Understanding Section 889 Part B - Prohibited Telecom

Explore the implications and compliance steps of Section 889 Part B, legislation impacting federal contractors' use of specific telecommunications services and equipment.

Title : Understanding Section 889 Part B - Prohibited Telecom

We present a comprehensive understanding of Section 889 Part B - Prohibited Telecom:


Having an impact on all federal contractors that includes those with GSA MAS Contracts, Section 889 Part B of the FY 2019 NDAA was implemented in August 2020. It carries far-reaching implications for the federal contracting sphere:

Section 889 Part B Overview

  • Specifically prohibits federal contractors from using particular telecommunications equipment and services.
  • This is not limited to the provision of such telecom to federal agencies but also extends to any usage by the contractors themselves.
  • A distinct departure from Part A which focuses on blocking the selling of or providing these types of prohibited telecom services to federal agencies.


Many important parameters need to be considered for federal contracting:

  1. These parameters apply to prime contractors only, and not to subcontractors.
  2. There is a requirement for contractors to state whether they use prohibited telecom in their professional operations.
  3. It dramatically impacts the ability to accept federal contracts, including GSA MAS Contracts without conforming to these compliance rules.

Prohibited Telecom Defined

This involves any equipment or services that derive from specific companies such as Huawei, ZTE, Dahua Technology, Hangzhou Hikvision Digital Technology, and Hytera Communications. It also includes anything that forms a critical or substantial component of any system or vital technology:


There are a few significant exceptions:

  • Service connections involving third-party facilities and telecommunications that do not route user data.
  • Specific backhaul, roaming, or interconnection arrangements that are exempt.

Waiver Process

Though waivers are theoretically possible, they are stringent in practice and usually based on national security:

  1. They offer a possibility of delayed implementation up till August 2022 if an agency waiver is issued.

Compliance Steps

The Steps for compliance to Section 889 Part B include:

  1. Understanding of the rules: Familiarize with Section 889 Part B requirements.
  2. Conducting a reasonable inquiry into the existing company data to identify prohibited telecom usage.
  3. Planning for removal: If prohibited telecom is found, plan for its phase-out and evaluate any potential waiver options.
  4. Educating employees: Ensure all staff members are aware of Section 889 and its compliance requirements.
  5. Represent compliance in future contracts: Declare telecom usage status when responding to federal orders.
  6. Annual representation in SAM.gov: Once the updates are done, annually represent the status of telecom usage.


With Section 889 Part B, the onus is significant on federal contractors to ensure their telecommunications infrastructure and services are completely in line with national security standards. Contractors need to assess and modify their telecom usage proactively to maintain eligibility for federal contracts:


In conclusion, compliance with Section 889 Part B is absolutely crucial to remain eligible as a contractor for federal jobs and to contribute effectively towards national security efforts. Led by a former GSA Schedule Reviewer, we offer the best GSA Schedule Consulting services. The legislation highlights the increasingly critical focus on cybersecurity and national security within federal contracting.

Pedro has extensive background as a Contracting Officer and Contract Specialist, has worked across seven federal agencies, managing contracts totaling over $1 billion in the professional and tech sectors. His notable tenure includes serving with the DoD/DARPA during the inception of their robotics program. Additionally, he played a pivotal role in initiating the Cyber Special Item Number (SIN) within the GSA's IT Schedule 70 as a Team Lead. After graduating from Harvard, he started Blackfyre to help you win your next contract.

Learn more about our services:

GSA Schedule

  • GSA Application Submission

  • Turn-Key Application Process

  • Up to 5 SIN Categories

  • Lead Negotiation Process

  • GSA Compliance & eBuyTraining

  • Six-month of GSA Support

Learn More

GSA Exercise Option Period

  • Document Preparation

  • BD Plan Creation

  • Capture Management Plan Development

  • Expert Guidance

  • Turn-Key Application Process

Learn More

GSA Maintenance Program

  • GSA Mass Mod Management

  • Quarterly FAS Reporting

  • GSA Pricelist Updates

  • Smooth SIP File Uploads

  • Unlimited GSA Admins Mods

  • GSA Schedule Support

Learn More

Growth Program

  • 10-Hour Weekly Hands-On Support

  • Develop and Manage Contract Opportunity Pipeline

  • Identify Contract Opportunities

  • Craft Technical Proposals

  • Craft Price Proposal

  • Enhance Past Performance Documentation

  • Subcontract Management Assistance

  • Six-month of free support

Learn More

BlackOps Program

  • Weekly Series of Four Calls Focused on Contract-Related Subjects

  • Assistance in Crafting Capability Statements

  • Guidance in Developing Technical Proposals

  • Support in Formulating Price Proposals

  • Access to a Supportive Community

  • Personalized One-on-One Assistance Aimed at Securing Your Initial Contract Win

Learn More

Ask CO

  • 24/7 Support

  • Guidance for Beginners on Entering the Field

  • Professional Consultation on All Aspects of Contracting

  • Customized Strategy Development Plan

  • Flexible Monthly Membership with No Long-term Commitment Required

Learn More

Monthly Contract Opportunities to Capture

  • Monthly Selection of Government Agency Contracts

  • BPA/IDIQ Upcoming Opportunities

  • Alerts on New Opportunities

  • Trends and Analysis of Agency Contracts

  • Quick Guides on Proposal Requirements

  • Agency-Specific Networking Opportunities

Learn More

Sign up for our weekly newsletter and join 10k other GovConleaders
about GovCon news and Upcoming Coming Opportunities.