FCC Chairman Brendan Carr announced that the Commission would vote on an order to “reexamine broadband nutrition labels so that we can separate the wheat from the chaff.  We want consumers to get quick and easy access to the information they want and need to compare broadband plans (as Congress has provided) without imposing unnecessary burdens.” 

Elements of the 2022 rules that the FCC kept are proving as revealing as those it dropped.

The changes are not in force yet. The amended definitions take effect 30 days after Federal Register publication, but the substantive changes await Office of Management and Budget review under the Paperwork Reduction Act, with an effective date the FCC will announce later by Public Notice. The rule text in the order's appendix reads "Delayed indefinitely."

What survives

Every standalone mass-market broadband internet access service plan still needs a label that includes the price, introductory rate, speeds, latency, data allowance, and contract terms. Labels must still be accessible to people with disabilities. They must still appear in every language in which a provider markets. Telephone sales remain a point-of-sale activity. During the 2026 proceeding, AARP and TURN argued that the telephone remains a preferred channel for older adults, lower-income households, and consumers with limited digital literacy—and, as TURN noted, for people who do not yet have broadband and are calling to find out what it costs. TURN cited 2023 American Community Survey data showing that 80 percent of adults with vision difficulty own a smartphone, against 62.7 percent with home broadband service.

Providers choosing the "up to" approach must break the total into government-imposed and third-party categories, list the types of fees in each, and link to a page explaining them. And the FCC declined requests to exempt mass-market services sold to business customers, and to exempt E-Rate and Rural Health Care services.

What comes off the labels

The clearest change is a change in position. Where the 2022 rules required the label itself to sit alongside the advertised plan, a provider may now post a clearly identified icon or link that connects directly to it—at the point of sale, and inside a customer's account portal as well. The fee line changes character, too. Rather than itemizing the location-varying charges a provider passes through, such as right-of-way and pole attachment fees, it may show a single maximum "up to" amount or an exact local total. On the telephone, sales representatives are no longer required to read the label aloud; instead, they must summarize seven fields.

The remaining changes are invisible to shoppers but consequential for anyone conducting research on broadband prices. The requirement to publish label contents in machine-readable files disappears, and with it the ability of researchers and comparison-shopping services to gather data at scale. So does the two-year archiving obligation. Finally, the label template itself moves out of the Code of Federal Regulations to fcc.gov/broadbandlabels. The FCC's Consumer and Governmental Affairs Bureau may now make non-substantive changes to the template's visual layout and formatting by Public Notice rather than by rulemaking, and must describe any update in a Public Notice before it takes effect. The delegation does not extend to substantive changes to what the label says.

The fee reversal, examined

Among the changes, the fee provision is the one where the FCC's own record most directly contradicts its stated reason, illustrating how the same source document can support opposite conclusions.

The 2026 order's central factual justification for permitting an aggregate figure is label proliferation: "Itemizing fees often requires providers to generate and maintain a large number of distinct labels to account for state and local variation in fees across their service territories."

The 2023 FCC had that argument before it, in nearly identical words. Petitioners warned they would be forced to list "potentially hundreds of fees for all jurisdictions in [a provider's] footprint," making labels "very lengthy and unwieldy." The FCC agreed that such a label would be unusable—and solved the difficulty a different way. The FCC held that labels must be accurate based on the consumer's location, so a provider never had to display fees that do not apply. Listing irrelevant fees "would effectively render comparison shopping impossible."

In other words, the problem the 2026 order solves by aggregation was addressed in 2023 through localization.

The New York State Public Service Commission—the only state regulator to file—cautioned that disclosing state and local fees is what prevents misleading or incomplete price information, and that weakening label elements risks a return to a marketplace where consumers cannot get clear cost figures. AARP and the Hispanic Technology and Telecommunications Partnership filed to similar effect. Public Knowledge raised a different worry: that nothing principled limits how much a provider may fold into the base price. The FCC answered that one directly, holding that the accuracy requirement supplies the limit, since a provider may not embed fees that push a consumer's bill above the maximum stated on the label.

Both FCCs invoke the same 2016 Public Notice in opposite directions. The 2026 FCC treats the notice as a source of authority because the Infrastructure Investment and Jobs Act directs display "as described in" that notice, and the notice calls for plain language that avoids "overwhelming consumers with too much information." Aggregation follows. The 2023 FCC had cited the notice the other way—as corroboration, noting that requiring specific fee amounts "accords with the approach reflected in the 2016 Public Notice that Congress directed the Commission to consider." One document, two directions.

