An interconnected VoIP service, meaning any internet-protocol voice service that lets users both place and receive calls on the public telephone network, is regulated by the FCC on essentially the same terms as a traditional phone company. Interconnected VoIP FCC compliance requirements cover emergency calling, lawful intercept, caller ID authentication, customer privacy, accessibility, universal service contributions, number portability, and orderly shutdown. Each obligation has its own filing, deadline, and penalty structure, and several of them can take a provider off the phone network entirely if ignored.
Which Services Are Covered
Four technical elements define an interconnected VoIP service under the FCC’s rules: real-time two-way voice, a broadband connection at the user’s location, IP-compatible customer equipment, and the ability to both place calls to and receive calls from any number on the public switched telephone network.1eCFR. 47 CFR 9.3 – Definitions The two-way PSTN interconnection is the deciding factor. An app that only connects users to other users of the same app is not covered. One-way services are not covered. Once a service crosses the interconnection line, every obligation below applies; there is no partial-compliance tier.
FCC Registration Number
Before filing anything else, a provider needs an FCC Registration Number (FRN), a ten-digit identifier issued through the Commission Registration System (CORES).2Federal Communications Commission. COmmission REgistration System for the FCC The FRN is attached to every downstream filing, from Form 499 to the annual regulatory fee payment. Register early, because other deadlines start running once the service goes live.
E911 Service and Location Information
Emergency calling is the most heavily enforced area. An interconnected VoIP provider must route every 911 call to the correct local public safety answering point and deliver the caller’s location.3eCFR. 47 CFR 9.11 – E911 Service How that location is delivered depends on the service type.
Fixed services, where the equipment stays at one address, must provide automated dispatchable location on every 911 call. Non-fixed services must provide automated dispatchable location where technically feasible, and otherwise maintain a Registered Location that the subscriber sets at signup and can update at any time. Non-fixed providers must also detect when a call is being placed from somewhere other than the registered address and either prompt the user to update or update the location automatically.3eCFR. 47 CFR 9.11 – E911 Service
Penalties are calculated per incident. The FCC applies a base forfeiture of $1,000 for each 911 call a provider fails to transmit. When a provider fails to notify public safety answering points about an outage, fines run on a sliding scale: $10,000 per answering point for the first 500 not notified, $5,000 each for the next 500, and $1,000 each after that.4Federal Communications Commission. Notice of Apparent Liability for Forfeiture (FCC-23-81)
CALEA Lawful Intercept
The Communications Assistance for Law Enforcement Act requires interconnected VoIP providers to design their networks so that court-authorized wiretaps and surveillance can be executed on demand.5Federal Communications Commission. Communications Assistance for Law Enforcement Act The network must be able to isolate and deliver both call content and call metadata for a specified target when a lawful order arrives. Non-compliance carries penalties of up to $10,000 per day for each ongoing violation under 47 U.S.C. § 1007.6Office of the Law Revision Counsel. 47 USC 1007 – Enforcement Orders The daily structure means delay compounds quickly.
STIR/SHAKEN and the Robocall Mitigation Database
Every interconnected VoIP provider must implement the STIR/SHAKEN caller ID authentication framework in the IP portions of its network so downstream carriers can verify that a calling number has not been spoofed.7Federal Communications Commission. Combating Spoofed Robocalls with Caller ID Authentication Independently, every voice provider, regardless of network type, must maintain a written robocall mitigation program describing what it does to keep illegal robocalls off its network.
Both the STIR/SHAKEN status and the robocall mitigation plan must be certified in the FCC’s Robocall Mitigation Database.8Federal Communications Commission. Robocall Mitigation Database The consequence of missing or non-compliant filings is not just a fine. Other voice providers and intermediate carriers are barred from accepting traffic from any provider not listed. In August 2025, the Enforcement Bureau ordered all carriers to block traffic from 185 companies that had been removed from the database for non-compliant filings.9Federal Communications Commission. FCC Orders Blocking of All Traffic from 185 Companies For a voice provider, being cut off from the network ends the business.
CPNI Privacy and Annual Certification
Customer Proprietary Network Information (CPNI) includes call detail data such as who a subscriber calls, when, and for how long. Interconnected VoIP providers face the same use restrictions as traditional carriers. CPNI may be used to market services within the same category the customer already buys, but generally cannot be used to market unrelated categories without customer approval, and cannot be used to track which customers are calling competing services.10eCFR. 47 CFR 64.2005 – Use of Customer Proprietary Network Information Without Customer Approval
One rule is specific to interconnected VoIP: providers may use CPNI without customer approval to market add-on features like call forwarding, caller ID, and call blocking.10eCFR. 47 CFR 64.2005 – Use of Customer Proprietary Network Information Without Customer Approval Sharing with affiliates or third parties outside that exception triggers approval requirements.
