FCC ALJ.
FCC Administrative Law Judges (FCC). No published AI policy as of May 2026.
FCC ALJ AI policy status. #
The FCC's administrative law judge program handles a small but specialized docket — primarily license revocations under 47 USC §312, common-carrier complaints, broadcast-station hearings, forfeiture proceedings, and Section 310(d) transfer-of-control matters. Representative practice is governed by 47 CFR Part 1. As of May 2026, no published AI policy applies to representative AI use in FCC ALJ proceedings. The FCC has issued substantive AI rules affecting its regulated entities — most prominently the August 2024 Declaratory Ruling that AI-generated voice content in robocalls is "artificial or prerecorded" within the TCPA, and the proposed AI-generated-content disclosure rule for political advertising — but no rule directed at representative conduct.
Authoritative source: https://www.fcc.gov/proceedings-actions/administrative-law-judges
Last verified: . If this row text disagrees with the linked source, the source controls.
Why FCC ALJ matters. #
FCC ALJ volume is small but the proceedings are existentially high-stakes for licensees. The body of FCC law presents a particular AI-verification challenge because it involves complex interaction between Communications Act provisions (47 USC), FCC orders (FCC Rcd citations), federal regulations (47 CFR), and treaty obligations for international telecom (ITU regulations). AI tools frequently conflate these citation systems — citing an FCC order using CFR-style notation, or attributing ITU recommendations to FCC precedent. The First Amendment overlay on broadcast and common-carrier regulation makes AI-generated arguments about content regulation particularly sensitive — verification of constitutional doctrine cited by AI is critical because the body of First Amendment broadcast-regulation case law is small enough that hallucination risk is high.
Practice implications. #
FCC ALJ representatives should: (1) apply ABA Op. 512 + applicable state-bar guidance; (2) take particular care with AI-generated FCC precedent — the four-source citation structure (Communications Act / FCC orders / 47 CFR / ITU regulations) is a known AI-confusion pattern; (3) coordinate with the FCC's substantive AI rules where the matter involves AI as the regulated subject (political advertising, TCPA / robocall regulation, deepfake political content); (4) the small body of First Amendment broadcast-regulation cases means AI-generated constitutional arguments need cite-checking against the actual case texts — not just the citations.