FCC direct numbering authorization for interconnected VoIP providers
Interconnected Voice over Internet Protocol (VoIP) providers can obtain telephone numbers directly from numbering administrators without relying on carrier partners. The Federal Communications Commission (FCC) established this authorization process in 2015 and strengthened it through subsequent rulemaking, fundamentally transforming how VoIP services operate within the North American Numbering Plan.
Who should use this guide: Compliance officers preparing regulatory applications, legal counsel evaluating operational independence strategies, and operational managers eliminating carrier intermediaries. This guide addresses providers scaling services across multiple states, those facing carrier relationship challenges, and companies needing direct control over numbering resources for technical or business reasons.
You'll learn the complete framework for securing and maintaining FCC VoIP numbering authorization – from understanding the regulatory foundation to navigating the application process and post-approval compliance responsibilities.
Understanding FCC VoIP Numbering Authorization Requirements
The FCC's jurisdictional role in telephone number allocation
The FCC maintains full jurisdiction over the U.S. telephone numbering system, managing nearly 1 billion telephone numbers with two primary objectives: promoting competitive markets and ensuring efficient resource utilization. This authority includes establishing rules for who can access numbering resources and under what conditions.
Penalties for non-compliance: Violations of FCC numbering rules result in substantial forfeitures. The PayG, LLC enforcement action demonstrates the consequences: underpayment of regulatory fees totaling $404,416.28 over four years led to a proposed forfeiture of $1,460,085 – more than three times the underpaid amount. The FCC can also revoke numbering authorizations and reclaim assigned numbers from non-compliant providers.
The Commission's approach to VoIP provider access reflects a deliberate policy shift toward market liberalization. Rather than maintaining traditional gatekeepers, the FCC recognized that direct access would foster innovation, reduce operational inefficiencies, and accelerate the deployment of advanced communication services.
The 2015 FCC Report and Order: How VoIP providers gained direct number access
On June 22, 2015, the FCC released its landmark Report and Order (FCC 15-70) establishing the framework for interconnected VoIP providers to obtain numbers directly from the North American Numbering Plan Administrator (NANPA) – the entity responsible for administering and assigning telephone numbers under the North American Numbering Plan – and the Pooling Administrator (PA) – which manages the allocation of blocks of 1,000 numbers (thousands-blocks) to carriers in specific rate centers. The Commission determined that the benefits of direct access – improved competition, deployment of advanced services, and elimination of inefficiencies – outweighed what it characterized as "perceived risks."
Addressing perceived risks: The FCC's 2015 Order acknowledged industry concerns that direct VoIP access could lead to number exhaustion, fraud, or reduced accountability. The Commission concluded these risks were manageable through: (1) applying the same stringent eligibility criteria used for traditional carriers, (2) requiring comprehensive compliance certifications, (3) maintaining oversight through ongoing reporting obligations, and (4) retaining full enforcement authority including the ability to revoke authorization and reclaim numbers. Subsequent implementation has validated this assessment, with no significant increase in numbering-related fraud or resource exhaustion attributable to VoIP providers.
The rules specifically address 10-digit NANP numbers, not IP addresses or other identifiers. The FCC rejected arguments that it must first classify interconnected VoIP as a telecommunications service before granting direct access, demonstrating commitment to technology-neutral regulation.
TRACED Act requirements and robocall mitigation for VoIP providers
Congress reinforced the importance of numbering oversight through the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence (TRACED) Act, which directed the FCC to examine ways to reduce access to telephone numbers by potential perpetrators of illegal robocalls.
The Commission's September 2023 updates (FCC 23-75) directly respond to this Congressional mandate. These enhanced rules safeguard U.S. numbering resources, protect consumers and national security interests, and reduce opportunities for regulatory arbitrage by bad actors who might exploit gaps in oversight.
Key changes in September 2023 (FCC 23-75): The updated rules introduced several critical requirements:
Enhanced foreign ownership scrutiny: Applications with 10% or greater foreign ownership are automatically referred to Executive Branch agencies for national security review, with more stringent vetting of ownership structures
Robocall Mitigation Database filing: Applicants must certify their enrollment in the FCC Robocall Mitigation Database and provide their robocall mitigation plan
STIR/SHAKEN implementation certification: Providers must certify their compliance with caller ID authentication requirements or provide detailed plans for implementation
Strengthened ongoing obligations: Enhanced reporting requirements and accelerated enforcement procedures for non-compliant providers
Increased application scrutiny: More detailed review of technical capacity, interconnection arrangements, and financial viability
VoIP Provider Eligibility Requirements for Direct Numbering
Who qualifies for FCC direct numbering authorization
The direct numbering authorization process is available exclusively to interconnected Voice over Internet Protocol (VoIP) providers. This classification matters – you must offer real-time, two-way voice communications that connect to and receive calls from the public switched telephone network (PSTN).