Broadband providers choosing the "up to" option must break the ceiling into government-imposed and third-party categories, name the fee types in each, and link to plain-language descriptions—protections FCC Commissioner Anna Gomez says she negotiated. Whether that partial itemization restores the comparison-shopping function the 2023 FCC sought to protect will be the proof of the pudding.

The evidence question

The 2026 order's premise is that the 2022 rules "resulted in sometimes-confusing labels."

The support for that proposition is a single footnote—one provider's comment describing its own experience, citing one Wall Street Journal article from December 2024. There is no consumer survey, no focus group, no usability testing, and no FCC study. The 2022 record rested on three congressionally mandated public hearings and two rounds of work by the Consumer Advisory Committee. The 2026 record drew AARP, TURN, Public Knowledge and its coalition partners, the Asian Americans Advancing Justice coalition, a nine-organization disability coalition, 31 members of Congress, and a state utility commission. They won concessions on several provisions and lost on the central ones.

On the cost side, the order is candid that the numbers are missing. The FCC grants relief on portal display while noting that commenters "do not specifically quantify the costs at issue," and again that "[n]o commenter attempts to quantify these claimed costs." The Costs and Benefits section contains no dollar figures at all.

The evidentiary standard is not applied evenly, but neither is it applied in only one direction. When two commenters asked the FCC to drop the multilingual requirement, the FCC refused precisely because the commenters offered no cost data. The same demand for evidence that saved the language requirement was not made of the claims that removed machine-readability and archiving.

On the burden of displaying fees, the 2023 FCC said it was "not persuaded that it will be burdensome for ISPs to itemize" fees they choose to pass through, "particularly since providers acknowledge being able to describe such fees to a consumer over the phone and on a consumer's bill once the consumer subscribes to service." The 2026 order reaches the opposite conclusion on burden without quantifying it.

Allowing hyperlinks instead of displayed labels, the FCC says, "may result in fewer consumers reading the label," but "interested consumers still have the opportunity to view the broadband label." The FCC concludes that the changes impose "no material harms on consumers."

Among the pending proposals the FCC closed in this order was one from its 2022 Further Notice: whether to employ focus groups, surveys, or subject-matter experts to gather feedback on future changes to the label. Having concluded that the 2022 rules confuse consumers, the FCC closed the inquiry into how it might have asked them.

The FCC also closed its inquiry into how "typical" performance metrics should be defined. The label reports typical download speed, upload speed, and latency, but each provider determines what "typical" means on its own network. One commenter had urged the FCC to keep that inquiry open, arguing that the current approach produces speed and latency disclosures that are not comparable between providers—the quality that makes side-by-side shopping possible in the first place.

The loss of machine-readability

The FCC's evidentiary case for eliminating machine-readability rests on one sentence: "there is no record evidence that any third parties have used machine-readable label content to develop pro-consumer tools." The FCC cited the International Center for Law & Economics, a think tank that filed in support of elimination.

The FCC also lists the commenters who argued the requirement was necessary. First on that list is BroadbandToolkit.com, a business unit of Signals Analytics that builds broadband comparison tools. Also on the list: Jon Peha of Carnegie Mellon, AARP, TURN, and the nine-organization Accessibility Organizations coalition. Scott Jordan of UC-Irvine filed comments, reply comments, and four separate ex parte submissions in the proceeding.

USTelecom, arguing for elimination, told the FCC the requirement "has no clear purpose or benefit except for third parties seeking to mine this information"—and added that those third parties could instead collect it directly from the consumer-formatted labels providers will keep on their websites. The order does not address how that fallback interacts with the rule it adopts a few paragraphs earlier, which allows the label on those websites to be replaced by a link.

A footnote adds a legal signal. The FCC observes that the machine-readability requirement was adopted before the Supreme Court's 2024 decision in Loper Bright Enterprises v. Raimondo, which held that agency interpretations of statutes are not entitled to deference. Loper Bright governs how courts review agencies rather than whether an agency may revisit its own rule, but its appearance here suggests the FCC anticipates the question being litigated.

Machine-readability and archiving were the two requirements that let anyone outside a provider's compliance department check a label. Machine-readable files were meant to enable third parties to build comparison-shopping tools, allow researchers to study the broadband market at scale, and enable the FCC to collect data and monitor compliance. Archiving lets the FCC or an affected customer obtain a retired label upon request, so that a complaint about an inaccurate label has something to test against. Both were eliminated. 

The Accessibility Organizations coalition told the FCC that the requirement is "essential" for DeafBlind, blind, and low-vision consumers who use assistive technologies. TURN called machine-readable labels "both a critical accessibility and research tool," listing screen readers and refreshable braille displays among the technologies that depend on machine-readability. The FCC's answer is that the eliminated requirement covered a separately hosted bulk data file—CSV, JSON, or XML—rather than the label itself, which a consumer opens in a browser, is already compatible with screen readers, and remains subject to an independent accessibility requirement.

