
Clawback provisions are legal mechanisms that allow NTIA or Eligible Entities to recover BEAD funds already disbursed when subgrantees fail to meet requirements, deadlines, or service obligations. These provisions must be included in all subgrant agreements and may be triggered by issues such as missed deployment benchmarks, inadequate service speeds, cybersecurity failures, or labor violations.
Under the Infrastructure Investment and Jobs Act, NTIA may also pursue clawbacks directly from Eligible Entities that fail to enforce accountability. Clawback provisions apply throughout the full service period—often 10+ years—making strong compliance monitoring essential for financial protection.
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