Oklahoma broadband property tax: what changes January 1, 2027

What if your company sells internet service in Oklahoma? Until now, the answer to "who values your property for tax purposes" depended on what kind of company you were. A cable operator with a broadband arm was handled one way. A telephone company was handled another. A fixed-wireless outfit on a grain elevator was handled a third. Starting with tax year 2027, Oklahoma broadband property tax gets a category of its own, and a new filing regime to go with it.

The change comes from Senate Bill 1122, passed in the 2026 session, which amends two sections of the Ad Valorem Tax Code (68 O.S. §§ 2808 and 2847). It creates a subclass of public service corporations called "broadband service providers" and tells the State Board of Equalization to assess their property at 15% of fair cash value. The bill became law without the Governor's signature on April 29, 2026, and takes effect January 1, 2027.

Then, on September 22, 2026, the Oklahoma Tax Commission adopted emergency rules (Chapter 10, Subchapter 18) to run the first filing and assessment cycle. Those rules are pending gubernatorial approval as we write this, and the Commission's own impact statement says further provisions may follow through regular rulemaking. So treat what follows as the current shape of the thing, not the final one.

We'll walk through the questions in the order they come up for the companies we see in this space: independent ISPs, fixed-wireless operators, cable companies that sell internet, and electric cooperatives and telephone companies with broadband subsidiaries. Their CPAs should find it useful too.

First question: who values your property, the county or the state?

Most Oklahoma business property is locally assessed. The county assessor values your building and your equipment, you file a rendition each year, and if you disagree you go to the county board of equalization. If that is your world, our piece on the business personal property rendition covers the mechanics.

Public service corporations live in a different system called central assessment. The Oklahoma Tax Commission's Ad Valorem Division collects the company's annual return, develops a recommended fair cash value for the company as a whole, and the State Board of Equalization sets the assessment. That value is then distributed to the local taxing jurisdictions where the company operates. Railroads, airlines, pipelines and utilities have lived here for a long time.

The two systems also use different assessment percentages, which is where the money is. Fair cash value is the price the property would bring in a fair, voluntary sale. The assessment percentage is the slice of that value the tax rate actually applies to. According to the Commission's ad valorem page, the current central-assessment percentages are 11.84% for airlines and railroads, 12% for video services providers, and 22.85% for public service corporations generally.

SB 1122 inserts a new number into that list. A broadband service provider is assessed at 15% of fair cash value under new § 2847(E). That sits above the 12% cable and video figure and well below the 22.85% that applies to a general public service corporation. Whether 15% is good news or bad news for your company depends entirely on which bucket you were in before.

Second question: are you a "broadband service provider" at all?

The statutory definition is broad. A broadband service provider is "any company, corporation, trustee, receiver, or other person offering broadband-based services including fixed or mobile Internet access, Voice over Internet Protocol, or Internet protocol television, to end-user consumers."

Two phrases do the work, and the emergency rules (710:10-18-2) define both.

"End-user consumer"

An end-user consumer is a customer that uses broadband-based services for its own purposes and does not resell them. The rule says it plainly: an internet service provider, wholesaler, or other reseller is not an end-user consumer. So a company that only sells wholesale transport or dark fiber to other carriers is not, on that fact alone, offering services to end users. A company that sells to households and businesses is.

"Offering broadband-based services"

Offering covers furnishing, selling, marketing, or holding out the availability of fixed or mobile internet access, VoIP, or IPTV to end-user consumers in Oklahoma. Notice "holding out." A company that advertises residential internet it has not yet turned on is arguably offering it. This is a definition built to be inclusive.

Here is the practitioner's point. The definition reaches past internet access. VoIP phone service counts. IPTV counts. A telephone cooperative that sells voice over its fiber is offering a broadband-based service even if it thinks of itself as a phone company. The label on your door does not control; the services on your rate card do.

Third question: do you fit one of the carve-outs?

SB 1122 also amended § 2808, the definitions section, to say that cable television companies and fixed wireless broadband internet service providers are not "transmission companies" or "public service corporations" under the Ad Valorem Tax Code. In plain terms, those two kinds of companies stay locally assessed by the county, not centrally assessed by the State Board.

