The National Telecommunications and Information Administration recently published general terms and conditions (GTCs) for the Broadband Equity Access and Deployment (BEAD) Program. NTIA's previous version of these terms and conditions dates back to April 2024. This summary highlights the key changes, additions, and revisions between the April 2024 and November 2025 versions. Changes are organized by significance and impact.

Each of the 50 U.S. States, the District of Columbia, Puerto Rico, Guam, American Samoa, the U.S. Virgin Islands, and the Commonwealth of the Northern Mariana Islands are eligible for BEAD support. Below, they may be referred to as Eligible Entities, States, or grantees. BEAD subgrantees are internet service providers (ISPs) and other entities selected by state/territory agencies (state broadband offices) to receive support to build out high-speed internet infrastructure.

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Summary of Major Changes and Their Significance

The November 2025 GTCs reflect a significant policy shift toward reducing state regulatory authority over broadband providers and streamlining deployment processes. Three major new terms impose substantial new requirements on state broadband offices:

1. Term 50 (NEW): Preempts state rate regulation and net neutrality laws for all BEAD subgrantees
2. Term 51 (NEW): Prohibits subgrantees from relying on future federal funding
3. Term 13.D (NEW): Imposes comprehensive permitting streamlining requirements including 90-day timelines

Additional changes update the hierarchy of authorities, modify environmental review processes, adjust bonding thresholds, revise signage requirements, and make several technical corrections.

Policy Implications

For State Broadband Offices

Significantly Increased Requirements

1. Must implement 90-day permitting timelines and establish Permitting Roundtables
2. Must commit not to enforce state rate regulation or net neutrality laws
3. Must track and publicly report permitting compliance and unresolved complaints
4. Must obtain certification from all subgrantees regarding future federal funding
5. Must use the Environmental Screening and Permitting Tracking Tool for all environmental screening

Reduced Requirements

1. No longer required to conduct extensive ongoing local coordination activities
2. Simplified small business/minority contracting requirements (removed)
3. Higher audit threshold reduces oversight burden ($750k → $1M)

Reduced State Authority

1. Cannot enforce rate regulation on any broadband provider serving as BEAD subgrantee
2. Cannot enforce net neutrality rules on any broadband provider serving as BEAD subgrantee
3. Preemption applies statewide (not just BEAD locations) for duration of subgrant plus federal interest period

For Subgrantees

New Protections

1. Protected from state rate regulation and net neutrality enforcement anywhere in a state
2. Can assert contractual rights if a state attempts to enforce preempted regulations
3. Fixed amount subgrantees are exempt from construction bonding requirements
4. Higher bonding threshold ($250k → $350k) for those still subject to bonding

New Restrictions

1. Must certify will not require/accept future federal funding for BEAD projects or locations
2. Certification publicly publishable by NTIA
3. More specific low-cost plan requirements (100/20 Mbps, ≤100ms latency)

Reduced Flexibility

1. Cannot plan business models around future USF or other federal subsidies for BEAD locations
2. Must demonstrate financial viability without reliance on speculative future funding

For Permitting Authorities

New Requirements

1. Must approve or deny broadband permits within 90 days
2. Must establish single point of contact for broadband permits
3. Must defer to subgrantee construction technique choices absent safety concerns
4. Must follow Federal Communications Commission (FCC) pole attachment rules (one-touch make-ready, self-help)
5. Subject to Permitting Roundtable escalation for delays
6. Performance tracked and publicly reported

Cost Restrictions

1. Permitting fees limited to reasonable approximation of actual costs
2. Only objectively reasonable costs can be included
3. Fees cannot exceed those charged to similarly situated competitors

Areas for Concern

1. State consumer protection authority significantly curtailed
2. Net neutrality protections preempted for BEAD subgrantees
3. Affordability protections are prohibited even for monopoly providers in unserved areas
4. Preemption extends statewide, not limited to BEAD-funded locations
5. Consumer protection term (data caps prohibition) appears to have been removed

