Library hotspot lending after the 2025 E-Rate change
On 30 September 2025 the FCC ended E-Rate support for Wi-Fi hotspots that libraries lend to patrons. Many libraries still lend them, now paid from the library budget, a grant or donations. This guide explains what changed, when CIPA applies and when it does not, which other rules may still ask for filtering, and the practical ways to keep lent devices filtered without watching patrons.
This guide is general information, not legal advice. Each legal statement comes from an official FCC, USAC, federal or state source, listed at the end of the page. Where those documents do not answer a question, we say so.
What changed in 2025
The rules on lent hotspots moved several times in four years. The dates matter when you read old board minutes, grant reports or a carrier contract.
- 10 May 2021The FCC adopted the Emergency Connectivity Fund. It paid for equipment and service that students, school staff and library patrons used away from school and library buildings during the pandemic, including hotspots.
- 30 June 2024The Emergency Connectivity Fund ended, as its law required after the public health emergency ended.
- 18 July 2024The FCC adopted the Hotspots Order (FCC 24-76), released on 29 July 2024. It made hotspots and their wireless internet service eligible for E-Rate when lent for off-premises use. USAC announced that libraries could start such lending programs from funding year 2025.
- 8 May 2025The US Senate passed S.J.Res.7 to disapprove the 2024 hotspot rules, as the FCC notes in its 2025 order.
- 30 September 2025The FCC adopted an Order on Reconsideration (FCC 25-62). It found that the best reading of the Communications Act does not permit E-Rate support for off-premises hotspots, rescinded the 2024 rules and told USAC to deny all pending funding year 2025 hotspot requests. The same day it ruled school bus Wi-Fi ineligible from funding year 2025 (FCC 25-63), and the Wireline Competition Bureau released an amended FY2025 eligible services list without hotspots (DA 25-920).
- 18 November 2025USAC told applicants that pending FY2025 hotspot requests will be denied and that they can no longer request funding for off-premises Wi-Fi equipment and services.
- 17 December 2025The FY2026 eligible services list (DA 25-1069) states that off-campus use of E-Rate-funded services is ineligible for support even when used for an educational purpose, and must be cost-allocated out of any funding request.
What it means in practice
- E-Rate cannot pay for hotspot devices or their data plans, for funding year 2025 or later.
- No E-Rate money reached library hotspots under the 2024 rules. The FCC states that USAC had not processed any FY2025 hotspot requests while the petitions for reconsideration were pending.
- If your library lends hotspots today, the money comes from somewhere else: the library budget, a city or county budget, a state or federal grant, a Friends group or a donor. That source now decides which conditions come with it.
- Discounts for internet access and Wi-Fi inside your buildings are not part of this change. The orders deal with use away from the library and with school buses.
Check USAC's E-Rate announcements before each filing window. The rules on off-premises use have changed often, and they may change again.
When CIPA applies to lent hotspots, and when it does not
CIPA is a condition attached to federal money. It is not a general law about every internet connection. So the first question is always: which money does the library take, and what did that money pay for?
What triggers CIPA for a library
A library that receives E-Rate discounts for internet access, internet service or internal connections must certify CIPA compliance. USAC describes this as Category One internet access and all Category Two services. A library that receives discounts only for telecommunications services certifies that CIPA does not apply.
The library certifies that it enforces an internet safety policy with a technology protection measure on any of its computers with internet access. The measure must block visual depictions that are obscene or child pornography for everyone, and visual depictions that are harmful to minors when minors use the computer. Under CIPA a minor is anyone under 17. The library or the authority responsible for it, not the federal government, decides what matter is inappropriate for minors.
What the FCC said in 2024, and what is left of it
When it made hotspots eligible, the FCC concluded that CIPA applies to off-premises use when the library receives E-Rate support for internet service, internet access, internal connections or related equipment, including hotspots. That conclusion was about E-Rate-funded hotspots. In September 2025 the FCC rescinded the 2024 hotspot rules and restored the rules that existed before them.
The 2024 order also quoted the FCC's guidance for the Emergency Connectivity Fund: CIPA does not impose any requirements on a hotspot device itself, but buying a hotspot with that fund triggered CIPA compliance for the school or library that bought it. In that guidance the purchase with program money was the trigger, not the device.
