FCC Advances Implementation of the Resilient Networks Act

The FCC’s January 2024 order implementing the Resilient Networks Act compels wireless carriers to document roaming agreements, expand DIRS participation, and formalize disaster reporting, prompting enterprises to revisit telecom continuity governance.

Kodi C.

Editor & Research Lead

Reviewed for accuracy by Kodi C.

Infrastructure supply chain and reliability briefings

The US Federal Communications Commission (FCC) adopted an order on 25 January 2024 to implement the Resilient Networks Act, legislation enacted after the 2022 Hurricane Ian review. The order obliges facilities-based mobile network operators to maintain, document, and disclose mutual aid and roaming agreements, expands participation in the Disaster Information Reporting System (DIRS), and standardizes outage reporting and public communications during emergencies. Enterprises that depend on carrier services for critical operations must understand the new obligations to recalibrate continuity plans, vendor oversight, and incident escalation workflows.

Mutual aid and roaming requirements

The FCC now requires each facilities-based wireless provider to file an annual certification describing the status of mutual aid arrangements, steps taken to negotiate agreements, and barriers encountered. Providers must maintain contact lists for potential roaming partners, test interoperability, and report on any limitations. During disasters, carriers must cooperate in good faith on roaming and infrastructure sharing. The FCC can compel explanations if providers decline assistance. Teams should request updated documentation from their primary carriers, ensuring it covers fallback roaming, spectrum compatibility, and traffic prioritization for critical users.

DIRS participation and reporting cadence

The order broadens DIRS to include additional service categories—such as satellite providers, backhaul operators, and certain broadband suppliers—and codifies expectations for prompt, accurate reporting. Providers must submit status updates at least daily during activation, covering cell site outages, generator fuel levels, power restoration estimates, and public safety answering point (PSAP) impacts. The FCC emphasizes data quality and may take enforcement action for incomplete submissions. Businesses should integrate DIRS data feeds into their network operations centers, using the information to inform crisis communications and adjust redundancy strategies.

Consumer and stakeholder communications

Carriers must deliver timely, accessible outage updates to customers, public safety agencies, and relevant government bodies. The order encourages multi-channel communications (SMS, email, websites, social media) and requires providers to document when and how notifications are issued. FCC staff may request these records during post-event reviews. Teams should evaluate whether carrier communication protocols align with their own crisis messaging needs, particularly for critical infrastructure sectors subject to Department of Homeland Security directives.

Disaster preparedness obligations

The FCC expects providers to maintain updated disaster response plans, including contact information for emergency operations centers, fuel resupply contracts, backup power arrangements, and inventory of deployable assets such as COWs (cells on wheels). Plans must be reviewed annually, and carriers must conduct exercises to validate coordination with state and local authorities. Teams should ask carriers for evidence of exercises, identify dependencies on shared infrastructure, and align their own resilience testing schedules.

State and local coordination

The order reinforces the Wireless Resiliency Cooperative Framework, urging providers to coordinate with state emergency management agencies, utilities, and public safety officials. Carriers must share situational awareness data, participate in joint planning, and engage in after-action reviews. Teams with facilities in multiple jurisdictions should track how their carriers interface with state emergency operations centers, as regional variations could influence service restoration timelines.

Implications for enterprise governance

Businesses should refresh telecom continuity plans to incorporate FCC expectations. Key actions include: cataloguing primary and secondary carriers with associated mutual aid arrangements; updating escalation matrices to reflect DIRS reporting cadence; integrating carrier outage notifications into internal crisis management platforms; and revising service-level agreements to reference the Resilient Networks Act obligations. Governance teams should brief executive leadership on potential regulatory enforcement if carriers fail to cooperate and ensure vendor risk assessments capture resilience posture.

Supply chain and contract management

Procurement teams must review contracts to confirm carriers commit to compliance, provide evidence of annual certifications, and support customer-specific continuity requirements (for example, priority roaming for critical staff). Enterprises may negotiate clauses requiring carriers to share DIRS submissions or provide custom dashboards. When working with managed service providers or mobile virtual network operators (MVNOs), teams should verify that upstream carriers’ obligations flow down contractually.

Interoperability and testing

The FCC’s emphasis on roaming readiness highlights the importance of cross-carrier testing. Teams should coordinate with carriers to validate that devices, SIM profiles, and authentication mechanisms function across roaming partners, particularly for IoT deployments and mission-critical push-to-talk services. Testing should encompass authentication, quality of service, and emergency calling capabilities. Results should be documented for internal audits and to show due diligence to regulators or insurers.

Regulatory reporting and audits

The FCC signaled that it may audit carrier compliance, reviewing certification filings, exercise records, and outage notifications. Teams should maintain their own logs of carrier performance during incidents, capturing timelines, communications received, and service restoration milestones. These records support escalation if carriers fall short and inform post-incident reviews. They also provide evidence for compliance with sector-specific requirements such as the Federal Energy Regulatory Commission’s (FERC) reliability standards or healthcare continuity obligations.

Integration with broader resilience frameworks

Teams should map the FCC requirements to existing business continuity and emergency management standards (ISO 22301, NFPA 1600). Doing so ensures consistent governance across telecom, power, data center, and cloud dependencies. Incorporating carrier obligations into enterprise risk assessments enables boards to evaluate residual risk and budget for additional redundancy—such as multi-carrier aggregation, satellite backup links, or private wireless networks.

Next steps for enterprises

Immediate priorities include engaging carrier account teams to obtain updated disaster plans, requesting evidence of mutual aid certifications, and aligning incident response runbooks with DIRS reporting cadence. Over the next quarter, enterprises should conduct joint tabletop exercises with carriers, update vendor scorecards to incorporate resilience metrics, and ensure procurement processes capture the new regulatory obligations. Longer term, teams may explore diversifying connectivity strategies, investing in private 5G or fixed wireless alternatives to reduce dependence on a single carrier’s disaster recovery posture.

The FCC’s Resilient Networks Act order signals a shift from voluntary cooperation to enforceable obligations for wireless resilience. Enterprises that early align governance, contracts, and continuity planning with the new requirements will be better positioned to maintain operations during disasters and to hold carriers accountable for performance.

Financial and insurance considerations

The new obligations may influence carrier pricing and service credits, as providers invest in backup power, satellite links, and field service resources. Teams should model potential cost impacts, evaluate whether existing telecom expense management tools capture resilience-related charges, and review business interruption insurance policies to ensure they cover connectivity outages. Insurers may request evidence that teams have diversified connectivity and scrutinised carrier compliance, making preventive documentation essential.

Architecture considerations

Infrastructure architects and platform teams should evaluate the architectural implications of this development:

Integration patterns: Assess how this component integrates with existing infrastructure services and data flows. Identify required API changes, protocol updates, or middleware modifications.
Scalability impact: Evaluate whether this change affects horizontal or vertical scalability characteristics. Plan for capacity adjustments and update auto-scaling policies as needed.
High availability: Review redundancy and failover configurations to ensure continued resilience. Update health check mechanisms and failover procedures to reflect new deployment characteristics.
Data persistence: If applicable, assess data migration, backup compatibility, and storage requirements associated with this change. Validate data integrity across upgrade paths.

Document architectural decisions and update reference architectures to guide future deployments and ensure organizational consistency.

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References

FCC — FCC Advances Resilient Networks Act Implementation (January 25, 2024) — www.fcc.gov
FCC — Report and Order Implementing the Resilient Networks Act — docs.fcc.gov
ISO/IEC 27017:2015 — Cloud Service Security Controls — International Organization for Standardization

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