Positive Developments

1. 90-day permitting timelines should accelerate deployment
2. Specific low-cost plan speed/latency requirements (100/20 Mbps, ≤100ms)
3. Increased transparency through public reporting of permitting compliance
4. Maintained tribal consent requirements
5. Maintained strong accountability provisions (clawbacks, reimbursable funding)

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I. Three Major New Requirements

1. Ensuring Timely and Effective Deployment of BEAD Projects (Term 50)

What Changed: Entirely new term added -- no equivalent in April 2024 version

What It Does: Prohibits states from enforcing any law, regulation, or requirement that directly or indirectly regulates the rates, terms, and conditions of broadband internet service OR imposes net neutrality rules, open access, or other utility-style rules on broadband internet service. [NTIA says a “net neutrality rule” is any law, regulation, order, contracting requirement, or other enforceable obligation by the state that prohibits broadband internet service providers from, among other things, blocking content, throttling speeds, imposing data caps, engaging in paid prioritization, or that imposes a general conduct or similar standard upon broadband internet service providers.]

Scope of Preemption

• Applies to BEAD subgrantees and their affiliates
• Applies anywhere the subgrantee provides service within the state (both BEAD-funded and non-BEAD locations)
• Remains in effect while a subgrantee has any subgrant within its period of performance, extended period of performance, or federal interest period

NTIA's Rationale

• State laws targeting broadband service undermine the financial viability of BEAD projects
• Such laws deter investment and increase operating costs
• Applying laws at non-BEAD locations could raise compliance costs and threaten overall subgrantee financial viability
• Permitting states to do what NTIA is prohibited from doing¹ would contradict Congressional intent

Implementation

• Grantees must commit not to enforce such requirements
• Required language must be included in all subgrant agreements
• Allows subgrantees to assert contractual rights if a state attempts enforcement

Reports to the Federal Communications Commission and Congress

Reports on unresolved complaints will be shared with FCC and Congress to determine whether additional actions are warranted, including:

• Further funding rescission
• Enforcement actions
• Legislation to modify pole attachment rules (see 47 U.S.C. § 224) to remove exemptions for municipal and cooperative poles/conduits

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2. Protecting the BEAD Program from Defaults (Term 51)

What Changed: Entirely new term added -- no equivalent in April 2024 version

What It Does: Requires all subgrantees to certify they will not require or accept additional federal funds to support BEAD projects during the subgrant's period of performance, extended period of performance, or federal interest period.

Two-Part Certification Required

1. No Additional BEAD Project Funding: Subgrantee and affiliates will not require or accept any additional federal funds to support a BEAD project

2. No Federal Broadband Subsidies for BEAD Locations: Subgrantee and affiliates will not require or accept any additional federal broadband service subsidies for the project(s) and/or "Broadband Serviceable Locations²" (BSL(s)) served by the subgrant

   • Exception: Subsidies committed PRIOR to BEAD subgrant agreement
   • Includes new operating expenses for any BEAD project(s) or BSL(s)
   • "Federal broadband subsidy" = any federal funds to subsidize broadband service (e.g., USF mechanisms)

NTIA's Rationale

• The Infrastructure Investment and Jobs Act requires that subgrantees have "financial and managerial capacity"
• Requirement for "equitable and nondiscriminatory" distribution of funds
• Subgrantee relying on speculative future federal funding would result in increased default risk
• Distribution to such subgrantee would be inequitable
• Agreements must accurately reflect economic risk of providing service
• Also consistent with NTIA's BEAD Notice of Funding Opportunity (NOFO) prohibition on treating locations with enforceable federal commitments as "unserved" or "underserved"

Implementation

• Certification incorporated by reference in all subgrant agreements
• Signed certification required before releasing any BEAD funds
• Grantees submit certifications to NTIA within 30 days of receipt
• NTIA may publicly publish certifications (grantees must inform subgrantees)
• Can be submitted individually or in batches to Federal Program Officers

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3. Grantee Permitting Obligations (Revised Term 13.D)

What Changed: Entirely new subsection added to existing environmental term

What It Does: Imposes comprehensive permitting streamlining requirements on state broadband offices to ensure BEAD projects are carried out in "timely and effective manner."

