Documents scheduled for Federal Register publication: July 31, 2026 | Analysis prepared: July 30, 2026

Three material U.S. legal and regulatory developments are scheduled for official Federal Register publication on July 31, 2026. The documents summarized below are public-inspection versions; the published versions should be consulted before calculating formal effective dates or compliance deadlines.

The developments span telecommunications spectrum policy, broadcast infrastructure cybersecurity, and international trade remedies — each carrying distinct implications for Turkish and Turkish-American businesses, investors, and legal practitioners.

The Federal Communications Commission adopted a final rule reallocating 160 MHz in the 3.98–4.14 GHz band (Upper C-band) for terrestrial flexible-use wireless services. The spectrum will be auctioned as eight unpaired 20 MHz blocks using exclusive licenses based on Partial Economic Areas (PEAs). Congress has set a statutory deadline requiring the auction process to be completed by July 4, 2027.

New licensees will be required to finance three categories of transition costs:

The FCC estimates radio-altimeter rebates alone at approximately $3.83–$5.71 billion, allocated among licensees principally according to their respective shares of gross winning bids. This liability is in addition to the auction price and must be modeled as part of the effective cost of spectrum acquisition.

Existing Part 27 rules will generally apply to new licensees, covering:

• Foreign ownership reporting and approval requirements
• Spectrum leasing arrangements
• License transfers, partitioning, and disaggregation
• Construction and deployment benchmarks

Most provisions of the final rule become effective 60 days after Federal Register publication. Specified information-collection provisions require separate OMB approval before taking effect.

The Upper C-band reallocation is the largest domestic spectrum auction since the C-band proceeding completed in 2021. The scale of the radio-altimeter rebate liability — potentially exceeding $5.7 billion — means that the effective cost of spectrum acquisition for winning bidders will substantially exceed the auction price. Bidding models that fail to account for this liability will materially understate the total investment required.

For foreign investors and Turkish telecommunications companies with U.S. operations or investment interests, the foreign ownership reporting and approval requirements under Part 27 and Section 310(b) of the Communications Act are a threshold issue. Licenses held by entities with more than 25% foreign ownership in the broadcast or common-carrier context require FCC approval, and CFIUS review may be separately triggered depending on the ownership structure and the nature of the spectrum use.

Auction participants and bidders: Develop a comprehensive cost model that includes the auction price, estimated radio-altimeter rebate share, satellite relocation contributions, and post-auction deployment capital expenditure. Assess spectrum aggregation limits and any applicable spectrum screen that may restrict bidding in particular PEAs.

Foreign investors and Turkish entities: Conduct a Section 310(b) analysis and assess CFIUS exposure before acquiring interests in spectrum licensees or entities that hold or plan to acquire Upper C-band licenses. Structure investment vehicles to comply with foreign ownership thresholds or obtain advance FCC approval.

Satellite operators and earth-station customers: Review existing service agreements, relocation provisions, equipment replacement obligations, and termination rights well in advance of the 2030–2031 transition dates. Negotiate relocation cost-sharing and service continuity provisions now, before transition timelines become binding.

Lenders and infrastructure funds: Ensure that financing commitments and covenant packages account for the radio-altimeter rebate liability as a senior obligation of the licensee. Assess the effect of the rebate obligation on debt-service coverage ratios and collateral value.

A separate FCC final rule requires all Emergency Alert System (EAS) participants — including broadcasters, cable operators, satellite providers, and other entities required to participate in the EAS — to implement three baseline cybersecurity measures. Compliance is required 60 days after Federal Register publication.

The FCC declined to impose:

• Comprehensive cybersecurity risk-management plans
• Additional incident reporting obligations
• New recordkeeping requirements beyond existing EAS rules

The rule is therefore a targeted, minimum-baseline mandate rather than a comprehensive cybersecurity framework.

EAS infrastructure has been the subject of demonstrated security incidents in which unauthorized parties have accessed EAS equipment and broadcast false emergency alerts. The FCC's rule responds to these incidents by establishing enforceable minimum controls. Failure to comply within the 60-day window exposes EAS participants to FCC enforcement action, including forfeitures.

For Turkish-owned or Turkish-affiliated media companies, broadcasters, and telecommunications operators with U.S. broadcast or cable licenses, this rule creates an immediate compliance obligation. The 60-day deadline is short; entities that have not already inventoried their EAS equipment and assessed their current credential, patching, and network-segmentation posture should begin that process immediately.

Broadcasters and cable operators: Immediately inventory all EAS encoders, decoders, studio-transmitter links, and remotely managed equipment. Identify any equipment currently accessible from the public internet and implement firewall or network-segmentation controls. Document credential replacement and patching procedures.

Managed-service and equipment vendors: Review service agreements to confirm that vendors are contractually responsible for timely security updates, patch notifications, and access restrictions. Where agreements are silent or inadequate, negotiate amendments before the compliance deadline.

Compliance documentation: Although the FCC did not impose new recordkeeping requirements, maintaining contemporaneous records of credential changes, patch installations, and network-segmentation configurations is advisable for demonstrating compliance in any future enforcement proceeding.

The U.S. Department of Commerce conducted an expedited first sunset review of antidumping-duty orders on mattresses from Cambodia, Malaysia, Serbia, Thailand, Türkiye, and Vietnam. Commerce concluded that revoking these orders would be likely to lead to continuation or recurrence of dumping by producers and exporters in each of the covered countries.

Commerce's affirmative determination does not, by itself, keep the antidumping order in force. The U.S. International Trade Commission (USITC) must separately determine that revocation would likely lead to continuation or recurrence of material injury to the U.S. domestic industry. Only if both Commerce and the USITC reach affirmative conclusions will the order remain in effect for an additional five-year period.

The Commerce determination signals that Turkish mattress manufacturers and exporters should not price future U.S. sales on the assumption that the antidumping order will expire at the conclusion of the sunset review. The identified margin of up to 20.03% represents a substantial duty exposure that will continue to affect the landed cost of Turkish mattresses in the U.S. market if the USITC also reaches an affirmative conclusion.

For U.S. importers of Turkish mattresses, the continuation of cash-deposit requirements and the possibility of final-assessment duties exceeding deposits remain live risks. Supply chain and sourcing decisions that were premised on order expiration should be reassessed.

Turkish manufacturers and exporters: Do not assume order expiration. Continue accounting for antidumping cash deposits in U.S. pricing models. Monitor the USITC proceeding and consider participating through counsel to present evidence on the injury prong.

U.S. importers: Maintain adequate reserves for potential final-assessment duties. Review supply agreements to confirm that duty-adjustment mechanisms, importer-of-record responsibility, customs cooperation obligations, and indemnification provisions are clearly allocated between the parties.

Supply agreement drafting: Agreements covering Turkish-origin mattresses for the U.S. market should address: (i) product scope and country-of-origin documentation; (ii) importer-of-record responsibility; (iii) duty-adjustment mechanisms triggered by changes in cash-deposit rates or final assessment; (iv) customs cooperation and recordkeeping obligations; and (v) indemnification if assessed duties exceed deposits.

All three documents are public-inspection versions scheduled for Federal Register publication on July 31, 2026. Formal effective dates should be calculated from the published version.