Every interconnected VoIP provider must file an annual CPNI compliance certification with the FCC’s Enforcement Bureau, generally due March 1 for the prior calendar year. The filing must be signed by a company officer with personal knowledge that adequate privacy procedures are in place, and must include a written explanation of those procedures, a summary of any customer complaints alleging unauthorized CPNI disclosure, and a description of any actions taken against data brokers during the prior year.11eCFR. 47 CFR 64.2009 – Safeguards Required for Use of Customer Proprietary Network Information The FCC has confirmed there is no small-company exemption.12Federal Communications Commission. FCC Enforcement Advisory: Annual CPNI Certifications
Accessibility and Relay Service
Under the FCC’s advanced communications accessibility rules, both the service and the equipment used to access it must be usable by people with disabilities unless achieving that is not feasible.13eCFR. 47 CFR Part 14 – Access to Advanced Communications Services and Equipment by People with Disabilities All VoIP providers must also contribute to the Telecommunications Relay Services Fund, which pays for services allowing deaf, hard-of-hearing, and speech-disabled users to communicate by phone. TRS contributions run through the same Form 499-A process as USF.
Universal Service Fund Contributions
Interconnected VoIP providers must contribute to the federal Universal Service Fund, which subsidizes rural and high-cost broadband, healthcare connectivity, school and library internet access, and the Lifeline program for low-income households. Providers report interstate and international end-user revenues to the Universal Service Administrative Company annually on FCC Form 499-A, then file quarterly Form 499-Q filings that determine actual payments.14Federal Communications Commission. FCC Form 499-A Telecommunications Reporting Worksheet
The contribution factor, the percentage of assessed revenues owed each quarter, is set by the FCC. For 2026 it is 37.6% in the first quarter and 37.0% in the second quarter.15Universal Service Administrative Company. Contribution Factors That figure feeds directly into a provider’s cost structure.
De Minimis Threshold
For calendar year 2026, a provider with annual interstate and international end-user telecom revenue of $37,175 or less qualifies as de minimis and does not have to file Form 499-Q or make direct USF payments.16Universal Service Administrative Company. De Minimis The annual Form 499-A is still required. De minimis status covers only USF. TRS Fund contributions, local number portability cost recovery, numbering plan administration, and regulatory fees apply no matter how small the provider is.
Interstate Safe Harbor
Because interconnected VoIP is often sold in bundles that mix local and long-distance usage, the FCC lets providers treat 64.9% of interconnected VoIP revenues as interstate for contribution purposes.14Federal Communications Commission. FCC Form 499-A Telecommunications Reporting Worksheet A provider that does not use the safe harbor must allocate revenues based on its own books and records in a manner consistent with its accounting practices.
Local Number Portability
Interconnected VoIP providers must complete valid port requests, whether a number is coming in from another carrier or leaving for one, and cannot enter any agreement that would prevent a customer from porting a number.17eCFR. 47 CFR 52.34 – Obligations of Interconnected VoIP Providers and VRS/IP Relay Providers A provider cannot refuse a port because the customer owes money or is still under contract.
Simple ports between wireline or intermodal carriers must be completed within one business day. Non-simple ports, which involve more complex configurations, get up to four business days unless the receiving provider or customer requests more time.18Federal Communications Commission. Wireline Competition Bureau Reminds Interconnected VoIP Providers of Their Local Number Portability and Section 214 Discontinuance Obligations Ports involving interconnected VoIP are classified as intermodal ports. The one- and four-business-day windows are hard deadlines.
Section 214 Discontinuance
A provider that wants to stop offering interconnected VoIP service cannot simply turn it off. Discontinuance rules under 47 U.S.C. § 214 and 47 CFR § 63.71 require filing a discontinuance application with the FCC and giving customers adequate notice before ending service.19Federal Communications Commission. WCB Reminds iVoIP Providers of LNP and Section 214 Discontinuance Duties The rule exists to protect subscribers who depend on the service for 911 and daily use. Providers that go dark without following the process face enforcement action.
State and Local Taxes
The Internet Tax Freedom Act’s ban on state and local taxes on internet access does not apply to interconnected VoIP. The statute carves out “voice or similar service utilizing Internet Protocol,” so states and localities may tax interconnected VoIP the same way they tax traditional phone service.20U.S. Congress. Internet Tax Nondiscrimination Act (Public Law 108-435)
In practice, subscribers see a monthly 911 surcharge funding local emergency dispatch, along with state and local sales taxes on the service price, and in some jurisdictions telecom-specific excise or gross receipts taxes. Rates vary widely by service address, so a provider operating in multiple jurisdictions needs billing systems that can apply the right rules for every customer location.