The fixed-wireless exclusion is a cliff

The statutory definition of a fixed wireless broadband internet service provider opens with the operative words, "an entity that solely offers access to the Internet through a stationary fixed point-to-point connection," and goes on to describe the technology. The emergency rule (710:10-18-15) repeats the standard: a company claiming the exclusion must show that it solely offers access to the internet through a stationary fixed point-to-point connection.

Read "solely" twice. A fixed-wireless operator that adds a hosted VoIP product or a small fiber build in town is no longer offering access to the internet solely through a fixed point-to-point connection. The exclusion is not pro-rated. On the face of the rule, it is either available or it is not, and a second service line can be what removes it. Growth decisions that look purely commercial have a property tax consequence attached.

Cable status is decided company by company

Cable television companies keep their existing position. Under § 2847(C), a video services provider certifies its gross receipts each year by April 15, and cable personal property is presumed assessed at 12% unless shown otherwise. The emergency rules (710:10-18-11) say the certification must report total gross receipts for the prior calendar year, for the whole system and for Oklahoma, and separately report gross receipts from video programming services.

The rules on cable status (710:10-18-7) make clear that the Commission will not take your word for it. Status is determined for the specific legal entity whose return is at issue, on the totality of the relevant facts and circumstances. The listed factors include what services the entity offers in Oklahoma, whether cable is sold stand-alone or bundled with internet and telephone, how it is marketed, the terms of service, and revenue and subscriber counts by service line.

Fourth question: what does the Commission expect you to file?

Everything the Commission wants from you is filed electronically. Under 710:10-18-4, centrally assessed companies file their returns, schedules and questionnaires through OkTAP unless the Commission authorizes something else, and the Ad Valorem Division may require whatever information it needs to decide whether a company is subject to central assessment in the first place.

The broadband questionnaire

Rule 710:10-18-10 creates an electronic broadband service provider questionnaire in OkTAP. Any company that may be a broadband provider completes it. The questionnaire has to establish the reporting legal entity, the services offered in Oklahoma, whether those include fixed or mobile internet, VoIP, or IPTV, and whether they go to end-user consumers. It also asks whether the company claims a cable or fixed-wireless exclusion, whether it claims video services provider status, and what services or property its affiliates hold. The Commission may demand supporting records.

The impact statement lists the number of affected providers as "Unknown." That single word explains the questionnaire. The Commission does not have a roster of Oklahoma broadband providers. It is going to build one, and the questionnaire is the net. If your company has never been centrally assessed and never filed anything with the Ad Valorem Division, do not assume you are off the radar for 2027.

The mixed-service supplemental schedule

Rule 710:10-18-12 requires a supplemental schedule from companies that offer both video and broadband, or both covered and excluded service lines. It wants revenue by service line, subscriber counts by line, which services the entity provides directly, which assets are shared across lines, and which assets are owned by an affiliate but used by the reporting company (or the reverse).

This is the data most mixed-service companies do not have sitting in a clean report. Fiber plant carries video and internet on the same strand. Headend equipment serves both. The schedule asks you to describe that sharing, and the answer feeds the classification decision below. If your books are not kept by service line, tax year 2027 is a reason to start.

What the Division reviews

Under 710:10-18-6, the Division checks whether the filing is complete and on time, whether the company is properly centrally assessed, what fair cash value to recommend to the Board, whether penalties apply, and which subsection of § 2847 governs. It may ask for organizational charts, service descriptions, websites and marketing materials, customer agreements, technical descriptions of fixed-wireless systems, financial statements, subscriber reports, and sworn affidavits. Expect your marketing to be read as evidence of what you offer.

Fifth question: which Oklahoma broadband property tax treatment applies?

Rule 710:10-18-9 is the center of the package. It walks through the classification factors and then names four recommended treatments: public service corporation only; broadband service provider only; video services provider plus public service corporation; and video services provider plus broadband service provider.

The way the subsections of § 2847 fit together matters here.

