FCC ADOPTS THE FUNDING YEAR 2026 E-RATE ELLIGIBLE SERVICES LIST (ESL)

On December 17, 2025, the FCC’s Wireline Competition Bureau adopted and released the final Eligible Services List (ESL) for Funding Year (FY) 2026 and authorized USAC to open the FCC Form 471 application filing window. CSM expects USAC to announce the filing window soon, and that it will follow a typical cycle: opening mid-January and closing the third week of March.

You can read the FCC Order here: FCC FY2026 Eligible Services List Order (DA 25-1069). CSM is proud to have contributed to the record of comments on the ESL, and while not all of our suggestions were adopted, the FCC indicated that it may seek further changes to the program in a future rulemaking.

WHAT THE FY2026 ESL MEANS FOR DISTRICT TECHNOLOGY

The ESL is the FCC’s official, controlling list of what is eligible for E-Rate discounts each year, and it applies to FY2026 funding requests.

HERE ARE SOME KEY TAKEAWAYS:

1. Software & remote support are now classified as Internal Connections. The Bureau corrected a long-standing issue by treating currently eligible software- and remote-based services like bug fixes, security patches, remote technical support, and remote configuration the same as the internal connections equipment they support. CSM considers this to be a big win for the E-Rate community. This will enable our clients to seek full funding for multi-year contracts in the year the payment for these services are made.

2. Basic Maintenance (BMIC) is narrowed to on-site maintenance. BMIC is now considered to include configuration changes performed in person, on-site (not remote) as well as time and materials.

3. No FY2026 changes to Managed Internal Broadband Services (MIBS).Even though the FCC sought comment, the Bureau made no changes to MIBS eligibility for FY2026 and indicated it will seek further comment in the future.

4. Advanced/modern firewall services are still not added to E-Rate. The Bureau declined requests to expand E-Rate eligibility for advanced or modern firewall services/features; only basic firewalls are E-Rate eligible.

5. Eligibility of DNS/DHCP remains limited. For FY2026, the FCC declined to expand standalone eligibility; DNS and DHCP remain eligible as Category One only when provided as a standard component of a vendor’s Internet access service with no separately identifiable cost.

RECOMMENDED NEXT STEPS (PRACTICAL CHECKLIST)

• Review the FY2026 ESL with your CSM consultant and confirm your planned projects align with eligible components/categories.

• For existing multi-year BMIC contracts that are now considered to be internal connections, your CSM consultant will review with you how funding reimbursement will now be improved.