We read FCC 25-62, the amended FY2025 eligible services list, the FY2026 eligible services list and USAC's announcement. None of them says how CIPA applies to hotspots or lent devices that a library pays for with other money.
The answer depends on the funding source
| What paid for the hotspot or lent device | Does that money bring a filtering condition? | What to check |
|---|---|---|
| E-Rate | Not possible. Hotspots and their service are ineligible from funding year 2025. | Remove hotspot lines from your E-Rate plans and contracts that assumed funding. |
| Emergency Connectivity Fund (2021 to 2024) | The FCC applied CIPA to off-premises use of equipment and service it funded. The fund ended on 30 June 2024. | If you still lend devices bought with it, ask your E-Rate adviser whether any obligations from that funding still apply. |
| LSTA grant, usually passed on by your state library agency | In some cases, yes. A public library that does not receive E-Rate discounts subject to CIPA, and uses LSTA money to buy computers used to access the internet or to pay direct costs of internet access, must have an internet safety policy with a technology protection measure on its computers with internet access (20 U.S.C. 9134(f)). | Ask your state library agency whether a hotspot data plan paid with LSTA money counts as a direct cost of internet access. |
| Another federal or state grant | Only if the grant terms say so. | Read the award terms and certifications before you sign. |
| Library or local government budget, Friends group or donors | No. This money carries no CIPA condition of its own. | Check state law, your board policy and your existing CIPA certification, below. |
Our plain reading, and the open question
If E-Rate does not pay for the hotspot, the hotspot does not bring CIPA with it. One question stays open. A library that certifies CIPA for its E-Rate internet promises to filter any of its computers with internet access, and a library-owned laptop lent to a patron is still one of the library's computers. The FCC and USAC documents we checked do not say whether that promise reaches a lent laptop used on a home or hotspot connection.
Ask your E-Rate adviser or attorney. Until you have an answer, filtering lent library computers is the cautious choice.
State law and board policy may still require filtering
CIPA sets the federal floor for libraries that take the money. A state, a city or county, and your own board can go further.
State library filtering laws
Some states have their own law on internet filtering in public libraries. They differ in who they cover, what must be blocked and up to what age. Two examples show how much the wording matters:
- Arizona requires a public library that provides a public access computer to deploy and enforce a technology protection measure (A.R.S. 34-502). The law defines a public access computer as one located in a public school or public library and available to minors, among other conditions (A.R.S. 34-501). A laptop at a patron's home may fall outside that definition. Your attorney can tell you how it is read.
- Virginia requires library boards to adopt an internet acceptable use policy. It must prohibit using the library's computer equipment and communications services for illegal material, and be designed to prevent access by patrons under 18 to material harmful to juveniles (Va. Code 42.1-36.1). Note the age: under 18 in Virginia, under 17 in CIPA.
Ask your state library agency three questions: does our state have such a law, does it tie state aid to filtering, and does its wording cover lent devices or lent connections?
Your board's own policy
Your internet safety policy may already answer the question. If it says that all internet access the library provides is filtered, that includes lent hotspots unless the policy says otherwise. If it is silent, decide and write the decision down, in the internet safety policy or in the lending policy.
CIPA requires reasonable public notice and at least one public hearing or meeting on the proposed internet safety policy. USAC says additional meetings are not needed when the policy is amended, unless state or local rules or the policy itself require them. Discussing a lending change in an open meeting still helps, because patrons and parents will ask.
Questions for the board
- Who may borrow a hotspot or laptop: adults only, or minors with a parent or guardian?
- Are lent devices filtered, and to which level: the CIPA minimum, the rules of the adult public computers, or the children's rules?
- How does an adult ask for a blocked site while the device is at home?
- What does the library record about use, who may see it, and for how long is it kept?
- Who checks each device between loans, and what do they check?
Four ways to keep lent devices filtered
There are four practical places to apply a filter. They cover different devices, so you may want to combine two of them.
1. Carrier-level filtering
Some mobile data plans for schools and libraries include a content filter in the carrier's network. It covers every device that connects to the hotspot, including a patron's own phone.
Ask the carrier:
- Which categories are blocked, and can you change them?