NTIA's Rationale

• The Infrastructure Investment and Jobs Act permits NTIA to issue guidance necessary to ensure timely and effective project implementation (see 47 U.S.C. § 1702(i))
• Department of Commerce Inspector General report (March 2025) found state/local permitting delays affect timely execution and increase deployment costs
• State broadband offices agree permitting is a major barrier
• Aligns with FCC efforts to "facilitate pole attachment process to promote fast, efficient, and ubiquitous deployment"

Four Major Requirements

1. 90-Day Permitting Timeline: Grantees must establish procedures ensuring broadband permit applications are approved or denied within 90 days, including by:

• Assisting state/local authorities in establishing single dedicated point of contact with knowledge of application/review processes
• Providing technical assistance to ensure sufficient permitting capacity (Master Agreement templates, Consultant Reimbursement Agreement templates, surge support for permit processing)
• Providing deference to construction techniques chosen by BEAD subgrantees (without seeking to influence decisions), absent identified safety concerns
• Maximizing streamlined processing through permitting by rule, batch processing of substantially similar requests, and waiving/expediting duplicative or burdensome requirements where possible
• Following FCC rules regarding timelines, rates, terms, and conditions for access to municipally owned poles and conduit—including provisions for "one-touch make-ready" and "self-help"
• Requiring BEAD subgrantees that own poles (including cooperatives) to comply with FCC rules across their footprint

2. Minimize Permitting Costs

• Ensure permitting fees are reasonable approximation of government's costs
• Only objectively reasonable costs factored into fees
• Fees no higher than those charged to similarly situated competitors

3. Permitting Roundtables: Establish roundtables/working groups of federal, state, local, tribal authorities and industry representatives that will:

• Meet regularly to identify and facilitate resolution of delays or disputes
• Collect complaints and supporting information from subgrantees
• Escalate unresolved complaints through appropriate roundtable/working group

4. Tracking and Reporting: Track, publicly post, and submit to NTIA in semi-annual reports:

• Subgrantee compliance with National Environmental Policy Act (NEPA) milestone schedules
• Data regarding unresolved complaints from subgrantees, including:
  • Issues escalated through permitting roundtables
  • Delays attributed to state/local prohibition on preferred construction techniques
  • Delays attributed to state/local failure to follow FCC pole attachment rules

Implementation

• Grantees must include this language outlining their commitments in all agreements with subgrantees
• See NTIA's Permitting Roundtables Implementation Guide

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II. Revision to Existing Terms

1. Award Compliance Requirements, Prioritization and Terminology (Revised Term 1)

What Changed: Updated to reflect new policy document and updated Department of Commerce terms

Significance

• Inserts BEAD Restructuring Policy Notice as authority with higher priority than NOFO
• Updates reference to Department of Commerce terms with specific September 2025 date
• Also updates reference to "updated Uniform Guidance (dated October 1, 2024)"

April 2024 Order (highest to lowest priority):

1. Infrastructure Investment and Jobs Act (47 U.S.C. § 1702)
2. Specific Award Conditions
3. BEAD GTCs
4. BEAD NOFO
5. Department of Commerce Standard Terms and Conditions

November 2025 Order (highest to lowest priority):

1. Infrastructure Investment and Jobs Act (47 U.S.C. § 1702)
2. Specific Award Conditions
3. BEAD GTCs
4. BEAD Restructuring Policy Notice (June 2025) ← NEW (see summary)
5. BEAD NOFO
6. Department of Commerce General Terms and Conditions (dated September 22, 2025)

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2. Signage and Public Acknowledgements Requirements (revised Term 6)

What Changed: Language completely rewritten to reflect rescission of signage requirements

Significance: Removes promotional/branding requirements, reflecting policy change in early 2025

April 2024 Language:

• Encouraged (not required) to post signage identifying activities as "funded by the Infrastructure Investment and Jobs Act"
• Encouraged to use Official Investing in America emblem per Building A Better America Brand Guide
• Costs must be reasonable and limited
• Should use recycled materials when possible

