As schools and libraries move into the fall, now is the time to begin planning for Funding Year 2027 (July 1, 2027 – June 30, 2028) while staying current on important FCC and USAC developments. Here’s what e2e Exchange clients need to know.

Funding Year 2027 Form 470 — Action Needed

e2e has sent a Form 470 Confirmation Document via PandaDoc. Please review and select the services and equipment you intend to purchase and utilize during FY 2027. The services available for selection include:

  • Category One Internet access (we have your current Internet accounts/contracts on file)
  • Category One Dark Fiber or Self-Provisioned Network with Special Construction
  • Category Two monthly services (Basic Maintenance of Internal Connections or Managed Internal Broadband Services)
  • Category Two Internal Connections

What is a Form 470?
A Form 470 is the E-Rate form that opens a required 28-day competitive bidding window. Any E-Rate-registered vendor may bid on the services or equipment listed. E-Rate rules require a fair and open process in which all vendors are treated equally during the bidding window.

Who needs to post a Form 470?
You generally need a Form 470 if any of the following apply:

  • You are at the end of a multi-year Category One or Category Two contract and need to sign a new one for the upcoming funding year
  • You have month-to-month services, or you are under a contract that was signed without a Form 470 at the time
  • You are planning any new services for your Form 471 applications
  • You are purchasing Category Two equipment (these are not multi-year contracts)

Category One Services Explained

  • Leased Lit Fiber: A fiber-based broadband service in which the service provider owns and manages the network. The applicant pays a fee for data transport to its locations.
  • Leased Dark Fiber: The applicant leases a portion of the provider-owned and maintained fiber network and pays to have the fiber lit so it can transmit data.
  • Self-Provisioned Network: The applicant owns the network completely and is responsible for maintaining it. The applicant hires a vendor to construct the network.
  • Special Construction: Upfront, non-recurring costs associated with the installation of new fiber to or between eligible entities.

Please complete and return the PandaDoc confirmation so we can prepare your Form 470 accurately and on time.

When Planning for FY2027: Prepare for E-Rate Procurement Changes

Schools and libraries planning for FY2027 have an additional reason to start procurement early: significant changes to the E-Rate competitive bidding process are coming for FY2028.

On April 30, 2026, the FCC adopted a Report and Order (FCC 26-30) that creates a new centralized competitive bidding portal and makes several program simplifications. The portal will be operational for the 2028 funding year. Any Form 470s filed on or after July 1, 2027 will go through the portal.

How the new portal will work
Once a Form 470 is certified, the portal will centralize the competitive bidding process. Service providers will upload bid responses to the portal (rather than sending them directly to applicants), and applicants will be notified. All correspondence, clarifications, evaluation documents, and contracts related to the Form 470 must be uploaded there. Questions and answers will also be handled in the portal. Applicants’ notices of award and related contracts/documents will need to be uploaded as well.

Key benefits and related changes
Documentation uploaded to the portal will satisfy E-Rate’s 10-year retention requirement, so applicants will not be required to retain local copies of those materials. Portal access will be limited to the library or school account administrator and up to two other individuals (including consultants). USAC will provide training and stakeholder input opportunities before launch.

Other changes beginning in funding year 2028 include:

  • Form 486 eliminated — CIPA compliance will be certified on the Form 471 instead.
  • Invoice deadline extensions — Applicants or service providers can request a one-time 120-day extension of the invoice deadline if the request is made within 15 days after the original deadline (no lengthy FCC waiver process required).
  • Mid-year bandwidth increases — Applicants can submit a service substitution to increase bandwidth during a funding year for unanticipated needs (no increase to the original funding commitment amount is allowed).
  • Spam bids — Applicants may disqualify bid responses that lack complete cost information or that simply ask the applicant to contact the provider, provided the reason for disqualification is documented.

Why this matters for FY2027
For organizations that know they will need ongoing services or equipment, FY2027 is a good opportunity to complete procurement before the new portal is introduced.

  • Category One services: If you are planning to procure internet access or data transport, consider whether a multi-year agreement or an agreement with optional extensions makes sense.
  • Category Two services and equipment: Completing procurement in FY2027 may help you avoid navigating the new bidding system while also meeting E-Rate deadlines.
  • Multi-year or phased projects: A multi-year procurement may provide greater flexibility for equipment purchases spanning more than one year.

A procurement completed in FY2027 does not eliminate all future E-Rate requirements, but it can mean one fewer competitive bidding process to manage during the FY2028 transition.

Documentation will be more important than ever
Applicants should maintain thorough procurement records, including:

  • Vendor bids and proposals
  • RFPs and Form 470 information
  • Bid evaluation and selection records
  • Communications with vendors
  • Contracts and amendments
  • Delivery and acceptance documentation
  • Purchase and installation dates
  • Equipment and asset records
  • Licensing and renewal information

Complete records make it much easier to respond to future USAC requests and demonstrate that procurement was conducted properly. e2e maintains all documentation on file for our clients.

FCC Review of the E-Rate Program (FCC 26-41)

From time to time, the FCC reviews the E-Rate program to ensure it continues to meet the evolving needs of schools and libraries. The FCC recently released FCC 26-41, seeking input from schools, libraries, service providers, consultants, and other stakeholders. No changes have been finalized; the program continues to operate under current rules.