- Can children's and adult loans get different rules?
- How does an adult get a site unblocked, and how fast?
- What is recorded, for how long, and who can see it?
- Does it still work when a browser uses its own encrypted DNS?
2. Filtering on the hotspot
Some hotspot models let you set the DNS servers or switch on a content setting in their admin page. A filter set there covers every device on that hotspot.
Watch for:
- Change the default admin password on every unit.
- Lock or hide the admin page if the model allows it.
- A cellular hotspot usually gets a changing public address from the carrier. A filter that recognizes your library by its fixed address cannot recognize the hotspot, so the setting must identify the hotspot itself.
- Check the settings at every return.
3. A filter link on lent laptops and tablets
The device carries its own private, encrypted link to the filter. It is filtered on the hotspot, on home Wi-Fi and on public Wi-Fi alike, with the rules you chose for it.
Watch for:
- Lock the setting with device management so a borrower cannot remove it.
- Stop borrowers from adding another browser, or lock its settings too.
- It covers the lent device only, not a phone tethered to the same hotspot.
4. Lend the hotspot only with a filtered device
Lend the hotspot as a kit with a filtered laptop or tablet, and set the hotspot so only that device can join. For example, set up the device to join with a Wi-Fi password the borrower is not given, or use a list of allowed devices if the model supports one.
Watch for:
- The kit is only as strong as the hotspot's admin password.
- Kits get split up, so check both parts at return.
- Borrowers can still use their own phone's mobile data. That is outside the library's control.
The four methods side by side
| Question | Carrier filter | On the hotspot | Link on the device | Hotspot and device kit |
|---|---|---|---|---|
| Covers a patron's own phone on the hotspot | Yes | Yes | No | Phones cannot join |
| Covers the lent device on home Wi-Fi | No | No | Yes | Yes |
| Different rules for children's and adult loans | Ask the carrier | Depends on the model | Yes, per device | Yes, per device |
| Setup work | Order with the data plan | Each unit, checked at every return | Once per device, locked by device management | Both of the last two |
| Main risk | Little local control | Admin settings changed | Setting removed on an unmanaged device | Kit split up |
One workable combination: a filter link on every lent laptop and tablet, because it keeps working after the hotspot goes back, plus carrier or hotspot filtering on hotspots lent on their own.
A filter link on lent devices with our hosted filter
Our hosted CIPA filter covers library networks for $99 a month per site. For devices away from the network, each device gets its own private encrypted link to the filter, with the same rules as your network. Laptops, take-home tablets and hotspots used outside your buildings all count as devices away from the network.
- Price. $0.10 per device a month, or $1 per device a year, with a minimum of 25 devices. Devices are added to your plan after a short email.
- Rules. A link belongs to one of your networks and carries its rules. Give children's loan tablets the children's area link, so they get the stricter rules wherever they are, and give adult laptops the adult link.
- Setup. The link is set by browser policy, a Windows setting or an Apple profile. For managed fleets, combine it with device management so users cannot remove it.
- Who the filter answers. The filter answers only the network addresses and encrypted links registered for your sites. Everyone else is refused.
- Workarounds. VPN and proxy websites are blocked by default.
- Hotspots. Whether a hotspot model can hold the link depends on its settings, so ask us about your model before you buy.
Example. A one-branch library lends 40 laptops. At list prices that is $99 a month for the branch plus $4 a month for the laptops. Paid yearly, it is $990 for the branch and $40 for the laptops.
Read more in how devices stay filtered away from the network, or see all options on the pricing page.
Patron privacy on lent devices
A filter on a lent device sits close to a patron's private life. Keep what you collect small and the rules clear.
Filtering is not monitoring
USAC's summary of CIPA lists monitoring the online activities of minors as a requirement for schools. The library requirements do not include it. A technology protection measure, as CIPA defines it, is a technology that blocks or filters internet access. It does not need to read messages or record what people type.
Keep device records and filter records apart
Our filter sees which websites a device looks up, not who uses it. That stays true only if nobody links the two. Name devices in the filter by asset tag, not by borrower. Keep the loan record in your lending system, and do not copy borrower names into filter reports or exports.