Opinions from the Commissioners

All three sitting commissioners supported the item, even though Commissioner Gomez dissented from the November 2025 notice that proposed these changes. In her statement on the order, Commissioner Gomez names four provisions she secured: 1) telephone sales retained as a point-of-sale, 2) the governmental/non-governmental fee breakdown, 3) the multilingual requirement, and 4) the recurring "Assessment of Consumer Benefits." And she names what she gave up: "I would have preferred that the labels provide a complete itemization," and "my preference would have been to display the full label."

The order directs the rechartered CAC (now known as the Consumer Protection and Accessibility Advisory Committee (CPAAC)) to report on whether the labels reach consumers and remain accessible. The first report is due two years after the order is published in the Federal Register, and then every four years.

The CPAAC review is the order's only forward-looking accountability mechanism,  arriving after the deregulation rather than before it. The accountability mechanism is entrusted to an advisory committee rather than the full FCC. This accountability exists because one commissioner asked for it.

The FCC's list does not require CPAAC to examine price accuracy or whether anyone successfully comparison shops. The FCC directs CPAAC to cover:

1. Reach: the extent to which broadband labels reach consumers, which the order says is whether people are aware that the labels exist and are using them, plus any remaining challenges to their use.
2. Publicity recommendations: how the FCC, industry, and consumer groups can better publicize the labels so consumers know about them and understand how to use them.
3. Accessibility: the extent to which labels are accessible for consumers with disabilities, and any remaining challenges to full accessibility.
4. Accessibility recommendations: how the FCC and providers can address those remaining accessibility challenges.
5. A catch-all: "other opportunities to better clarify and make more useful to consumers the information on the label."

Commissioner Gomez is also the only commissioner to cite Section 60504(c), the requirement to hold public hearings, which she reads as establishing a continuing obligation: "the Commission should revisit our disclosure requirements to confirm that they continue to serve consumers well."

Chairman Brendan Carr's statement describes the order as giving providers "more practical ways to make labels available through hyperlinks, QR codes, and online account portals." The order authorizes an icon or a link; there is no mention of QR codes anywhere in it.

Commissioner Olivia Trusty places the item inside the Commission's Build America Agenda and writes that "[t]he record demonstrates that requiring providers to itemize every pass-through fee could create confusion rather than promote transparency." The order's support for that point consists of one commenter and a research citation, which the order itself renders as "citation omitted." Her assertion that consumers "overwhelmingly want confidence that they will not be surprised by a higher price" carries no citation.

Notably, none of the three statements mentions machine-readability or archiving.

Where We Started and Where We Ended Up

Start where we began: a person shopping for home internet. In 2010, the FCC decided that a broadband consumer deserved accurate information about price, speed, and terms. Startups building services on top of the network, the FCC enforcing its rules, and the independent engineers and consumer watchdogs watching what providers actually did all needed transparency as well.

In 2016, an advisory committee of industry and consumer representatives turned that principle into a label anyone could read. In 2017, the FCC withdrew it, reasoning that the same information in any format would serve consumers equally well. In 2021, Congress disagreed, named the 2016 design, and ordered it back—writing the mandate, as the FCC now emphasizes, around a single audience. In 2022, the FCC built the label out again, adding requirements that served the other constituencies. In 2026, the FCC removed those requirements, citing the statute's single audience as the reason.

The FCC's stated reason for eliminating machine-readability is that Section 60504 directs disclosure "to consumers," and that supplying data to third parties exceeds that mandate. Measured against the statute alone, that is a fair reading; Congress apparently wrote subsection (a) with a single audience for the labels in mind. Measured against the rule the label implements, it is considerably narrower than where the FCC began. The FCC is under no obligation to keep serving purposes Congress did not adopt. But it is worth naming what has happened across fifteen years: a rule written so that several different parties could check on broadband providers is becoming a rule written so that one shopper can compare prices.

For that shopper, the label is still there. It still carries the price, the introductory rate, the speeds, the fees. It may now sit a click away rather than beside the advertisement, and its fee line may be a ceiling rather than a sum. Whether those changes make it a better shopping tool is a question the FCC has assigned to an advisory committee, with a first report due no earlier than 2028.

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More From Benton

• A New Chapter in the Consumer Broadband Label Debate
• Here's How the Infrastructure Investment and Jobs Act Will Make it Easier to Shop for Broadband Service
• First Look at Broadband Labels
• A Consumer-Driven Broadband Label Design

 

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