SurgePays, Inc. (SURG): PESTLE Analysis [Nov-2025 Updated]

SurgePays, Inc. (SURG) is a high-growth play, but the story is simple: their success hinges on government telecom subsidies. You are looking at a company that expects to hit up to $90 million in revenue for the 2025 fiscal year, yet it operates in a highly scrutinized, politically charged space. We need to map the external forces-from FCC regulations to the end of the Affordable Connectivity Program (ACP)-to understand the real risks and the true scale of their opportunity for bridging the digital divide.

Honestly, your biggest near-term risk and opportunity for SurgePays, Inc. is the government-subsidized Lifeline program; its stability is the political and economic fulcrum for their high-growth strategy.

Political Factors: Subsidy Reliance and Regulatory Risk

The core takeaway here is that SurgePays, Inc.'s growth is tied directly to Washington's mood. The company relies heavily on the Federal Communications Commission's (FCC) Lifeline program for its Torch Wireless revenue, and any shift in government priorities or funding cuts is your primary political risk. The conclusion of the Affordable Connectivity Program (ACP) in 2024 is already forcing a strategic pivot.

US political polarization means that federal telecom support is always on the table for debate. If the political winds shift, the revenue stream from over 125,000 Torch Wireless subscribers could be defintely impacted. That's the whole ballgame.

Action: Track all FCC and Congressional committee discussions on telecom subsidy reform quarterly.

Economic Factors: Growth vs. Liquidity

The numbers show massive scaling potential, but the liquidity picture needs attention. SurgePays, Inc.'s 2025 Revenue Guidance is strong, projecting between $75 million to $90 million, which is a huge signal of market penetration. Plus, their Q3 2025 net revenue surged 292% year-over-year to $18.7 million.

Here's the quick math: that kind of top-line growth is explosive, but it's coming at a cost. The company still reports net losses, and as of June 30, 2025, cash and equivalents were only $4.4 million. That's a liquidity concern when you're scaling this fast.

The good news is they are targeting the prepaid wireless market for LinkUp Mobile revenue, which is recession-resistant. People cut back on many things, but not their phone service. Still, watch that cash balance closely.

Sociological Factors: Bridging the Digital Divide

SurgePays, Inc. is fundamentally a social-impact business, targeting the digital divide. Their core mission is to bring affordable mobile connectivity to underserved communities and subprime consumers. This is a high-demand market, evidenced by their successful acquisition of over 125,000 Torch Wireless subscribers.

Their retail distribution network, which operates in thousands of local convenience stores, is a smart move. It builds community trust where traditional carriers often fail to reach. This strategy positions them well for organic growth.

What this estimate hides is that their growth is directly tied to the size of the low-income demographic eligible for federal aid. It's a clear, definable market, but it's not a market they can expand beyond without a major product shift.

Bridging the digital divide is a powerful growth driver.

Technological Factors: Scalable MVNE Platform

The technology backbone is solid and scalable, but competition is fierce. SurgePays, Inc. completed its Full Mobile Virtual Network Operator/Enabler (MVNO/MVNE, meaning they use another carrier's network infrastructure) platform integration with AT&T's nationwide 4G LTE and 5G network in 2025. This allows them to control the customer experience and scale rapidly without building their own towers.

Their proprietary point-of-sale (POS) software is the critical asset, acting as the backbone for customer activations and fintech top-ups. This scalable MVNE wholesale business model generates high-margin, recurring revenue, which is what we like to see.

Still, they need to maintain a competitive edge against larger wireless carriers' prepaid brands, like Verizon's Visible or T-Mobile's Metro. The technology has to be flawless to keep churn low.

Legal Factors: High Compliance Burden

The legal landscape is a high-stakes compliance game. Operating in the subsidized wireless space means SurgePays, Inc. faces a strict compliance burden with Federal Communications Commission (FCC) rules for the Lifeline program. Regulatory scrutiny is high here due to historical fraud concerns across the industry.

This isn't a place for shortcuts. Data privacy and security laws for their fintech and telecom customer base are critical, especially as they handle sensitive customer information and transactions. A single breach could be catastrophic.