November 2025 Language:

• Controller Alert CA-23-6 regarding Investing in America Emblem was rescinded on February 18, 2025 pursuant to Controller Alert 25-01
• Existing signs may remain on site
• To extent signs remain, should be maintained in good condition throughout construction OR until additional instructions provided

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3. Environmental and Historic Preservation (EHP) Review (Revised Term 13)

Multiple Changes Beyond New Section 13.D

Change 1 - Use of Environmental Screening and Permitting Tracking Tool​

• NEW Requirement: Grantees must use Environmental Screening and Permitting Tracking Tool (ESAPTT) within NTIA Grants Portal (NGP) to perform environmental screening and obtain NTIA NEPA approvals
• April 2024: Only mentioned submitting documentation "to NTIA for review"

Change 2 - Smart Start Guidance Reference

• NEW: Includes footnoted reference to NTIA's "Smart Start: How to Plan and Prepare for National Environmental Policy Act (NEPA) Compliance for BEAD (Apr. 2024)"
• Specifies grantees must hire/retain staff with "relevant NEPA qualifications and experience" (more specific than April 2024)

Change 3 - Tribal Notification/Section 106 of the National Historic Preservation Act of 1966 (54 U.S.C. 300101, et seq.) (NHPA)

• April 2024: Required grantee to provide NTIA-assigned Environmental Program Officer sufficient information to initiate Tribal notification via FCC's Tower Construction Notification System (TCNS); provide notified Tribes with info via preferred means "as identified in TCNS"
• November 2025: Simplified to "provide notified Tribes with information regarding grant funded activities via their preferred communication means, as identified to NTIA if applicable"
• Removes reference to TCNS system and Environmental Program Officer

Change 4 - Program Comments:

• April 2024: Apply Advisory Council on Historic Preservation (ACHP) Program Comment to Avoid Duplicative Reviews for Wireless Communications Facilities "or any other applicable program comment or program alternative developed to address Section 106 review of communications facilities"
• November 2025: Apply ACHP Program Comment, "Program Comment for Federal Communications Projects, and any other applicable program comment or program alternative, or following the ACHP rules at 36 CFR 800 Subpart B"
• Adds specific reference to Federal Communications Projects Program Comment and provides alternative pathway via 36 CFR 800 Subpart B

Change 5 - Removal of NTIA EHP Guidance Section:

• April 2024: Included Section 13.D "NTIA EHP Guidance" with detailed list of topics on which further guidance would be issued (8 bullet points about evaluating FirstNet PEIS, determining NEPA document types, formatting requirements, submission processes, etc.)
• November 2025: Entire Section 13.D removed; replaced with new Permitting Streamlining Requirements (described above)

Change 6 - Archaeological Resources:

• April 2024: "Such construction activities may then only continue with the written approval of NTIA"
• November 2025: "Construction activities may not resume in the area without the prior written approval of NTIA"
• Slight clarification of scope (activities in "the area" rather than all "such construction activities")

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4. Local Coordination (Revised Term 23)

What Changed: Substantially narrowed in scope

Significance:

• Dramatically reduces ongoing local coordination obligations
• Treats local coordination as largely complete with Five-Year Action Plans
• Removes extensive documentation and engagement requirements
• Simplified to certification-based compliance

April 2024:

• Extensive requirements for comprehensive local coordination approach
• Required coordination with political subdivisions, Tribal governments, local/community-based organizations, unions/worker organizations
• Required documentation in Five-Year Action Plan, Initial Proposal, and Final Proposal
• Encouraged integration with Digital Equity Act coordination
• Detailed requirements across 7 areas: geographic coverage, diverse stakeholder groups, awareness/outreach, transparency, underrepresented engagement, equitable distribution, fair labor practices, workforce development

November 2025:

