A copper retirement notice is the filing an incumbent local exchange carrier makes with the FCC before it removes or disables copper loops, or replaces them with fiber. The rules at 47 CFR §§ 51.325–51.333 set out what it must contain, who must be served directly, and how long the carrier must wait. The FCC moved to remove the filing and objection process in an April 2026 order, but the two sections that change most of these mechanics are delayed indefinitely — so what follows is still in force.
What Counts as a Copper Retirement
The rules define a copper retirement as the removal or disabling of copper loops, subloops, or the feeder portion of such loops or subloops — or their replacement with fiber-to-the-home or fiber-to-the-curb loops. The same section requires public notice of any network change that will affect a competing service provider's ability to provide service, affect the incumbent carrier's interoperability with other providers, or result in a copper retirement (47 CFR § 51.325).
The obligation sits with the incumbent carrier that owns the copper, not whichever reseller bills you, and the trigger is the disabling of the copper itself — not a change to the service on your invoice.
What the Notice Has to Contain
A public notice of a planned network change must include, at minimum, the carrier's name and address; the name and telephone number of a contact who can supply additional information; the implementation date; the location or locations where the changes will occur; a description of the type of change, including the technical specifications, protocols and standards involved where they apply; and a description of the reasonably foreseeable impact of the change (47 CFR § 51.327).
How and Where the Notice Gets Filed
An incumbent carrier has two permitted methods: file a public notice with the Commission, or give public notice through industry fora, industry publications, or its own publicly accessible website — in which case it must also file a certification identifying the changes, confirming that notice was given in compliance with the rules, and describing where the information lives (47 CFR § 51.329).
A filing must carry a prescribed title — for a copper retirement, "Public Notice of Copper Retirement Under Rule 51.333" — and go through the Commission's Electronic Comment Filing System using the "Submit a Non-Docketed Filing" module. The date the system receives it is the official filing date, and the notice must stay available and accurate until the change is implemented.
General network-change notice runs at least twelve months ahead, or six months where the change can be completed within twelve months of the make/buy decision, with short-term procedures for anything inside six (47 CFR § 51.331).
The 90-Day Clock, and Who Can Object
A copper retirement notice goes to the Commission with a certificate of service showing the carrier served a copy on every telephone exchange service provider that directly interconnects with its network — at least five business days before filing. For copper retirements, service may be made by posting on the carrier's website where the interconnecting provider has agreed to receive notice that way (47 CFR § 51.333).
The notice is then deemed final on the 90th day after the Commission releases its public notice of the filing. Where the copper facilities are not used to provision services to any customers, that shrinks to the 15th day — but a carrier may not give less than 90 days' notice where those facilities do serve customers. A directly interconnecting information service provider or telecommunications carrier that cannot accommodate the change can object within nine business days of the public notice, with an officer's affidavit; the carrier's response is due by the fourteenth business day. An objection is deemed denied 90 days after the public notice unless the Commission rules otherwise, and until it rules or that period expires, the carrier may not retire the copper at issue.
What the FCC Changed in April 2026
The Commission's Report and Order, "Reducing Barriers to Network Improvements and Service Changes," was adopted March 26, 2026, released March 27, 2026, and published April 20, 2026 in WC Docket Nos. 25-208 and 25-209 (91 FR 20913).
It eliminates all filing requirements in the network change disclosure rules, plus the Commission's public-notice and objection process for short-term network changes and copper retirements — codifying relief the Wireline Competition Bureau had already granted. Carriers must still post public notice through industry fora, industry publications or a publicly accessible website — not behind a paywall — rather than filing it with the Commission. They must also keep giving direct notice of copper retirements and short-term network changes to directly interconnected telephone exchange service providers, to 911 service providers, and to directly interconnecting carriers that support essential 911 functions. The order states that the rules do not negate notice obligations in privately negotiated contracts, and that they do not relieve a carrier of obtaining Commission authorization where a retirement also results in a service discontinuance.
Two things qualify that. The order is effective May 20, 2026 except for the instructions amending §§ 51.329 and 51.333, which are delayed indefinitely until review of the information collections finishes — the Commission will announce that date by public notice. And the codified rules still read as before: in the eCFR edition in force on September 15, 2026, both sections appear in their earlier form with the amendment flagged as pending.
The order also states that neither Section 251(c)(5) nor the implementing rules impose end-user notice obligations, so carriers notify end users as a matter of practice, not obligation.
What This Means If You Still Buy Copper-Based Services
Read the process for what it is: an interconnection filing aimed at other carriers and 911 service providers, not a customer notice.
Inventory every circuit that still depends on copper — fire alarm, elevator phones, security panels, nurse call paths, alarm and fax lines — and name one owner for the list. Ask your carrier in writing for the retirement plan and dates touching your sites, and keep the answer. Put the replacement path into the same contract cycle as the retirement, and test it end to end after cutover.
Two references help before that conversation. What the FCC's POTS forbearance changed covers the regulatory side, and what happens when a carrier sends a disconnection notice covers the clock that starts once a retirement becomes a service change on your account. To see where your exposure sits first, the copper sunset risk assessment walks a portfolio site by site.
A retirement notice is a date on someone else's calendar until you turn it into a plan. Tell us what your sites still run on copper and we will map the replacements and the compliance layers — the voice network obligations that travel with the service, the certifications that belong to the equipment maker, and the deployment work that is ours.
About the author
Carter Dewey
Carter Dewey is CEO & Founder of TrustedNetworx, helping multi-site organizations navigate telecom modernization, POTS replacement, and AI-powered operations — translating complex infrastructure challenges into practical, phased migration roadmaps.