Plus, the multi-year strategic agreement with AT&T creates contractual obligations that must be managed perfectly. That contract is the key to their network access, so it's a non-negotiable legal priority.

Environmental Factors: Focus on Social Governance (S in ESG)

The environmental impact is low, but the 'S' in ESG is their real focus. SurgePays, Inc. has a predominantly digital and service-based business model, meaning low direct environmental impact. They don't run factories or a massive fleet.

The main indirect factor is the disposal of subsidized mobile devices (e-waste), which is a long-term factor they will eventually have to address. What this estimate hides is the lack of publicly available, specific Environmental, Social, and Governance (ESG) or carbon footprint disclosures as of late 2025.

Their focus is clearly on social governance (S in ESG) by providing essential connectivity. That's where they get their credit. Finance: Draft a formal ESG disclosure plan, starting with the 'S' component, by Q1 2026.

SurgePays, Inc. (SURG) - PESTLE Analysis: Political factors

Reliance on the FCC's Lifeline program for Torch Wireless revenue.

SurgePays' core subsidized business, Torch Wireless, is fundamentally dependent on the Federal Communications Commission's (FCC) Lifeline program, a Universal Service Fund (USF) initiative. This reliance creates a stable, recurring revenue base but exposes the company to regulatory shifts. The Lifeline program budget for calendar year 2025 was set at approximately $2.9 billion, an increase of about $100 million from the prior year, which is a positive sign for the program's immediate stability.

This funding mechanism, supported by contributions from telecommunications carriers, is more insulated from the annual appropriations battles of Congress than programs funded directly by the federal budget. Still, the program's per-subscriber subsidy is modest, offering up to $9.25 per month for broadband or mobile phone service. This is the revenue stream underpinning Torch Wireless, which contributed $5.6 million to the company's Q3 2025 revenue and serves over 125,000 subscribers. Any future reduction in this monthly subsidy would directly erode the gross margin for every one of those subscribers.

Regulatory risk from the conclusion of the Affordable Connectivity Program (ACP) in 2024.

The political risk from the conclusion of the Affordable Connectivity Program (ACP) in May 2024 was a massive, near-term headwind that SurgePays has been actively navigating throughout 2025. The ACP, which provided a much larger monthly subsidy of $30 to $75, was a key driver of the company's revenue during its existence. The program's expiration, due to Congress failing to authorize additional funding, caused a sharp revenue drop for the company in the second half of 2024.

The company's transition away from the ACP is evident in its 2025 financial guidance. SurgePays generated over $240 million in revenue during the ACP era, but its 2025 revenue guidance is significantly lower, projected in the range of $75 million to $90 million. This drop shows the real-world financial impact of a major federal program ending, even as the company successfully pivots its infrastructure to the Lifeline program.

Here's the quick math on the transition risk:

Program	Funding Status (Nov 2025)	Monthly Subsidy (Non-Tribal)	SurgePays Revenue Impact
Affordable Connectivity Program (ACP)	Expired (May 2024)	$30.00 to $75.00	Caused sharp revenue decline in 2024.
Lifeline Program	Fully Funded (USF)	$9.25	Torch Wireless Q3 2025 Revenue: $5.6 million

Potential for shifting government priorities or funding cuts to subsidy programs.

While the Lifeline program's USF funding structure provides a buffer, future political shifts still pose a risk. The FCC's Wireline Competition Bureau has been actively managing the program's rules, such as extending a waiver that pauses the phase-out of support for voice-only services until December 1, 2025. This action is a temporary political decision that keeps the current benefit structure in place for another year, but it defintely highlights that the program's specifics are subject to ongoing regulatory review and potential change.

The risk isn't just a funding cut, but also adverse policy changes, like a sudden increase in minimum service standards (e.g., mobile broadband data capacity) without a corresponding increase in the subsidy. This would force SurgePays to absorb higher wholesale costs to meet the new mandate, directly impacting its gross profit, which was a loss of $2.6 million in Q3 2025.