• Subsection (C) covers video programming value, certified annually. The rule adds a protection: a company is not recommended for central assessment solely because it holds video services provider status if it is properly treated as a cable company.
• Subsection (D) keeps the historical percentage, tied to 1996, for other centrally assessed property. A public service corporation that does not qualify under (C) or (E) is recommended for treatment under (D).
• Subsection (E) is the new 15% broadband treatment. The rule describes it as an alternative to subsection (D), not a layer on top of it.

For mixed companies, video value goes under (C) and the remainder goes under (D) or (E) depending on whether the entity qualifies as a broadband provider. And then comes the sentence that will generate the arguments: under subsection (i), no allocation shall be created between § 2847(D) and (E) for broadband and non-broadband property, outside the video-plus-broadband case in subsection (g), absent a statute or a final court order.

Translate that. A telephone company or electric utility with a broadband arm inside the same legal entity cannot, under the emergency rule, split its property into a 15% broadband piece and a 22.85% utility piece. The entity gets one treatment under (D) or (E). The Commission is not going to invent a mixed ratio, and it has said so in the rule.

Sixth question: does your entity structure change the answer?

Every determination in this package is made entity by entity. Rules 710:10-18-7 and -8 say so expressly, and the factors in the broadband-status rule include affiliate relationships, equipment type and technical descriptions, not just revenue.

That has consequences. A holding company with a cable subsidiary and a separate ISP subsidiary may find one child locally assessed and the other centrally assessed at 15%. A cooperative that houses broadband in the parent may face the no-allocation rule described above, while a cooperative that built its broadband business in a subsidiary may be looking at (E) treatment for that subsidiary alone. Neither outcome is automatically better. Fair cash value, the local tax rates where the property sits, and what the business would have paid under the old regime all have to be run before anyone can say which structure costs less.

Seventh question: what happens when you disagree?

Central assessment also moves the dispute forum. A locally assessed company that disagrees with its value goes to the county assessor and the county board of equalization, the process we describe in our article on property tax protests for Oklahoma commercial property. A centrally assessed company deals with the Ad Valorem Division and the State Board of Equalization instead. The deadlines and procedure are different, and a company that has only ever protested at the county level should not assume the calendar it knows carries over.

Two kinds of disputes are foreseeable. The first is classification: whether the entity is a broadband service provider, a cable company, a fixed-wireless provider, or a general public service corporation. Because the rules make that a facts-and-circumstances call, the company's own filings, marketing and contracts will be the evidence. The second is value: once the bucket is settled, what the property is worth. Both are worth thinking about before the first return is filed, because the questionnaire answers you give in the first cycle will be the record in every later one.

What we would do between now and the first filing

Nothing here calls for panic. The rate and the effective date are set by statute, the Commission has said the emergency rules cover only initial implementation, and the first assessment cycle is tax year 2027. What the next several months are good for is preparation.

1. Inventory every legal entity in the group and list, entity by entity, exactly which services each one offers to end-user consumers in Oklahoma. Include VoIP and IPTV, not just internet access.
2. If you rely on the fixed-wireless exclusion, test the word "solely" against every product on the rate card and every product in the pipeline.
3. If you are a cable operator, confirm your video services certification is current and that you can separate video programming receipts from everything else.
4. If you are mixed-service, start building the revenue, subscriber, shared-asset and affiliate-asset data the supplemental schedule asks for. Decide now how shared plant will be described.
5. Pull marketing materials, customer agreements and the website and read them the way the Ad Valorem Division will: as statements of what the company offers.
6. Model the tax under both the old treatment and the new one before deciding whether any restructuring is worth the cost, and remember that the no-allocation rule limits what a single entity can do.

If your company sells internet, voice or video in Oklahoma and you are not sure which assessment regime you will be in for 2027, this is a good season to find out. You can reach our practice through the contact page or the Oklahoma City office, and a conversation now, while the first return is still months away, tends to cost a good deal less than untangling a classification after the State Board has acted on it.

This article is general information about Oklahoma, Texas, and federal law, not legal advice, and it does not create an attorney-client relationship. Facts matter; talk to a lawyer about yours.