• States: "Each Grantee developed a comprehensive local coordination approach to ensure local coordination was captured within each eligible entity's five-year action plan"
• With publication of BEAD Restructuring Policy Notice, "the Grantee may no longer engage in the activities listed in the Local Coordination and Public Notice sections of the NOFO (section IV.C.1.c and IV.C.2.c.iv)"
• Satisfy statutory requirement by certifying that it observed Final Proposal public comment requirements and received plans submitted by political subdivisions up until submission of Final Proposal to NTIA

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6. Recordation of Federal Interest in BEAD-Funded Property (Revised Term 47)

What Changed: Minor clarification about Low Earth Orbit satellite (LEO) Capacity Subgrants

Significance: Clarifies that LEO capacity subgrants are exempt from federal interest recordation requirements but still subject to consumer/taxpayer protections

April 2024:

• No mention of LEO Capacity Subgrants

November 2025:

• Adds Section C noting: "Per the BEAD Restructuring Policy Notice, NTIA will not take a Federal interest in equipment or property acquired or improved with a LEO Capacity Subgrant. Additionally, the consumer and taxpayer protections set forth in the NOFO apply to the recipients of such subgrants for the duration of the LEO Capacity Subgrant ten-year Federal interest period."

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7. Federal Interest Period (Revised Term 48)

What Changed: Addition of LEO Capacity Subgrant provision

Significance: Same as Term 47 -- creates exemption for LEO satellite projects while maintaining protections

April 2024:

• Two provisions: (a) 10-year period for broadband infrastructure projects; (b) Grants Officer determines period for other property

November 2025:

• Same two provisions PLUS adds provision (c): "Per the BEAD Restructuring Policy Notice, NTIA will not take a Federal interest in equipment or property acquired or improved with a LEO Capacity Subgrant. Additionally, the consumer and taxpayer protections set forth in the NOFO apply to the recipients of such subgrants for the duration of the LEO Capacity Subgrant ten-year Federal interest period."

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III. Technical and Administrative Chabges

1. Removal of Small Business Contracting Requirement (Term 4)

What Changed:

• April 2024: Had a separate Term 4 titled "Contracting with Small and Minority Businesses, Women's Business Enterprises, and Labor Surplus Area Firms" requiring affirmative steps per 2 CFR 200.321
• November 2025: This term is completely removed; subsequent terms renumbered

Significance: Removes affirmative action requirements for small/minority/women-owned businesses - all subsequent term numbers shift up by one

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2. Construction Bond Threshold (Term 8 formerly 9)

What Changed: Simplified Acquisition Threshold increased

April 2024: $250,000

November 2025: $350,000

Additional Change:

• November 2025 adds: "Subgrantees of fixed amount subgrants made under the authority of Term 52 below are not required to comply with 2 CFR 200.326."
• Exempts fixed amount subgrantees from bonding requirements

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3. Low-Cost Service Option (Term 29 formerly 31)

What Changed: Restructured and simplified requirements

Significance

• Removes middle-class affordability component
• Removes ACP references (program ended)
• Makes requirements more specific (speed/latency thresholds)
• Allows use of existing plans if they meet criteria

April 2024 (Term 31 - "Affordability and Low-Cost Plans")

• References both low-cost plan requirement AND middle-class affordability plan
• States grantee will describe both in Initial and Final Proposals
• Requires ensuring services allow use of Affordable Connectivity Program or successor
• Requires subgrantees continue offering low-cost option during Federal Interest Period

November 2025 (Term 29 - "Plans")

• Title changed from "Affordability and Low-Cost Plans" to just "Plans"
• Removes all references to:
  • Middle-class affordability plans
  • Affordable Connectivity Program
  • Initial and Final Proposal descriptions
• Adds specific requirements: Low-cost option must offer speeds of at least 100/20 Mbps and latency of ≤100ms
• Adds: "Applicants that already offer a low-cost plan that meets these service requirements may satisfy the low cost service option requirement by proposing, in their application, to offer their existing low-cost plan to eligible subscribers"
• Still references corrective action including recoupment per 47 U.S.C. § 1702(h)(5)(C)

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4. Term 30: Now "Reserved"

What Changed:

• April 2024: Term 30 was "Conduit Access Points" with requirements for interspersed conduit access points, excess conduit capacity, etc.
• November 2025: Term 30 is marked "Reserved" with note "Error! Bookmark not defined."