US political polarization could impact future federal telecom support.

The failure of Congress to pass the Affordable Connectivity Program Extension Act, despite the program serving over 23 million households, is a concrete example of how US political polarization directly affects the telecom subsidy market. This inability to find consensus on a popular, $14.2 billion program creates a climate of uncertainty for any future, large-scale federal support initiative.

For SurgePays, this means:

• Future large-scale, high-subsidy programs like the ACP are unlikely in the near-term polarized environment.
• The company must focus entirely on the more stable, but lower-subsidy, Lifeline platform.
• The political appetite for increasing the Lifeline subsidy beyond the current $9.25 per month is low.

The political environment demands a strategy built on regulatory compliance and operational efficiency within the current, stable-but-capped Lifeline framework, not on the hope of a new, large subsidy program emerging. The end of ACP was a clear warning.

SurgePays, Inc. (SURG) - PESTLE Analysis: Economic factors

Aggressive Revenue Scaling and 2026 Guidance

You're looking for clear signs of scale, and SurgePays, Inc. (SURG) is showing them, but you need to look past the immediate quarter and toward the next year. The company is projecting a massive scaling potential, evidenced by its aggressive 2026 revenue guidance of $225 million. This is a significant jump from 2025 run-rate figures, and it reflects the full integration of its Mobile Virtual Network Operator (MVNO) and point-of-sale (POS) platforms.

Here's the quick math: the company's near-term guidance, issued earlier in 2025, projected over $200 million in revenue over the subsequent 12 months. This growth is tied directly to the national rollout of LinkUp Mobile and expanding MVNE (Mobile Virtual Network Enabler) partnerships. The business model is built to support this, so the focus is now purely on execution.

Q3 2025 Revenue Surge vs. Persistent Net Losses

The third quarter of 2025 (Q3 2025) demonstrated explosive growth, but it's crucial to remember that this is still a high-growth, pre-profitability story. Net revenue for Q3 2025 surged to $18.7 million, representing a 292% increase year-over-year. This is defintely a strong signal of product-market fit and distribution success.

Still, the company continues to invest heavily to capture market share, meaning net losses persist. The reported net loss for Q3 2025 was $7.5 million. To be fair, this loss is a significant improvement, narrowing by 47.6% compared to the prior year. The path to profitability hinges on improving gross margins in the Mobile Virtual Network Operator (MVNO) segment and the Point-of-Sale (POS) and Prepaid Services segment, which management anticipates turning positive during 2025.

Q3 2025 Financial Metric	Value	Year-over-Year Change
Net Revenue	$18.7 million	+292%
Net Loss	$7.5 million	-47.6% (Loss Narrowing)
Loss Per Share (GAAP)	-$0.38	N/A

Liquidity and Capital Risk

A key risk for any high-growth company is liquidity, and this is where you need to pay close attention. As of September 30, 2025, the company's cash, cash equivalents, and investment balances stood at only $2.5 million. This is a tight position, especially for a company with a quarterly net loss of $7.5 million.

The company's ability to fund its aggressive growth and manage working capital will be critical. This low cash balance, relative to the burn rate, suggests a high reliance on operational improvements and potentially future financing. What this estimate hides is the expected positive cash flow from operations before the end of 2025, which the company had previously guided to.

Recession-Resistant Market Strategy

SurgePays' business model is strategically positioned to be less susceptible to a broad economic downturn, making it a good defensive play in a volatile market. The focus is on the prepaid wireless market, which caters to the underbanked and value-conscious segments. In a recession, consumers typically trade down from expensive postpaid wireless plans to more affordable prepaid options, increasing the total addressable market for LinkUp Mobile.

The company also heavily relies on government-subsidized programs, which provide a stable, non-cyclical revenue base. Their Torch Wireless brand operates under the federally supported Lifeline program.

• LinkUp Mobile targets value-conscious consumers with plans starting at low monthly prices.
• Torch Wireless provides services via the non-cyclical, government-supported Lifeline program.
• The company launched a completely free wireless program for households receiving SNAP/EBT benefits, further cementing its position in a segment where demand is inelastic.