Initial comments were due October 13, 2026. Reply comments are due approximately November 12, 2026. This proceeding (WC Docket No. 26-133) provides an opportunity for the E-Rate community to share real-world experiences as the FCC considers potential updates.

What the FCC is considering
FCC 26-41 seeks stakeholder input on a broad range of topics, including:

  • The future of E-Rate — How the program should evolve as connectivity needs change, which services should remain eligible, and whether certain communities (including rural ones) may need additional consideration.
  • Screen time and CIPA requirements — Issues related to student screen time and the use of E-Rate-supported networks and services, as well as aspects of the Children’s Internet Protection Act (CIPA) involving filtering, monitoring, personal devices, parental controls, and technology use in schools and libraries.
  • E-Rate consultants — Potential updates to registration, annual certification, disclosure, recordkeeping, and compensation requirements.
  • Competitive bidding and cost-effectiveness — Situations in which an applicant receives only one bid or no bids, and whether additional documentation or justification should be required.
  • Lowest Corresponding Price (LCP) — Whether current rules should be updated and whether additional pricing information could help applicants, service providers, and USAC evaluate cost-effectiveness.

Why E-Rate applicants should consider commenting
This is an opportunity for schools and libraries to share their experiences directly with the FCC. You do not need to be an expert in FCC regulations or address every issue. A comment can simply explain what E-Rate means to your organization and what you believe the FCC should consider.

Helpful topics include:

  • How E-Rate funding supports your organization
  • What services and infrastructure E-Rate helps you obtain and maintain
  • Whether additional eligible services (such as cybersecurity) would be beneficial
  • How a reduction in E-Rate support could affect your technology budget or services
  • What aspects of the current process work well
  • Whether additional administrative requirements could make participation more difficult
  • Challenges your organization experiences
  • Improvements that could make E-Rate more useful, accessible, or efficient

The most helpful comments often come from the people who work with E-Rate every day.

How to file a comment or reply
Go to the FCC’s Electronic Comment Filing System (ECFS): https://www.fcc.gov/ecfs

  1. Click “Submit a Filing.”
  2. Enter the Proceeding/Docket Number: 26-133 (WC Docket No. 26-133).
  3. Select the proceeding that appears.
  4. For Type of Filing, select Comment (or the closest available option).
  5. Enter your name/organization information.
  6. Upload your comments as a PDF.
  7. Review and submit until ECFS confirms the filing was successfully submitted.

FCC 26-41 remains in the proposal and public-comment stage. No changes to the E-Rate program have been finalized as a result of this proceeding.

FY 2026 Funding Status

Wave 23 of Funding Commitment Decision Letters (FCDLs) was issued on September 30, 2026. Total committed funding for FY 2026 is just over $2 billion so far. USAC estimated that total E-Rate funding requested for FY 2026 is about $3.5 billion.

As a client of e2e Exchange, we track each FCDL that is released and send a copy to the applicant for their records. If you have any questions regarding the status of your FCDL(s), please contact your e2e Account Specialist and we will help.

Resources

E-Rate 101 Presentation
e2e is excited to share our online presentation to help you brush up on the E-Rate program, program timelines, and the new Category Two budget cycle.
[E-Rate 101 Presentation]

How e2e Can Help

At e2e Exchange, we work with our clients throughout the entire E-Rate procurement and application process. As you begin planning for FY2027, our team can help you:

  • Evaluate upcoming technology needs
  • Determine what services or equipment may need to be competitively bid
  • Assist with the Form 470 and bidding process
  • Ensure the necessary documentation is maintained

The best time to prepare for FY2028 is during FY2027—not when the new requirements are already in place.

If your organization has upcoming contracts, technology projects, or procurement needs, contact your e2e Account Manager to discuss your FY2027 plans. We can help you determine what should be addressed now and develop a procurement strategy that positions your organization for a smoother transition into FY2028.

Level of Service at e2e

How is e2e doing for you? Are we providing the level of support that you need? All of our clients are very special to us, and we are grateful for your business. We value your opinion and input, as our goal is to provide a high level of service that meets your needs and expectations.

We encourage any and all feedback you may have regarding our service. We pride ourselves on long-term relationships and greatly appreciate the opportunity to work with you over the years. Please let us know how we are doing and if we can improve.

With Kind Regards,
e2e Exchange

About e2e Exchange, LLC

e2e Exchange, LLC was formed to provide E-Rate compliance help and application management services to schools and libraries throughout the nation. Our team of experienced E-Rate specialists shares a high standard of performance and commitment to exceptional customer service. We manage the details, deadlines, and demands of the E-Rate process for our clients while striving to maximize their E-Rate funding potential.

Clients will find that their questions, concerns, phone calls, and emails will always be answered quickly and thoroughly by our dedicated team. Our company prides itself on our focus, commitment, and dedication to providing our clients with the best possible experience throughout the entire application process. We care about all of our clients, and we are passionate about the work we do for them each and every day.

Contact us
Call: 888.522.8096
Email: erate@e2eexchange.com

We are here to help you maximize your E-Rate funding while staying fully compliant.