Definition of interconnected VoIP: Under 47 CFR § 9.3, an interconnected VoIP service must:
Enable real-time, two-way voice communications (not just messaging or one-way audio)
Require a broadband connection from the user's location
Require Internet Protocol-compatible customer premises equipment (CPE)
Permit users generally to receive calls that originate on the PSTN and to terminate calls to the PSTN (full PSTN interconnection in both directions)
Examples of services that qualify vs. don't qualify:
Qualify:
Business VoIP phone systems with PSTN calling capability (e.g., RingCentral, 8x8, Vonage Business)
Residential VoIP services with PSTN access (e.g., Vonage Home, Ooma)
Cloud contact center platforms that connect to the PSTN
One-way VoIP services (e.g., audio streaming, podcast delivery)
VoIP services that only allow calling other users of the same service without PSTN access
Mobile apps that route calls through cellular networks rather than broadband IP connections
Obtaining direct access is a voluntary business decision. You can continue operating through carrier partnerships if you prefer that model. The authorization provides an alternative path for those seeking greater operational independence.
Meeting the facilities readiness requirement for VoIP numbering
You must demonstrate facilities in place – or will have them in place – to provide service within 60 days of the numbering resources activation date (also known as the LERG effective date – the date when telephone number assignments become active in the Local Exchange Routing Guide (LERG), the authoritative database of telecommunications numbering resources managed by iconectiv that is used for call routing across North American networks).
Interconnection agreements: Signed contracts with carriers for PSTN connectivity, including Session Initiation Protocol (SIP) trunking agreements
Tariffed service orders: Orders for tariffed interconnection services from incumbent carriers
Network diagrams: Technical architecture showing connection points to the PSTN
Letters of intent: Commitments from carriers to provide interconnection within the 60-day window
Existing service evidence: For established providers, proof of current PSTN-connected service delivery
You can establish facilities readiness through two primary methods:
Carrier partnership model: Present both an agreement between your VoIP provider and its carrier partner, plus an interconnection agreement between that carrier and the relevant Local Exchange Carrier (LEC) – a telephone company authorized to provide local telephone service in a specific geographic area, including incumbent LECs (ILECs) like regional Bell operating companies and competitive LECs (CLECs)
Direct interconnection model: Provide proof of PSTN interconnection via a tariffed offering or commercial arrangement, such as a TDM-to-IP (Time Division Multiplexing to Internet Protocol – a connection method that bridges traditional circuit-switched telephone networks with modern packet-switched IP networks) or VoIP interconnection agreement
The FCC accepts various forms of evidence, recognizing that interconnection arrangements vary significantly across markets and technologies.
How to obtain an Operating Company Number (OCN) for VoIP services
You must request numbers under your own unique Operating Company Number (OCN). This identifier must be associated with the NECA Company Code Category Type of "IPES" (Internet Protocol Enabled Services) – a designation that distinguishes VoIP providers from traditional carriers in numbering databases.
Type of service (select "IPES" for VoIP providers)
Contact information for regulatory matters
Pay the application fee (typically $550-$675 as of 2024)
Receive your four-digit OCN (processing typically takes 2-4 weeks)
Ensure your OCN is properly registered in industry databases before applying for FCC numbering authorization
The OCN serves multiple purposes beyond numbering administration, often functioning as the Service Provider ID (SPID) in various industry systems. Ensure your OCN registration accurately reflects your corporate structure and operational scope.