SurgePays, Inc. (SURG) - PESTLE Analysis: Social factors

Sociological

SurgePays, Inc. operates at the critical intersection of technology and social equity, with a core mission focused on bridging the digital divide for underserved communities and subprime consumers. This social purpose is not just a marketing angle; it is the fundamental driver of the company's revenue model, which is heavily reliant on government-subsidized programs like Lifeline and the massive, latent demand for affordable connectivity.

The company's success is defintely tied to its ability to serve a demographic that is often overlooked by major carriers. This market segment requires specific distribution and pricing models, which SurgePays addresses through its multi-channel platform. The strategic focus on the Lifeline program, a government-subsidized benefit that provides essential wireless connectivity, has driven significant growth in 2025.

Here's a quick look at the scale of this social factor opportunity as of Q3 2025:

• Lifeline-Subsidized Subscribers: Torch Wireless, the company's Lifeline brand, scaled to over 125,000 subscribers.
• Prepaid Subscribers: The affordable prepaid brand, LinkUp Mobile, surpassed 95,000 recurring active subscribers.
• Q3 2025 Lifeline Revenue: Torch Wireless contributed $5.6 million in revenue in the third quarter of 2025.

Core Mission and Community Trust

The business model is built on establishing community trust, a vital social factor when dealing with financially vulnerable consumers. SurgePays achieves this by integrating its services directly into the daily lives of its customers through a vast retail distribution network, primarily in local convenience stores. This 'boots-on-the-ground' approach transforms familiar neighborhood shops into trusted transaction points for service activation, payments, and prepaid top-ups.

The company's distribution network is a significant competitive moat. As of early 2025, the company's wireless services were sold and activated over a retail network of over 9,000 community-focused stores nationwide. By Q3 2025, the company had expanded its distribution via partners like HT Hackney, which services over 40,000 retail locations, and SurgePays' near-term goal is to expand its platform to 100,000 retail locations. This physical presence is crucial for building the social capital needed to serve the subprime market effectively.

Growth Tied to Low-Income Demographic and Federal Aid

SurgePays' growth trajectory is fundamentally tied to the size and needs of the low-income demographic eligible for federal aid. While the Affordable Connectivity Program (ACP) ended its enrollment freeze in February 2024 and its funding ran out, the Lifeline program remains a key subsidy. The sheer scale of the market that relied on the recently concluded ACP illustrates the massive demand for subsidized connectivity:

At the time of the enrollment freeze in February 2024, the ACP had 23,269,550 households enrolled. This number represents the immediate, addressable market of households facing a significant affordability gap, many of whom are now candidates for the Lifeline program and other affordable prepaid services like LinkUp Mobile.

The table below summarizes the key social-economic drivers and their corresponding scale within SurgePays' operations as of Q3 2025:

Social Factor Driver	Metric (Q3 2025 Data)	Value/Amount
Demand for Subsidized Connectivity	Torch Wireless (Lifeline) Subscribers	Over 125,000
Reach into Underserved Communities	Retail Distribution Network Goal	100,000 retail locations
Size of Addressable Market (Post-ACP)	Households Enrolled in ACP (Feb 2024 Freeze)	23,269,550 households
Demand for Affordable Prepaid Services	LinkUp Mobile Recurring Active Subscribers	Over 95,000

The company's ability to navigate the complex regulatory landscape of federal aid programs is a critical social-political risk, but the underlying social demand for their services is clear and substantial. The shift from the broader ACP to the more focused Lifeline program, coupled with the growth of the unsubsidized LinkUp Mobile, shows a strategic adaptation to sustain growth within this socially defined market. You should monitor the 2026 revenue guidance of $225 million to see if this dual-channel strategy successfully captures the post-ACP market.

SurgePays, Inc. (SURG) - PESTLE Analysis: Technological factors

The core of SurgePays, Inc.'s strategy rests on a technological platform shift in 2025, moving from a reseller model to a direct, scalable infrastructure provider. This transition, anchored by a major network integration, is what allows the company to project $75 million to $90 million in revenue for the full 2025 fiscal year, according to August 2025 guidance. This is a massive step up in technical capability, so let's look at the components.