Check your state's library records law
Your state may protect library user records by law. Arizona, for example, bars a library or library system supported by public money from disclosing records that identify a user as requesting or obtaining specific materials or services, except in listed cases such as written consent or a court order (A.R.S. 41-151.22). A filter log tied to a named borrower could become such a record. Ask your attorney how your state's law applies.
Short retention, named access
Decide how long filter records are kept, which staff roles may read them, and for what reason. Write the answers into the lending policy, and keep to them.
Reset between loans
Sign out of every account, clear browser data and downloads, and confirm the filter setting is still in place before the next loan.
No location tracking by default
Some hotspots and device management tools can report location. If you use it to find lost devices, keep it apart from browsing records and say so in the agreement.
Adults and unblocking away from the desk
CIPA lets an administrator, supervisor or other person authorized by the library disable the technology protection measure during use by an adult, to enable access for bona fide research or other lawful purposes. USAC gives a library example: a sign-in page where an adult affirms that they will use the computer for bona fide research or other lawful purposes.
At the desk this takes a minute. With a device at someone's kitchen table, plan the route in advance:
- Lend adults devices with the adult rules, set to block only what your policy requires for adults, plus VPN and proxy websites.
- Give a phone number or email address for unblock requests during opening hours, and say how quickly staff respond.
- Keep children's loan devices on the children's rules, with no unblock route.
- Record that an unblock happened and for how long, not what the adult read.
Our guides on CIPA adult unblocking in libraries and patron self-unblock cover the desk procedure and the records in detail.
What to put in the lending agreement
The agreement is where patrons learn what is filtered. Keep it to one page, in plain words. The wording below is an example to adapt, not a legal template.
| Clause | Example wording |
|---|---|
| Who may borrow | Adults with a library card in good standing. A parent or guardian signs for borrowers under 18. |
| What is filtered | This device is filtered under the library's internet safety policy, on any network it uses. |
| Adults and blocked sites | If an adult needs a blocked site for research or another lawful purpose, call or email [contact] during opening hours. |
| What is recorded | The library records which device is lent to whom. The filter records which websites the device looks up, not who uses it. Filter records are kept for [period] and seen only by [role]. |
| Device settings | Do not change, remove or work around the filter or the device settings. |
| Data and connections | The hotspot allows [number] devices at a time. Data may slow down after [amount]. |
| Return | Return the device and charger by the due date. We reset it before the next loan. |
| Loss or damage | Fees for lost or damaged items are listed at the desk. |
| Help | Contact [desk or name] if the device or the filter stops working. |
Have your attorney review the final text, especially the parts on records and on minors.
Setting up a filtered lending program, step by step
- List what you lend. Count hotspots, laptops and tablets, who owns each one, and what paid for it.
- Check the funding conditions. Use the funding table above for each source, and note any grant terms.
- Decide the policy with your board. Who may borrow, which rules apply, how adults ask for unblocking, and what is recorded.
- Choose a method per device type. For example, a filter link on laptops and tablets, and carrier filtering on hotspots lent on their own.
- Set up the rules. Create the profiles you need, such as children's loans and adult loans, and assign each device to one.
- Lock the devices. Use device management to lock the filter setting and the browsers. Change every default admin password.
- Test away from the building. Take a staff device home and onto a hotspot, and run the test list below.
- Write the agreement and train the desk. Show staff how to check a device out and in, and what to say about filtering.
- Check every return. Reset the device, confirm the filter setting, charge it and note the check.
- Review each quarter. Look at lost devices, unblock requests and complaints, and adjust the rules or the agreement.
A short test list
| Test | Where | Pass looks like |
|---|---|---|
| A site in a blocked category | Hotspot and home Wi-Fi | Blocked. On https sites the browser may show a warning instead of the block page; the site stays blocked. |
| A site in an allowed category, such as a job portal | Hotspot and home Wi-Fi | Opens normally. |
| A VPN or proxy website | Hotspot and home Wi-Fi | Blocked. |
| Removing the filter setting as a borrower would | On the device | Not possible without an admin account. |
| A children's loan device on a site outside the children's rules | Any network | Blocked, with no unblock option. |
| After a reset | At the desk | Filter setting still in place. |
Repeat the tests after any change to devices, data plans or device management. Keep the date and result with your lending records.