Common OCN registration mistakes to avoid:
Selecting wrong company code category (must be "IPES" for VoIP, not traditional carrier categories)
Mismatched legal entity names between OCN registration and FCC application
Incomplete contact information preventing industry communications
Failing to update OCN records when corporate structure changes
Not verifying OCN appears correctly in LERG and other industry databases before FCC application
Required certifications and disclosures
The application requires several critical certifications that establish your legitimacy and capacity:
Compliance certification: Certify compliance with all applicable FCC obligations:
Universal Service Fund (USF) contributions: Providers must contribute to federal universal service programs based on interstate and international revenues. Registration and reporting occurs through USAC Form 499
Telecommunications Relay Service (TRS) support: Contributions supporting telecommunications relay services for individuals with hearing or speech disabilities
911 service provision: Compliance with Enhanced 911 (E911) requirements including delivery of callback number and location information to Public Safety Answering Points (PSAPs)
Local Number Portability (LNP) administration: Participation in number portability systems allowing customers to retain their phone numbers when changing providers
This certification carries significant weight – non-compliance results in substantial forfeitures, as demonstrated by the PayG, LLC case where underpayment of $404,416.28 over four years led to a proposed forfeiture of $1,460,085.
Verification before certifying:
File FCC Form 499 with USAC and obtain a 499 ID confirming USF registration
Review all FCC rules applicable to interconnected VoIP providers (47 CFR Parts 9, 52, 54, 64)
Implement E911 service capability meeting FCC location accuracy standards
Register with the Number Portability Administration Center (NPAC) for LNP participation
Consult with telecommunications counsel to ensure comprehensive compliance
Capacity certification: Certify that you possess the requisite technical, managerial, and financial capacity to provide service. This broad requirement encompasses everything from network infrastructure to customer support capabilities.
Specific capacity requirements and documentation:
Technical capacity:
Network infrastructure diagrams showing redundancy and scalability
Evidence of PSTN interconnection arrangements
Description of network monitoring and management systems
Disaster recovery and business continuity plans
Managerial capacity:
Organizational chart with key personnel qualifications
Financial statements demonstrating sufficient capital reserves
Business plan showing sustainable operations
Evidence of insurance coverage for telecommunications operations
Ability to meet ongoing regulatory payment obligations
Foreign ownership disclosure: The FCC requires disclosure of foreign ownership information, with applications showing 10% or greater foreign ownership generally referred to Executive Branch agencies for national security review. This requirement reflects heightened concerns about foreign influence over critical communications infrastructure.
National security review timeline: When applications are referred for national security review:
Initial referral: Occurs within 15 days of application acceptance
Standard review: Executive Branch agencies typically have 120 days to complete review
Extended review: In complex cases, reviews can extend to 180 days or longer
During review: Applications are held in pending status; FCC cannot grant authorization until clearance received
Possible outcomes: Approval, approval with conditions (such as security arrangements or limitations on access to customer data), or denial recommendation
Robocall mitigation: Make specific certifications regarding your robocall mitigation practices, demonstrating commitment to preventing illegal robocalling activities.
Specific robocall mitigation requirements:
Robocall Mitigation Database registration: All applicants must file a certification in the FCC Robocall Mitigation Database demonstrating their robocall mitigation efforts
Full implementation: IP portions of network authenticate calls using STIR/SHAKEN protocols
Partial implementation with plan: Non-IP network portions with detailed plan for authentication or network upgrade
Exemption basis: If claiming exemption (e.g., small provider), must provide supporting justification
Robocall mitigation plan details: Must describe specific reasonable steps taken to prevent originating or transmitting illegal robocall traffic, including:
Know-your-customer practices for downstream providers
Network monitoring for unusual calling patterns
Complaint response procedures
Procedures for blocking or ceasing transmission of suspicious traffic
Accuracy declaration: Include a signed declaration that submitted information is true and accurate, creating liability for false statements under 47 U.S.C. § 502.
Step-by-Step: How to Apply for FCC VoIP Numbering Authorization
Step 1: Filing your VoIP numbering application via ECFS
The Commission established a streamlined mechanism within its Electronic Comment Filing System (ECFS) specifically for VoIP numbering authorization applications. The filing process follows this path:
Accepted formats: PDF, Microsoft Word (.doc, .docx), text files (.txt)
File size limits: Individual files up to 25 MB; total submission up to 100 MB
Naming convention: Use descriptive filenames (e.g., "CompanyName_Interconnection_Agreement.pdf")
Confidential materials: Clearly mark confidential sections; password-protect if highly sensitive
The confirmation number links your application and payment – record it immediately upon submission.