Full MVNO/MVNE platform integration with AT&T's nationwide 4G LTE and 5G network completed in 2025.

Honestly, this was the pivotal technological event for SurgePays in 2025. The company finalized its Mobile Virtual Network Operator (MVNO) and Mobile Virtual Network Enabler (MVNE) platform integration with the AT&T network on April 1, 2025. This move was fast-it took less than six months from the November 2024 agreement to full network migration, which is defintely a rapid execution in telecom.

This integration is critical because it gives SurgePays direct access to a Tier-1 network's 4G LTE and 5G services for its own brands, LinkUp Mobile and Torch Wireless. More importantly, it validates their back-end infrastructure, allowing them to operate as an MVNE, selling that infrastructure to other wireless providers.

Proprietary point-of-sale (POS) software is the backbone for activations and fintech top-ups.

The company's proprietary POS software platform, deployed in a retail distribution network of over 9,000 convenience and community stores, is the engine for customer acquisition and recurring revenue.

This platform does more than just process sales; it's a full ecosystem for digital financial services, SIM activations, and prepaid top-ups. For example, the prepaid wireless top-up revenue through this POS network grew over 400% from Q1 to Q2 2024, demonstrating its power as a distribution channel.

Plus, SurgePays is now commercializing a proprietary software platform, DigitizeIQ, as of October 2025. This tool, repurposed from a legacy subsidiary that generated over $50 million in revenue, is now an intake engine for underbanked consumer marketing, converting transactional data into high-margin revenue streams.

• Activates SIMs and processes top-ups for LinkUp Mobile.
• Enables digital financial services in retail locations.
• Drives recurring transaction revenue from over 9,000 locations.
• Includes the ClearLine SaaS platform for retail media.

Scalable MVNE wholesale business model generates high-margin, recurring revenue.

The Mobile Virtual Network Enabler (MVNE) wholesale business, branded as HERO, is designed to be a high-margin, recurring revenue stream. The technology here is the ability to offer a full suite of nationwide wireless infrastructure services-like SIM provisioning and billing-to other MVNOs that don't have a direct carrier relationship.

This model is highly scalable because the incremental cost to onboard a new wholesale partner is minimal once the core platform is built and integrated with AT&T. As of the end of Q3 2025, the MVNE pipeline has expanded, with 3 MVNOs fully integrated and another 2 MVNOs in the onboarding process.

Here's the quick math on the MVNO/MVNE traction as of Q3 2025:

Metric	Value (Q3 2025)	Context
Net Revenue (Q3 2025)	$18.7 million	Up 292% year-over-year.
LinkUp Mobile Subscribers	Over 95,000 recurring active subscribers.
Torch Wireless Revenue	$5.6 million	Lifeline-subsidized brand, with over 125,000 subscribers.
MVNE Integrated Partners	3 MVNOs fully integrated.

Need to defintely maintain a competitive edge against larger wireless carriers' prepaid brands.

The technological edge for SurgePays is not just the platform itself, but its unique deployment. They combine the reliability of the AT&T network with a proprietary, purpose-built POS and fintech platform that reaches underserved communities through trusted local retailers. This combination is what the CEO calls a 'sustainable competitive advantage' that is 'very difficult to replicate.'

The technology must be cost-efficient to compete with large prepaid brands like AT&T Prepaid, Verizon's Visible, or T-Mobile's Metro by T-Mobile. SurgePays is showing operational leverage as they scale, with Selling, General, and Administrative (SG&A) expenses decreasing 32.5% year-over-year to $4.2 million in Q3 2025. This indicates their technology platform is built for scale, which is crucial for maintaining competitive pricing and higher margins. The platform is built to scale.

The risk remains that larger carriers could heavily subsidize their own prepaid brands or launch competing MVNE services, but SurgePays' focus on a niche distribution channel-the 9,000+ retail locations-provides a significant barrier to entry.

