Facilities-Based International Carriers Must File Route Lists with FCC by November 14, 2018


The Federal Communications Commission (“FCC”) recently released filing requirements for certain carriers holding international Section 214 authority, which requires that these carriers file and maintain international route lists as laid out in Section 63.22(h) of the FCC’s rules. The filings must be submitted no later than November 14, 2018.  This filing requirement was adopted in 2017, as the FCC eliminated the requirement for annual traffic and revenue reporting.  These lists will provide FCC the information needed for potential merger review and to monitor route competitiveness.

Who Must File

International facilities-based service providers who provide FCC international Section 214 facilities-based services must file and continuously update a list of all U.S.-international routes where they have direct termination arrangements with a foreign carrier.

However, the FCC does not require listing routes where the U.S. carrier has no arrangement with a carrier in the destination market, but instead provides service to that market via arrangements with a third party carrier in intermediate countries.

When to File

  • Initial Route List: Current international facilities-based service providers must file their initial route list by November 14, 2018. New international facilities-based providers, or those without an existing direct termination arrangement, must file its list within thirty (30) days of entering into any new direct termination arrangements.
  • Updated Route List: After providing the FCC the list, the international facilities-based service providers must update the list within thirty (30) days after either adding a termination arrangement or discontinuing an arrangement for a previously listed destination.

What to File

International Facilities-based service providers are required to include the following in their initial and updated lists:

  1. The company’s name;
  2. List of all international Section 214 authorizations held by service provider, as indicated by FCC file number (e.g., ITC-214-20030303-00003);
  3. List of all U.S.-international routes where the service provider has a direct termination arrangement with a foreign carrier;
  4. For updated lists, the update must include a summary of the changes to the previously-reported routes; and
  5. A signed certification by a company officer verifying the completeness and accuracy of the list, which includes the name and title of the certifying officer; physical address, telephone number and e-mail of the certifying officer; and the physical address, telephone number and e-mail of the company’s official contact or attorney of record.

How to File

Providers must file their route lists electronically, in PDF format, within the International Bureau Filing System (“IBFS”) Filing System. Step-by-step instructions for filing these lists can be found here. The FCC further encourages filers to email a courtesy copy of any route submissions to internationalroutelist@fcc.gov.


The FCC stated that they will not treat international route list filings as available for public inspection. Filers can indicate they want confidential treatment through the IBFS filing system, and should further label each page of the list filing as containing commercial proprietary information exempt from public disclosure under the Freedom of Information Act and Section 0.459 of the FCC’s rules.

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