E-RATE UPDATE | November 12, 2026
It’s Official: Your FY2027 E-Rate Rules Are Set
No surprises, no new hoops. On November 10, 2026, the FCC’s Wireline Competition Bureau adopted the final Eligible Services List (ESL) for Funding Year 2027 in Order DA 26-1220. The list is unchanged from what the Bureau proposed in June.
That’s good news if you’re planning purchases now. The rules you used for FY2026 carry forward, so you can start your Form 470 and RFPs with confidence. But a few big questions were on the table this year, and how the FCC answered them matters for your budget and your long-term planning.
The Big News at a Glance
Managed Wi-Fi Survives Another Year
Managed internal broadband services (MIBS) remain fully eligible for FY2027. The Bureau had asked whether MIBS should be limited by school size, restricted for applicants who own their equipment, or eliminated outright. The community answered loudly.
Every commenter who addressed MIBS supported keeping it. Commenters also opposed paying MIBS on an hourly, ticket-by-ticket basis. One commenter argued that hourly billing rewards providers when networks break, while fixed-price managed service rewards them when networks stay up.
The numbers helped make the case. Funds For Learning reported that MIBS accounts for about 3.5% of Category Two commitments and 1.45% of all E-Rate commitments. The median request was $5,850 per year, and 67% of requests were under $10,000. In FY2025, MIBS reached 11,039 sites serving over 4.8 million students.
Don’t get comfortable, though. The order says MIBS eligibility or reimbursement rules may change in future years. The Commission is still reviewing the question in its June 2026 rulemaking (FCC 26-41). If you rely on managed Wi-Fi, now is a good time to make sure your contracts clearly itemize eligible equipment and services.
Network-as-a-Service: Still a No
Standalone Network-as-a-Service (NaaS) remains ineligible for FY2027. Lumen asked the FCC to fund NaaS under Category One, arguing it runs on already-eligible Internet and Ethernet services. Supporters said pay-as-you-go pricing could cut costs when demand drops, such as over the summer.
The Bureau declined. Funding variable monthly pricing would require redesigning Forms 470 and 471 and add administrative burden. It could also weaken competitive bidding, since low usage estimates might win bids and then fall short. NCTA added that variable pricing would make budgets less predictable, both for schools and for the fund.
What this means for you: Keep requesting Category One services at a fixed price. You can still mark a service as burstable on the Form 471, but the cost you request must be fixed.
Asked For, Not Added
Commenters pushed for several new items. The Bureau declined all of them, noting that the ESL process interprets current rules rather than rewriting them.
|
Request |
FY2027 answer |
|
Advanced and next-generation firewalls |
Not added. Being studied in the Schools and Libraries Cybersecurity Pilot. Basic firewall rules are unchanged. |
|
AI security monitoring and governance tools |
Not added as a new Category Two service. |
|
“Network modernization” category or separate capital funding |
Not added. Category Two budgets work as before. |
|
Standalone DNS and DHCP |
Still ineligible. Eligible only when included as a standard part of your Internet access service. |
Bottom line on security: If cybersecurity is your priority, the E-Rate ESL won’t cover advanced tools this year. Watch the Cybersecurity Pilot for where that conversation goes next.
Key Dates
FCC rules require the final list at least 60 days before the Form 471 window opens, so the window can’t open before January 9, 2027. USAC will announce the actual dates.
Your FY2027 Action Checklist
☐ Download the FY2027 ESL and keep it handy while you write your Form 470 and RFPs.
☐ Check your remaining Category Two budget before planning internal connections purchases.
☐ Request software, bug fixes, security patches and remote support as Category Two Internal Connections, alongside the equipment they support.
☐ If you use managed Wi-Fi, confirm your contract itemizes eligible equipment and services.
☐ Request Category One services at a fixed price, not usage-based NaaS pricing.
☐ Make sure any firewall, DNS or DHCP request matches the ESL rules.
☐ Watch for USAC’s announcement of the FY2027 Form 471 window dates and remember the 28-day wait after your Form 470 posts.
Questions? Reach out to your E-Rate Account Manager before the filing window opens.
Resources
• FCC Order DA 26-1220: Final Eligible Services List for Funding Year 2027 (released November 10, 2026)
• Draft FY2027 ESL Public Notice, DA 26-647 (June 30, 2026)
• USAC Eligible Services List page, with past years’ lists and the ESL Glossary
• USAC Cybersecurity Pilot Program
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