SurgePays, Inc. (SURG) - PESTLE Analysis: Legal factors

Strict compliance burden with Federal Communications Commission (FCC) rules for the Lifeline program.

You're operating in a highly regulated space, and the shift from the Affordable Connectivity Program (ACP) to Lifeline means your compliance burden is defintely increasing. SurgePays is leveraging its October 2024 Master Services Agreement with TerraCom, Inc., a licensed Lifeline provider, to transition its customer base, but this requires strict adherence to FCC rules. The financial incentive is huge, as the government reimbursement per subscriber ranges from $9.25 to $34.25 per month, depending on the state, so the compliance must be flawless.

The company is aggressively scaling its Lifeline-subsidized Torch Wireless brand, which is projected to reach an 80,000 to 90,000 monthly subscriber activation run rate by September 2025. This rapid growth demands robust internal controls to prevent fraud and ensure accurate eligibility verification, which are the main areas the FCC scrutinizes.

Regulatory scrutiny is high in the subsidized wireless space due to historical fraud concerns.

The subsidized wireless sector, especially Lifeline, has a history of high regulatory risk due to past instances of waste, fraud, and abuse, which means SurgePays operates under a constant microscope. The regulatory environment is not just federal; state-level bodies like the California Public Utilities Commission (CPUC) are also a factor.

Here's the quick math on the regulatory challenge:

• Lifeline Program Monthly Subsidy Range: $9.25 to $34.25 per subscriber.
• Torch Wireless Subscriber Activations: Projected 80,000-90,000 per month by September 2025.

A clear example of this scrutiny is the July 2025 CPUC resolution that denied TerraCom's request to participate in the California LifeLine Program, partly because the company failed to notify the CPUC of the SurgePays agreement and withdrew a compliance plan from the FCC. This shows that even strategic partners bring regulatory baggage that SurgePays must manage. You have to be careful about who you partner with.

Data privacy and security laws for the fintech and telecom customer base are critical.

As a technology company with a Mobile Virtual Network Operator (MVNO) and a Point-of-Sale (POS) fintech platform, SurgePays handles vast amounts of personally identifiable information (PII) for its telecom and financial services customers. This exposes the company to a fragmented, and increasingly strict, patchwork of US state data privacy laws.

In 2025 alone, eight new state privacy laws are taking effect, including in states like Iowa, New Jersey, and Tennessee, which adds significant compliance complexity. For instance, the California Consumer Privacy Act (CCPA), as amended by the CPRA, applies to companies with annual revenue exceeding $26.6 million or those processing data for over 100,000 California residents.

Given SurgePays' 2025 revenue guidance of $75 million to $90 million, they are clearly subject to these laws. The company must invest in data protection assessments and update privacy disclosures across all states where its 125,000+ Lifeline and 95,000+ LinkUp Mobile subscribers reside.

2025 State Privacy Law Triggers	SurgePays 2025 Data	Compliance Risk Status
CCPA (CA) Revenue Threshold	>$26.6 million annual revenue	High (2025 Revenue Guidance: $75M-$90M)
TIPA (TN) Revenue Threshold	>$25 million annual revenue	High (Exceeds threshold)
Customer Data Volume (Lifeline/LinkUp)	>220,000 total subscribers (Q3 2025)	High (Likely exceeds 100,000 consumer data processing threshold in key states)

Contractual obligations under the multi-year strategic agreement with AT&T.

The multi-year strategic agreement with AT&T, signed in November 2024 and fully integrated by April 1, 2025, is the operational backbone for SurgePays' wireless business. This Mobile Virtual Network Operator (MVNO) contract is a critical legal document that dictates service quality, network access, and wholesale pricing. Any material breach could be catastrophic, as it would immediately cut off access to AT&T's 4G LTE and 5G wireless services nationwide.

The contract also enables SurgePays to launch its Mobile Virtual Network Enabler (MVNE) wholesale business, where it provides infrastructure services to other wireless companies. This means the legal obligations extend beyond just its own retail brands (Torch Wireless, LinkUp Mobile) to its new wholesale partners, adding a layer of complexity to the master service agreement.

