The FCC’s ban on Hikvision has moved in stages: since November 2022, no new Hikvision surveillance or telecommunications equipment can receive the FCC authorization it needs to be imported, marketed, or sold in the United States, and as of October 2025 the agency has adopted rules to phase out sales of models that were already approved. Equipment already installed can legally keep operating, but the room to buy, resell, service, or fund it with federal dollars is shrinking.
What the Ban Actually Covers
Hikvision sits on the FCC’s Covered Communications Equipment and Services List alongside Huawei, ZTE, Hytera, and Dahua. Its listing is narrower than the others. Huawei and ZTE face a blanket ban on all telecommunications equipment. Hikvision’s entry covers video surveillance and telecommunications equipment only “to the extent it is used for the purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes.”1Federal Communications Commission. List of Equipment and Services Covered By Section 2 of The Secure Networks Act
The qualifier matters. A Hikvision camera at a federal courthouse falls squarely inside the ban. The same model in a private retail store sits in a gray zone that regulators and courts are still working out, because the meaning of “critical infrastructure” is itself unsettled (more on that below).
No New Hikvision Models Can Be Authorized
The FCC’s November 2022 Report and Order, implementing the Secure Equipment Act of 2021, blocked the agency from granting new Equipment Authorizations for any covered equipment. An Equipment Authorization is the certification a radio frequency device must hold before it can be legally imported, advertised, or sold in the U.S.2eCFR. 47 CFR Part 2 Subpart J – Equipment Authorization Procedures Without one, a device cannot enter the U.S. market.
The 2022 rule is prospective. It bars future Hikvision product lines from reaching American buyers, but on its own it does not retroactively cancel the authorizations Hikvision models had already received.
Previously Approved Models Are Now Being Phased Out
That gap is what the FCC closed on October 28, 2025, when it adopted a Second Report and Order creating a process to limit previously granted authorizations for covered equipment.3Federal Register. Protecting Against National Security Threats to the Communications Supply Chain Through the Equipment Authorization Program The rules let the FCC prohibit the continued importation and marketing of specific covered devices without revoking the underlying authorization outright.
“Marketing” is defined broadly under FCC rules: it includes selling, leasing, offering for sale or lease, advertising, importing, and distributing for the purpose of sale. Continued operation of equipment already installed is not affected by these limitations.4Federal Communications Commission. FCC Fact Sheet – Protecting Against National Security Threats to the Communications Supply Chain Through the Equipment Authorization Program Second Report and Order
The FCC applies the limitation through public notice. The agency announces its intent to limit specific authorizations, publishes an impact assessment weighing national security risks against economic and supply chain effects, and opens a comment period of at least 30 days before making a final decision.5eCFR. 47 CFR 2.939 – Revocation, Withdrawal, or Limitation of Equipment Authorization
What Existing Users Can and Cannot Do
If you already run Hikvision cameras, NVRs, or DVRs, no current federal rule requires you to remove them. The FCC has been explicit that its limitations on existing authorizations target importation and marketing rather than continued operation.4Federal Communications Commission. FCC Fact Sheet – Protecting Against National Security Threats to the Communications Supply Chain Through the Equipment Authorization Program Second Report and Order You can keep using the system.
The practical picture is more difficult. Replacement parts and expansion units become harder to source as importation restrictions take hold. Security patches are a nuanced issue: Hikvision continues to release updates globally, but its ability to distribute them through U.S. channels is constrained by the marketing restrictions, and a camera that stops receiving patches becomes a cybersecurity liability over time.
The FCC has also reserved authority to revoke existing authorizations outright if it finds that a certification application contained false statements about whether the equipment was covered. In that scenario, the grantee has 10 days to respond before the FCC decides on revocation.5eCFR. 47 CFR 2.939 – Revocation, Withdrawal, or Limitation of Equipment Authorization A full revocation, unlike a marketing limitation, would reach continued use.
