The short version
E-Rate eligibility does not change for 2027. On November 10, 2026, the FCC's Wireline Competition Bureau adopted the final Eligible Services List (ESL) for funding year 2027 in DA 26-1220. The E-Rate ESL for 2027 is the latest word on what is E-Rate eligible, and the order makes no changes to the list.
- Managed internal broadband services (MIBS), like managed Wi-Fi, stay eligible.
- Standalone network-as-a-service (NaaS) stays ineligible.
- Advanced and next-generation firewalls were not added. The basic firewall rules are unchanged.
- The FCC Form 471 window can open no earlier than 60 days after the order's November 10 release, so January 9, 2027 at the earliest.
What is the E-Rate ESL?
The Eligible Services List is the FCC's annual list of every product and service that can receive an E-Rate discount. Under 47 CFR 54.502(a), if it isn't on the ESL, it isn't eligible.
One detail worth knowing: the ESL says USAC's website guidance is informal only. It is not part of the ESL and "will not be used to determine whether a service or product is eligible." The ESL itself is the source of truth. For who qualifies as an applicant, see our guide to who is eligible for E-Rate funding.
What is E-Rate eligible in 2027
| Category | What's eligible |
|---|---|
| Category One Broadband to the building | Data transmission and Internet access: leased lit fiber, leased dark fiber, self-provisioned networks, Ethernet, cable modem, DSL, MPLS, satellite, fixed wireless and microwave, and more. Also special construction, installation, and the network equipment needed to make the service work. |
| Category Two Broadband inside the building | Internal connections: access points, switches, routers, cabling, racks, antennas, caching, wireless controllers, UPS/battery backup, firewall services and components, and the software that runs them. Plus managed internal broadband services (MIBS) and basic maintenance of internal connections (BMIC). |
| Miscellaneous | Taxes, shipping, lease fees, installation, activation, initial configuration, and basic on-site training tied to installation. |
What is not E-Rate eligible
- Off-campus use of E-Rate-funded services, even for an educational purpose. It must be cost-allocated out.
- End-user devices like computers, laptops, and tablets, plus applications, content, and email.
- Standalone NaaS, and standalone DNS or DHCP services.
- Equipment and services on the FCC's Covered List (national security supply chain restrictions).
- Applicant staff salaries and labor, and consulting that isn't tied to installing and configuring eligible components.
- Under basic maintenance: unbundled warranties, 24-hour network monitoring, and upkeep of ineligible equipment.
The latest E-Rate eligibility decisions for 2027
1. MIBS stays eligible, for now. The Bureau asked whether MIBS should be limited by applicant size, replaced by basic maintenance when the applicant owns the equipment, or removed. Every commenter that addressed MIBS supported keeping it. The Bureau kept it, but noted that "eligibility and/or reimbursement requirements may change for future funding years" as the FCC reviews its June 2026 rulemaking (FCC 26-41).
All commenters that discussed MIBS supported its eligibility for E-Rate support and opposed the requirement that MIBS be reimbursed on an hourly, ticket-based approach.
No changes, including for MIBS or NaaS, are made to the eligible services list for funding year 2027. MIBS continues to be eligible, but eligibility and/or reimbursement requirements may change for future funding years as the Commission reviews the record developed in the Further Notice of Proposed Rulemaking.
2. NaaS stays ineligible. The Bureau found that variable, usage-based pricing would require form changes, add administrative burden, could undermine competitive bidding, and would make costs harder for schools to budget.
Making NaaS eligible would not only require form changes and increase administrative burdens, but could undermine the competitive bidding process and create challenges for schools that need stable cost estimates for budgeting. Thus, the Bureau declines to change the eligibility of NaaS in the E-Rate program.
3. No new cybersecurity eligibility. Requests to add advanced or next-generation firewalls and other network security services were not addressed in this order. The Bureau pointed to the separate Schools and Libraries Cybersecurity Pilot, where those services are being studied.
4. DNS and DHCP are eligible only when bundled. They qualify in Category One when they come as a standard part of a vendor's Internet access service. Sold separately, they don't qualify in either category.
What to do with this
Applicants: Your FY2027 planning assumptions hold. Check each line of your funding requests against the ESL itself, not a summary, and cost-allocate anything ineligible. If you rely on MIBS, follow the FCC 26-41 proceeding, since that is where future changes would come from.
Service providers and manufacturers: Product eligibility carries over from FY2026. Make sure quotes separate eligible from ineligible items clearly, especially firewall licensing and managed services contracts.
Frequently asked questions
What is E-Rate eligible in 2027?
For funding year 2027, Category One covers data transmission and Internet access to schools and libraries. Category Two covers internal connections such as access points, switches, routers, cabling and firewall components, plus managed internal broadband services and basic maintenance. The FCC adopted the list with no changes.
What is the latest E-Rate eligibility update?
The latest update is the FY2027 Eligible Services List, adopted by the FCC's Wireline Competition Bureau on November 10, 2026 in DA 26-1220. It makes no changes to E-Rate eligibility for funding year 2027.
What is the E-Rate Eligible Services List (ESL)?
The ESL is the FCC's annual list of the products and services that qualify for E-Rate discounts. It is split into Category One (broadband to schools and libraries) and Category Two (internal connections, managed internal broadband services, and basic maintenance).
Did E-Rate eligibility change for 2027?
No. The FCC's Wireline Competition Bureau adopted the FY2027 ESL on November 10, 2026 with no changes.
Are firewalls E-Rate eligible in 2027?
Partly. Basic firewall protection included as a standard part of Internet access is eligible in Category One. Firewall services and components that are provided by a different vendor or priced separately are Category Two internal connections. The FCC did not add advanced or next-generation firewalls to the FY2027 ESL.
Is managed Wi-Fi (MIBS) E-Rate eligible in FY2027?
Yes. Managed internal broadband services remain eligible in Category Two for FY2027. The FCC said the rules could change in a future funding year.
Is network-as-a-service (NaaS) E-Rate eligible?
No. Standalone NaaS remains ineligible for FY2027.
When does the FY2027 Form 471 window open?
The order authorizes USAC to open the FY2027 FCC Form 471 filing window no earlier than 60 days after the order's November 10 release, so January 9, 2027 at the earliest.
Sources
- FCC Wireline Competition Bureau, Order adopting the FY2027 Eligible Services List, DA 26-1220, WC Docket No. 13-184 (Nov. 10, 2026)
- 47 CFR 54.502 (eligible services)
- USAC, Eligible Services List page (informal guidance)