SurgePays, Inc. (SURG) - PESTLE Analysis: Environmental factors

Low direct environmental impact due to a predominantly digital and service-based business model.

As a Mobile Virtual Network Operator (MVNO) and a fintech platform, SurgePays, Inc.'s direct environmental footprint is inherently low. The core business involves selling prepaid wireless services and digital financial transactions through a point-of-sale (POS) platform, not manufacturing physical goods or operating energy-intensive network infrastructure like cell towers [cite: 8, 5 in previous step]. This means the company's primary environmental impact is limited to its corporate offices, data center usage (which is often outsourced), and the logistics of its retail distribution network, which is minimal compared to a Mobile Network Operator (MNO).

The company is essentially a software and service layer. This is defintely a low-carbon business model. The real environmental risk is indirect, sitting further down the value chain.

Indirect impact from the disposal of subsidized mobile devices (e-waste) is a long-term factor.

The most significant environmental risk for SurgePays is the e-waste generated by the devices it distributes to its customer base, particularly through its subsidized programs like Lifeline. While the company does not manufacture the devices, it is a key distributor of 'Phone-in-a-Box' kits and SIM cards [cite: 4 in previous step]. This creates a large, indirect environmental liability.

The scale of this liability is growing with the company's expansion. For instance, SurgePays' LinkUp Mobile brand shipped over 250,000 SIM cards to customers and partners by the end of Q1 2025 [cite: 9 in previous step]. Considering the US e-waste challenge, where over 150 million mobile phones are discarded annually and the overall e-waste recycling rate was estimated at only about 15.4% in 2021, the risk is clear.

Here's the quick math on the wider market risk SurgePays operates within:

US E-Waste Metric (2025 Context)	Amount/Value	Significance to SurgePays
US E-Waste Management Market Size	Projected $16.0 billion in 2025	Indicates a growing, regulated market for device recycling.
Annual US Mobile Phone Discards	Over 150 million units	Directly quantifies the scale of the product life-cycle problem.
US E-Waste Recycling Rate (2021 est.)	Approximately 15.4%	Highlights the high probability of distributed devices ending up in landfills.
SurgePays Q3 2025 Lifeline Subscribers	Over 125,000 [cite: 4 in previous step]	Represents the growing base of devices that will eventually become e-waste.

Lack of publicly available, specific ESG or carbon footprint disclosures as of late 2025.

As of late 2025, SurgePays, Inc. has not published a dedicated Environmental, Social, and Governance (ESG) report or a specific, auditable carbon footprint disclosure. This lack of transparency is a risk for institutional investors who increasingly rely on these metrics for capital allocation and is a common trait among smaller, high-growth technology companies.

The absence of a formal disclosure means investors cannot quantify the company's Scope 1, 2, or 3 emissions (the full range of emissions from operations to the supply chain). This is a gap that will need to be filled as mandatory sustainability disclosures become more common globally [cite: 13 in previous step].

Focus is on social governance (S in ESG) by providing essential connectivity.

While the 'E' (Environmental) in ESG is a blind spot, the company's entire business model is built around the 'S' (Social). SurgePays' core mission is to bridge the digital divide by providing essential mobile and financial services to underserved communities [cite: 7 in previous step].

The most concrete evidence of this social focus is the performance of its Lifeline-subsidized brand, Torch Wireless, which provides essential wireless connectivity to qualifying low-income individuals [cite: 4 in previous step].

Key Social Impact Metrics (Q3 2025):

• Lifeline Subscriber Base: Over 125,000 active users [cite: 4 in previous step].
• Lifeline Revenue Contribution: $5.6 million in Q3 2025, up from virtually zero in Q3 2024 [cite: 4 in previous step].

This focus on government-supported programs provides a stable, recurring revenue base, but more importantly, it directly aligns with the social goal of universal access to communication services [cite: 3 in previous step]. The current strategy is to prioritize this social value creation, with the environmental component remaining an unaddressed, but manageable, long-term risk.