Amateur Radio Guide to Following CEPT and FCC License Rules Posted by John Crovelli, W2GD

Editor’s Note: Ward Silver, NØAX, contributed to this article.

It took a global pandemic to raise our general awareness of amateur radio licensing reciprocity and remote control rules. Many seized the opportunity to apply remote control technology for operations locally, nationally, and even internationally. While investigating what radio regulations might apply to “remoting,” many found there is something commonly referred to as “CEPT,” which provides the legal basis for temporary in-person operations across national boundaries. (See Appendix 1—What is CEPT?) The goal of this article is to show you the rules for operating and identifying legally when traveling or using remote control. (Thanks to the ARRL for additional review and suggestions for this article.)

In general, CEPT (and similar bilateral and multilateral agreements) enable an amateur radio licensee to temporarily operate a station in countries beyond their national border without obtaining a separate license from a host country. (See “The CEPT License” below.) This agreement is defined in the document CEPT Recommendation AR 61-01. This agreement requires each country to implement it in their rules. Each country determines how the CEPT agreement applies to its licensees. In the U.S., the CEPT agreement was adopted in amendments to the FCC’s rules in 1998 in Section 97.107(b)(1). In other words, the CEPT provisions are applied by the FCC to holders of FCC licenses, both U.S. citizens and non-citizens (referred to as “aliens”). CEPT documents are also available at arrl.org/cept.

In most situations, you may legally operate without notifying the visited country, as long as you follow CEPT rules. But there are a few limitations within the rules that are not well known, often misinterpreted, misunderstood, and occasionally violated. (See Appendix 2—Other Reciprocal Licensing Agreements.)

The CEPT License

In some countries the national license contains everything required and qualifies as a CEPT license. This is not the case in the U.S. For an FCC-licensed U.S. citizen to operate in other countries, the licensee must have a CEPT license. A “bare” FCC license does not qualify as a CEPT license. For a U.S. citizen, a valid CEPT license based on an FCC license requires three documents: the FCC license of appropriate class, proof of citizenship (such as a passport), and a copy of FCC Public Notice DA 16-1048.

A note about U.S. license classes: Advanced and Extra class license holders have privileges in countries listed in Annex 2 or Annex 4 to CEPT Recommendation T/R 61-01. General class license holders must check to be sure they meet the licensing requirements of a host country and what privileges will apply. (See ECC/REC (05)06, CEPT Novice Radio Amateur License.) Novices and Technicians do not have CEPT privileges.

FCC Rules and CEPT Recommendations

U.S. citizens licensed by the FCC visiting CEPT countries must abide by rules set forth in FCC DA 16-1048. This document, last issued in 2016, applies only to U.S. citizens and not foreign nationals who are licensed by the FCC. Part 97.107 governs FCC license grants issued to aliens.

Public Notice DA 16-1048 is the FCC version of CEPT AR 61-01 and is enforceable like all other regulations found in Part 97. The rules for an authorized portable operation by a U.S. citizen in CEPT countries are precisely presented within this notice in three languages. Effectively, FCC licensees are directed to follow the rules as presented in CEPT AR 61-01 when operating abroad.

FCC Part 97.107 sets limits on how FCC-licensed aliens may operate from a station located in the U.S.:

1. An alien licensee may use their FCC-issued call sign ONLY while operating in the U.S., including its territories and possessions.
2. If a U.S. license of any class is held by a foreign amateur, it MUST be used in place of any other operating authority. This rule prohibits a foreign national from using their FCC-issued call for any purpose other than operation in the U.S.
3. An FCC license is required for an alien licensee to operate a U.S. station by remote control from any non-U.S. location. 

FCC regulations do not apply once the foreign national exits the U.S., at which time regulatory control reverts to their home country national license. (A home country license is from the foreign national’s country of citizenship.)

CEPT and Remote Operation

Probably the most misunderstood concept about CEPT regulations involves remote operation. CEPT does not address remote control and does not authorize anyone to perform remote operation. Rules governing permission for remote operations are administered by each national license authority. Unlike the U.S., which has authorized transmitter remote control within FCC Part 97 rules for decades, most nations have yet to address and codify remote rules in their national license regulations.

In general, it is usually necessary for operators to obtain a reciprocal license from the country of interest. Notable recent examples in contesting circles are remote multi-op entries from ZF, PJ2, PJ4, FY, and others. Recent DXpeditions have also involved operation by remote control from outside the boundaries of the entity being activated.

Identifying Correctly—Examples

These examples show what call sign must be used in several common cases. Let’s assume that the U.S. amateur’s call sign is W2GD, the non-U.S. amateur is a German citizen with the call sign DL8WWW who also holds the Extra Class FCC-issued call sign WBØGQP, and the host country is Netherlands (PA).

U.S. Citizen with FCC License

• Operating in-person in host country: PA/W2GD
• Operating a non-U.S. station by remote control from outside the host country: not permitted unless specifically allowed by the host country

Foreign National with FCC License

• Operating in-person under CEPT in host country: PA/DL8WWW (must use their national license call sign)
• Operating in-person in the U.S.: WBØGQP (must use the FCC-assigned call sign)
• Operating a U.S. station by remote control: WBØGQP (only allowed when the operator is located inside the U.S.)

