What Happens After Submitting a Bulk Fixed Availability Challenge

The fixed availability challenge process begins when a challenger submits a dispute, or challenge, to an internet service provider’s reported availability data, as shown on the National Broadband Map.  An individual fixed availability challenge may be submitted for a single location via the Broadband Map interface, or a bulk challenge covering multiple locations may be submitted in the BDC system. 

For information on the types of fixed availability challenges that can be filed, see: How to Submit an Availability Challenge.

For information on the methodologies that can be used for bulk challenges, see: Overview of Bulk Fixed Availability Challenges.

Initial Processing Stage

Challenge submissions first undergo a preliminary review by FCC staff.  Challenge submissions that lack required information are rejected at this stage; the rest move forward to the challenged provider for review. 

Initial Provider Response

Providers have 60 days from receiving and being notified about a challenge to submit a response to the challenge, either in the BDC system or via an API. 

In responding, providers may select one of three options:  “Concede”, “Dispute”, or “Concede - Service Change”.   When a provider chooses the Concede – Service Change option, it indicates that the service was available as reported for the as-of date, but based on service changes occurring since the as-of date, the service is no longer available or was not available on the date of the challenger’s request.


If a provider disputes the challenge, the provider must provide evidence both in the BDC system, and separately to individual consumer challengers.  This evidence will be automatically shared with bulk challengers through the BDC system. For more information on the evidence required to dispute a challenge, see: Evidence Required to Dispute a Fixed Availability Challenge.


When a provider chooses the Concede or Concede – Service Change options, the availability data on the map will be updated to reflect the concession.

60-day Period for Provider/Challenger Resolution Efforts

If a provider disputes a challenge, the provider and the challenger have 60 days to attempt to resolve the challenge among themselves before the FCC adjudicates the challenge.

During this period, the challenged provider should reach out to the challenger as soon as practical, using the point of contact listed with the challenge, either to indicate that it makes service available at the challenger’s location or to otherwise explain why its availability data are correct. While providers should initiate and, if appropriate, maintain a dialogue with the challenger, challengers may also reach out to providers to discuss their challenge(s).  

If a provider and challenger are able to reach an agreement during this period, either for or against the challenger’s initial position, the provider should enter in the system, as soon as possible, the outcome of their discussions and, to the extent the provider agrees with the challenge, revise its availability data accordingly. 

When the challenger agrees with the provider that the service is available as originally reported at the challenged location(s), it may withdraw its challenge (for information on how to withdraw challenges, see: How Bulk Challengers Can Withdraw Fixed Availability Challenges).  Alternatively, the provider may enter a final response that indicates the challenger concurs that service is available as reported. 

We strongly encourage both parties to attempt to reach a resolution before the end of the second 60-day period (note that providers and challengers can resolve each element of a bulk challenge independently). 

Provider Final Response

By the end of the second 60-day period, the provider must report the outcome of its negotiation process with the challenger in the BDC system.  If the provider continues to dispute the challenge at this point, it must provide a reason why the challenge could not be resolved among the parties.  

Failure to Respond

If a provider fails to submit an initial response in the system within 60 days of receiving the challenge, the system will automatically concede the challenge on the provider’s behalf.   

Additionally, if the provider fails to submit a final response after the dispute resolution period described above, it will result in an automatic concession of the challenge.

FCC Adjudication Phase

When a provider reports that it couldn’t resolve a challenge with the challenger, the challenge will be referred for adjudication by the FCC.  The FCC will assess the evidence submitted by both parties in the BDC system and make a determination to uphold (in favor of the challenger) or overturn (in favor of the provider) the challenge.  In the case of bulk challenges, the FCC may partially agree or disagree with a bulk submission, finding some challenged locations in favor of the challenger and some in favor of the provider based on the evidence submitted by the challenger and by the provider in its initial response.

In the case of a finding in favor of the challenger (an upheld challenge), the provider will have 30 days to revise its data in the BDC system, consistent with the adjudication.  In the event of a finding in the provider’s favor, the challenge concludes, and the location(s) will indicate that the challenge has been overturned and no longer identified on the map as "Challenged”.  

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