Resale and the Secondary Market
The October 2025 order takes direct aim at the secondary market. Because “marketing” covers selling, leasing, offering for sale, and distributing for the purpose of sale, once the FCC limits a specific equipment authorization, reselling that device becomes prohibited even if the original authorization was valid at the time of first sale.4Federal Communications Commission. FCC Fact Sheet – Protecting Against National Security Threats to the Communications Supply Chain Through the Equipment Authorization Program Second Report and Order
The FCC acknowledged that older covered equipment “likely remains marketable in the United States” and concluded that waiting for it to become obsolete “would not address the present unacceptable risks.” The revised 47 CFR § 2.803 now provides that no one may market a radio frequency device unless it holds a valid FCC authorization that has not been limited under § 2.939(e). Once the FCC acts on a specific class of Hikvision devices, listing them for resale or selling them to another user would violate federal rules.
Federal Funding: NDAA Section 889
The FCC rules run alongside a separate restriction that catches many buyers first. Section 889 of the fiscal year 2019 National Defense Authorization Act operates through federal procurement. Part A, effective August 2019, bars federal agencies from purchasing systems that use covered telecommunications or video surveillance equipment as a substantial component. Part B, effective August 2020, prohibits federal agencies from contracting with any entity that uses covered equipment at all, even when the contract has nothing to do with surveillance.6Acquisition.GOV. Section 889 Policies
For federal grant and loan recipients, the rule means federal dollars cannot pay to purchase, maintain, or renew contracts for covered equipment. Unlike federal procurement contracts, the grants and loans prohibition cannot be waived.7Department of Labor. Prohibition on Covered Telecommunications and Video Surveillance Services or Equipment Grants and Loans Schools, hospitals, local governments, and other recipients can still use Hikvision cameras they bought with non-federal money, but grant funds cannot buy, extend, or maintain them.8National Institutes of Health. 4.1.37 Prohibition on Certain Telecommunications and Video Surveillance Services or Equipment
A school district running Hikvision cameras can keep them running, but when the cameras fail or need upgrading, federal grant money cannot cover replacements or repair contracts. The path forward is either funding the transition from a non-federal budget or replacing the system with non-covered equipment.
The Unsettled Definition of “Critical Infrastructure”
Hikvision USA challenged the FCC’s 2022 order in the U.S. Court of Appeals for the D.C. Circuit. On April 2, 2024, the court issued a split decision. It upheld the FCC’s authority to prohibit new authorizations of Hikvision equipment used for physical security surveillance of critical infrastructure, but found the FCC’s definition of “critical infrastructure” overly broad and sent that portion back to the agency for a definition aligned with the NDAA’s statutory text.9Federal Communications Commission. United States Court of Appeals for the District of Columbia Circuit Decision
A December 2025 FCC notice proposed a new definition and opened it to public comment, which means the exact reach of the ban outside obvious government or public safety contexts remains legally unsettled.10Federal Register. Protecting Against National Security Threats to the Communications Supply Chain Through the Equipment Authorization Program The core ban stands; its outer edge is still being drawn.
Penalties for Violations
Under Section 503(b) of the Communications Act, the FCC can impose civil penalties of up to $25,132 per day for a continuing violation, with a statutory maximum of $188,491 for a single act or failure to act. Those figures reflect 2026 inflation-adjusted amounts.11Federal Communications Commission. FCC Notice of Apparent Liability for Forfeiture
Selling equipment that lacks a valid, non-limited Equipment Authorization, importing covered devices after a limitation takes effect, or making false representations in certification applications can all trigger forfeiture proceedings. The FCC has pursued equipment authorization cases before, and per-day accumulation can push totals well into six figures for entities that ignore the rules.
Planning Around the Restrictions
The regulatory direction is consistent. The FCC moved from blocking new products in 2022, to restricting sales of already-approved products in 2025, to proposing a tighter definition of which uses trigger the ban in late 2025. Each step narrows the space in which Hikvision equipment can legally be bought and sold in the United States.
Existing systems still face no immediate legal removal obligation. But the combination of import restrictions, NDAA funding prohibitions, patch distribution uncertainty, and the FCC’s reserved authority to revoke authorizations outright makes long-term reliance risky. Budgeting a transition to non-covered equipment is the practical response, especially for any organization touching federal funding. Waiting increases the chance of replacing equipment under pressure when the next rule lands rather than on your own timeline.