Foreign National with Home Country License (no U.S. license)

• Operating in-person in the U.S.: W2/DL8WWW (portable identifier must include district)
• Operating a U.S. station by remote control: not allowed, an FCC license is required

Know the Rules

Misconceptions about CEPT (See Appendix 3–Common Misconceptions about CEPT) disappear with an understanding of the intent and scope of regulations in place worldwide to facilitate license reciprocity between nations. Bookmarking a link to the Part 97 rules, such as arrl.org/part-97-amateur-radio, is a good idea. You may also find it helpful to review the information atarrl.org/operations-faq. Understanding licensing and identification rules will help you obtain the necessary licenses and ensure that you are operating legally.

Note that rules for individual contests and award programs may also place restrictions on the use of reciprocal licensing privileges and operating by remote control. Be sure you read and comply with these rules as well!

Appendix 1: What is CEPT?

CEPT is an acronym for the European Conference of Postal and Communications Administrations. It was established in 1959 by 19 European countries and now has 46 members. Activities include cooperation on commercial, operational, regulatory, and technical standardization issues. The CEPT Electronics Communications Committee (ECC) considers and develops policies on electronic communications activities in a European context, taking into account European and international legislation and regulations. This includes harmonization of license privileges among nations. CEPT implicitly recognizes and conforms with all ITU radio regulations.

Operating reciprocity between nations is defined in the document CEPT Amateur Radio License–Recommendation AR 61-01. It was first approved in 1985 and made it possible for radio amateurs from CEPT countries to operate temporarily in other CEPT countries without obtaining an individual license from the host country. It was revised in 1992 to enable participation by non-CEPT countries (including the U.S.). Further changes were made in 2016 and 2020 that take into account decisions on national amateur radio license conformity as agreed to under CEPT Recommendation AR 61-02 (HAREC–Harmonized Amateur Radio Examination Certificates). Links to CEPT and related documents can be found at arrl.org/cept.

All CEPT countries have administratively incorporated the Recommendations found in AR 61-01 as binding within their national license regulations and many have adopted AR 61-02 as well. All licensees must abide by the terms of CEPT as enacted by their national licensing authority and the host country. Participating non-CEPT countries like the U.S. agree to abide by the same regulatory principles and are free to incorporate the terms of these Recommendations into their national radio regulations in a format of their choosing.

Recommendation AR 61-01 defines license privileges and limitations. It specifies that operators must respect and follow all radio regulations of a host country, defines license class and reciprocity limitations, and specifies the authorized call sign prefix that must be used as a portable identifier when operating from a CEPT country. The ECC has also published Frequently Asked Questions Related to Radio Amateur Regulations in CEPT (updated February 8, 2017).

Appendix 2: Other Reciprocal Licensing Agreements

There are several other agreements similar to CEPT. The U.S. and Canada have had an automatic reciprocity process in place since 1952 that is specifically codified in Part 97.107, including the required method of station identification. In the Americas, the Organization of American States (OAS) CITEL Committee created the International Amateur Radio Permit (IARP) program in 1995. For these reciprocal licenses there is an actual license document, as opposed to the CEPT license, which is a home country license plus the supporting elements. There are many other bilateral licensing agreements between nations worldwide. Where reciprocal operating agreements do not exist, direct contact and negotiation with the destination country authorities is required. The ARRL website offers extensive information on this subject at arrl.org/us-amateurs-operating-overseas. 

Appendix 3: Common Misconceptions about CEPT

Misconception #1: CEPT covers the regulation of remote operation and authorizes remote operations across national borders. NO: CEPT only authorizes in-person operation from within signatory countries. CEPT does not address remote operation from inside or outside a country. A host country can add regulations for remote operation by CEPT licensees however it wants beyond the base CEPT agreement.  (See the ECC FAQ referenced in Appendix 1.)

Misconception #2: CEPT signatory countries often issue local exceptions to the CEPT rules. NO: Few exceptions exist and are noted in the CEPT agreement or in the host country’s rules. Exceptions generally do not conflict with the CEPT agreement.

Misconception #3: Non-U.S. citizen FCC licenses may be used as the basis for a CEPT license. NO: In order for an FCC license to be used this way, U.S. citizenship is required. Alien license holders are barred from using their FCC license for CEPT licensing purposes.

Misconception #4: A non-U.S. citizen from a CEPT country holding an FCC license may use their home country call sign with a U.S. portable designator while operating from the U.S. (including territories and possessions). NO: The FCC license and Part 97 rules always apply. Only FCC-issued call signs are authorized. Most violations of reciprocity rules involve foreign nationals operating a remote-controlled station in the U.S. without holding an FCC license or by using their national license call sign instead of their U.S. call.

Misconception #5: A non-U.S. citizen from a CEPT country holding an FCC license may use their FCC-issued call sign from locations outside the U.S. with a portable designator (prefix) indicating their location.

NO: A non-U.S. citizen holding an FCC license may not use their U.S. call sign outside FCC jurisdiction.