Content moved to Term 33: The conduit access points requirements appear to be incorporated into revised Term 33 (Deployment and Provision of Service Requirements)

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5. Network Capabilities (Term 27 formerly 28)

What Changed: Removed specific deployment authorization

April 2024 (Term 28):

• Included requirement that "any subgrant agreement for a Funded Network permits the Subgrantee to use the subgrant to deploy broadband infrastructure in or through any area required to reach interconnection points or otherwise to ensure the technical feasibility and financial sustainability of a project"

November 2025 (Term 27):

• Removes the above provision about deploying through any area to reach interconnection points
• Otherwise identical (references quality-of-service standards, speed/latency, network outages per NOFO IV.C.2.a and Performance Measures Policy Notice)

Note: The interconnection deployment authorization moved to Term 33 (Deployment and Provision of Service Requirements)

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6. Consumer Protections and Interconnection (Terms 32, 35) - Removed 

What Changed:

April 2024 had separate terms:

• Term 32: Consumer Protections (no data caps, no unjust network management practices, acceptable use policies OK, semiannual certification required)
• Term 35: Interconnection Requirements and Wholesale Access (Middle Mile interconnection requirements, remedial action if subgrantee can't provide retail service, network sale requirements)

November 2025:

• Both terms removed as separate items
• Consumer protection content (data caps prohibition, etc.) appears to be removed entirely or relocated - not visible in November 2025 GTCs
• Interconnection/wholesale content incorporated into revised Term 33 (Deployment and Provision of Service Requirements)

Significance:

• Data caps prohibition may have been removed (significant policy change if so)
• Network management practice restrictions may have been removed
• Interconnection requirements consolidated into broader deployment term

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7. Audit Requirements (Term 38 formerly 40)

What Changed: Audit threshold increased; subrecipient language clarified

Significance

• Raises audit threshold by $250,000, reducing audit burden
• Clarifies subrecipient vs. commercial entity distinction
• Adds batching option
• More explicit about document request authority

April 2024 (Term 40):

• Threshold: $750,000 or more
• Commercial entities expending $750,000 or more must submit audit
• States "NTIA, DOC OIG, or another authorized Federal agency may conduct an audit"

November 2025 (Term 38):

• Threshold: $1,000,000 or more (both for 2 CFR Part 200 Subpart F entities and commercial entities)
• Changes "unless otherwise specified in the terms and conditions" to "Subrecipients that are not subject to Subpart F"
• More specific: commercial entities are "subrecipients" not subject to Subpart F
• States subgrantees "may batch their audit submission to the Grantee when allowable and/or required by the Grantee"
• Changes "may conduct" to "may request audit documents or conduct an audit"

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8. Major Purpose Test (Term 46 formerly 45)

What Changed: Addition of LEO Capacity Subgrants provision

Significance: Clarifies LEO satellite subgrants are always treated as infrastructure projects regardless of cost breakdown

April 2024 (Term 46):

• Defines broadband infrastructure projects (last-mile, Middle Mile, multi-family Wi-Fi)
• Defines "major purpose" as >50% of costs
• Grantees determine major purpose; NTIA can review/revise

November 2025 (Term 45):

• Identical to April 2024 PLUS adds: "For the purposes of the BEAD program, LEO Capacity Subgrants shall be considered projects whose major purpose is broadband infrastructure."

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9. Fixed Amount Subgrants (Term 52 formerly 51):

What Changed: One technical addition regarding bonding

April 2024 (Term 51):

• Comprehensive exceptions for fixed amount subgrants (removed Cost Principles, modified Procurement Standards, equipment title vests in subgrantee, etc.)

