How and where do we file the annual CPNI certification in EB Docket 06-36?

The deadline

The rule sets March 1, for data pertaining to the previous calendar year (47 CFR § 64.2009(e)). When that date falls on a weekend or federal holiday, the filing moves to the next business day (47 CFR § 1.4(e)(1), (j)), which is why the 2026 filing was due March 2 (DA 26-139). March 1 is a Monday in 2027 and a Wednesday in 2028. There is no small-company exemption (DA 26-139).

Where and how

• In ECFS, the FCC’s Electronic Comment Filing System, referencing EB Docket No. 06-36 in the “proceeding” field; or through the FCC’s web-based CPNI application, which has its own instructions (DA 26-139).
• One certification for each affiliate with a unique Form 499 Filer ID (DA 26-139).
• Do not send copies to the Enforcement Bureau or its staff unless a consent decree requires it (DA 26-139).
• It is not your Form 499 or universal service filing; those are separate (DA 26-139).

What the filing contains

The FCC’s suggested template asks for the date filed, the companies covered, the Form 499 Filer ID, and the officer’s name and title, then the certificate. Attach the statement explaining how your procedures ensure compliance, an explanation of any actions against data brokers, and a summary of customer complaints about unauthorized release of CPNI, or an affirmative statement that there were none (§ 64.2009(e); DA 26-139). Questions go to EB-TCD-Privacy@fcc.gov. Failure to comply can bring forfeitures of up to $251,322 per violation or per day, up to $2,513,215 (§ 1.80(b)(2); DA 26-139).

Last reviewed: September 30, 2026

General information drawn from the rule text and the FCC documents listed below — not legal advice. You review, sign and submit your own filings.