Hotspot lending questions
Does E-Rate still pay for library hotspots?
No. On 30 September 2025 the FCC rescinded its 2024 hotspot rules in an Order on Reconsideration (FCC 25-62) and told USAC to deny all pending funding year 2025 hotspot requests. Hotspots and their wireless internet service are not eligible from funding year 2025 onward.
Do we have to filter hotspots we pay for ourselves?
Not because of CIPA alone, since local money carries no CIPA condition of its own. It depends on the funding source: LSTA money and some grants carry filtering conditions, and state law or your board policy may require filtering. Whether your E-Rate CIPA certification reaches lent library computers used off site is not settled in the FCC and USAC documents we checked, so ask your E-Rate adviser or attorney.
Can we filter a patron's own phone on a lent hotspot?
Only through the hotspot itself or through the carrier. A filter link on a lent laptop or tablet covers that device, not other devices that join the same hotspot.
What does it cost to filter lent devices with your hosted filter?
Devices away from the network cost $0.10 per device a month, or $1 per device a year, with a minimum of 25 devices. They are added to a hosted filter plan, which starts at $99 a month per site.
Does the filter record who used a lent device?
No. The filter sees which websites a device looks up, not who uses it. Keep borrower names out of the filter dashboard and name devices by asset tag, so it stays that way.
Can an adult ask to unblock a site on a lent device?
CIPA lets an authorized person disable the filter during use by an adult for bona fide research or other lawful purposes. Decide the route in your policy, for example adult rules on adult loans and a phone or email route to staff during opening hours.
Do we need a new public hearing to change our lending policy?
For CIPA, USAC says additional meetings are not needed when the internet safety policy is amended, unless state or local rules or the policy itself require them. Check your state rules and your own policy before you skip one.
Does the change affect E-Rate for our branch connections?
No. The 2025 orders ended support for hotspots lent for off-premises use and for school bus Wi-Fi. Internet access and Wi-Fi inside your library buildings are not part of that change.
Sources
- FCC, Order on Reconsideration, Addressing the Homework Gap through the E-Rate Program, FCC 25-62, adopted and released 30 September 2025: docs.fcc.gov/public/attachments/FCC-25-62A1.pdf
- FCC, Declaratory Ruling on school bus Wi-Fi, FCC 25-63, adopted and released 30 September 2025: docs.fcc.gov/public/attachments/FCC-25-63A1.pdf
- FCC Wireline Competition Bureau, amended FY2025 eligible services list, DA 25-920, released 30 September 2025: docs.fcc.gov/public/attachments/DA-25-920A1.pdf
- FCC Wireline Competition Bureau, FY2026 eligible services list order, DA 25-1069, released 17 December 2025: docs.fcc.gov/public/attachments/DA-25-1069A1.pdf
- FCC, Report and Order (Hotspots Order), FCC 24-76, adopted 18 July 2024, released 29 July 2024, including the CIPA section and the Emergency Connectivity Fund dates: docs.fcc.gov/public/attachments/FCC-24-76A1.pdf
- USAC, FCC Rescinds E-Rate Eligibility for School Bus Wi-Fi and Wi-Fi Hotspots: usac.org
- USAC, FY2025 Off-Premises Wi-Fi Hotspots Funding: usac.org
- USAC, CIPA requirements, Administrative Authority and amendments: usac.org/e-rate/applicant-process/starting-services/cipa/
- 47 U.S.C. 254(h)(6), (h)(7) and (l), Children's Internet Protection Act provisions for libraries: govinfo.gov
- 20 U.S.C. 9134(f), internet safety condition on LSTA funds: govinfo.gov
- Arizona Revised Statutes 34-501 and 34-502: azleg.gov/ars/34/00501.htm and azleg.gov/ars/34/00502.htm
- Arizona Revised Statutes 41-151.22, privacy of library user records: azleg.gov/ars/41/00151-22.htm
- Code of Virginia 42.1-36.1, library acceptable internet use policies: law.lis.virginia.gov
Keep lent laptops and tablets filtered
Each device gets its own private encrypted link to the hosted filter, with the same rules as your network. $0.10 per device a month or $1 per device a year, minimum 25 devices, on a plan from $99 a month per site.