November 2025 (Term 52):

• Identical to April 2024 EXCEPT:
• In Section 51.C.2.b: Adds "(including contractors and subcontractors of Subgrantees)" when discussing NTIA consent for equipment sale/lease/transfer
• More explicit about who needs consent

Note: The April 2024 version was Term 51; November 2025 is Term 52 because of insertion of new Terms 50 and 51

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IV. Summary of Structural Changes

Term Renumbering

Due to removal of old Term 4 (small business contracting) and addition of two new major terms (50 and 51), all terms from old Term 5 onward shifted:

April 2024 → November 2025 Mapping:

• Terms 1-3: Unchanged numbers
• Term 4: Removed entirely
• Terms 5-49: Renumbered as Terms 4-48
• NEW Terms 50-51: Added
• Term 51: Renumbered as Term 52

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V. Critical Dates and References

Controller Alert Rescission:

• February 18, 2025: Controller Alert CA-23-6 (Investing in America Emblem) rescinded via Controller Alert 25-01

Inspector General Report:

• March 2025: DOC OIG released report (OIG-25-014-I) noting state/local permitting delays affecting broadband deployment

BEAD Restructuring Policy Notice:

• June 2025: Published - now third in hierarchy of authorities

Department of Commerce Terms Update:

• September 22, 2025: Updated DOC General Terms and Conditions

Uniform Guidance Update:

• October 1, 2024: Updated Uniform Guidance effective date

NTIA Guidance Documents Referenced:

• Smart Start: How to Plan and Prepare for NEPA Compliance for BEAD (April 2024)
• Permitting Roundtables Implementation Guide
• Environmental Screening and Permitting Tracking Tool (ESAPTT) in NGP

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VI. Quick Reference Comparison Table

Topic	April 2024	November 2025	Change Type
Hierarchy of Authorities	5 tiers	6 tiers (adds Restructuring Policy Notice)	Revision
State Rate Regulation	No restrictions	Preempted for all subgrantees statewide	NEW
Net Neutrality	No restrictions	Preempted for all subgrantees statewide	NEW
Future Federal Funding	No restrictions	Prohibited via required certification	NEW
Permitting Timeline	No specific requirement	90 days mandatory	NEW
Permitting Roundtables	Not required	Mandatory	NEW
Signage	Encouraged with branding	Existing signs may remain	Revision
Small Business Contracting	Affirmative steps required	Requirement removed	Removed
Local Coordination	Extensive ongoing requirements	Limited to certification	Revision
Environmental Tool	Submit to NTIA for review	Use ESAPTT in NGP	Revision
Tribal Notification	Via TCNS system	Via preferred means	Revision
Bonding Threshold	$250,000	$350,000	Increase
Audit Threshold	$750,000	$1,000,000	Increase
Low-Cost Plan Detail	General requirement	100/20 Mbps, ≤100ms required	More specific
ACP Reference	Required consideration	Removed	Removed
Middle-Class Affordability	Required in proposals	Removed	Removed
Data Caps Prohibition	Explicit term	Appears removed	Removed
Consumer Protections Term	Separate term	Appears removed/relocated	Restructured
LEO Capacity Subgrants	Not mentioned	Federal interest exemption	NEW
Federal Interest - Infrastructure	10 years	10 years (unchanged)	No change

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Notes

1. See 47 U.S.C. § 1702(h)(5)(D) (“Nothing in this subchapter may be construed to authorize the Assistant Secretary or the National Telecommunications and Information Administration to regulate the rates charged for broadband service.”).
2. Broadband Serviceable Locations (BSLs) are specific residential or business structures in the U.S. where fixed mass-market broadband internet can be installed, forming the foundation of the FCC's National Broadband Map, with each BSL representing a physical building (like a house, apartment building, or office) that's a potential point for service, identified by coordinates and addresses for mapping broadband availability.

This article is intended only as a quick comparison of the April 2024 and November 2025 documents. Please review those documents for more details.

The Benton Institute for Broadband & Society is a non-profit organization dedicated to ensuring that all people in the U.S. have access to competitive, High-Performance Broadband regardless of where they live or who they are. We believe communication policy - rooted in the values of access, equity, and diversity - has the power to deliver new opportunities and strengthen communities.

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