Step 2: Paying the FCC VoIP numbering authorization fee
The filing fee of $1,560 (updated from the previous $1,485 fee) must be paid through the Commission Registration System (CORES). This separate payment system requires careful attention to ensure proper crediting:
Input the ECFS confirmation number in the "FCC Code 2" field
Complete the payment process and retain all receipts
Accepted payment methods:
Credit card (Visa, MasterCard, American Express, Discover)
Electronic Funds Transfer (EFT) from U.S. bank accounts
Wire transfer for large payments
Check or money order (results in longer processing times)
Troubleshooting payment issues:
Verify ECFS confirmation number is entered exactly as provided (including any dashes or letters)
Confirm payment code "CDY" is selected (not other fee types)
Allow 24-48 hours for payment to be credited to your application
Contact the FCC Financial Operations office at 1-877-480-3201 if payment not reflected after 3 business days
Keep CORES receipt confirmation number for all payment inquiries
Payment issues cause the most common application delays. Verify that your payment properly links to your application before proceeding.
Step 3: submitting courtesy and confidential copies
Beyond the formal ECFS filing, email a courtesy copy of the complete application package to DAA@fcc.gov. This parallel submission helps Commission staff process applications efficiently.
For applications containing highly confidential information:
Password-protect sensitive documents before attachment
Send the password in a separate email to maintain security
Clearly mark confidential sections in both the ECFS filing and courtesy copy
Standard business information (interconnection agreements, corporate structure, compliance certifications) typically does not require confidential treatment.
Understanding the FCC review process and public notice period
The Wireline Competition Bureau reviews each application for procedural compliance before accepting it for filing. Once accepted, the Bureau issues an "Accepted-For-Filing Public Notice" that opens a public comment period – typically 15 days.
Who can comment and valid objections: During the public comment period:
Parties who may file comments:
Competing telecommunications providers
Industry associations and consumer advocacy groups
State public utility commissions
Any member of the public
Types of valid objections:
Evidence of applicant's failure to meet eligibility requirements
Demonstrated non-compliance with FCC rules or regulations
Documented history of regulatory violations or consumer harm
Material misrepresentations in the application
National security concerns related to foreign ownership
Technical insufficiency in proposed robocall mitigation measures
The "deemed granted" rule provides certainty for compliant applications: on the 31st day after the Public Notice release, your application automatically becomes effective unless the Bureau notifies you otherwise. The Bureau may delay or deny applications for several reasons:
Failure to respond to FCC information requests
Public interest concerns raised in filed comments
Incomplete applications or missing certifications
Unresolved compliance issues
If application is delayed or denied:
Delay scenario:
FCC requests additional information: Respond within the specified timeframe (typically 10-30 days) with complete answers
Comments raise concerns: File a response addressing the issues raised, with supporting evidence
Payment or procedural issues: Correct deficiencies and notify the Bureau in writing
Timeline extension: Deemed granted date is extended by the length of time needed to resolve issues
Denial scenario:
Formal denial order: Bureau issues written order explaining grounds for denial
Application for review: File Application for Review with the full Commission within 30 days of denial order under 47 CFR § 1.115
Appeals process: If Commission denies review, applicant may seek judicial review in U.S. Court of Appeals within 60 days
Reapplication: Address deficiencies cited in denial order and file new application (requires new filing fee)
Section 52.15(g)(3) of the Commission's rules governs this entire process, establishing both the procedures and the substantive requirements for authorization.
After Authorization: VoIP Provider Compliance Requirements
Required 30-day state notification before requesting numbers
After receiving FCC authorization, send notice to the public utility commission of each state where you intend to request numbering resources. Transmit this notice at least 30 days before requesting any numbers from NANPA or the Pooling Administrator.
The Industry Numbering Committee (INC) created a template for this notification, available on the ATIS website at https://www.atis.org/. When requesting numbers, providers must furnish both evidence of FCC authorization and proof that the state commission received the required 30-day notice.
State commission contacts: A comprehensive list of state public utility commissions is available through:
Certified mail: Return receipt showing delivery to state commission
Email with read receipt: Electronic delivery confirmation
State commission acknowledgment: Written or email confirmation from commission staff
Courier delivery confirmation: Signed receipt from state commission mail room
Retain all proof of delivery for presentation to NANPA/PA when requesting numbers
How to request telephone numbers from NANPA and the Pooling Administrator
With authorization secured and states notified, request numbering resources from the appropriate administrators. Each request requires documentation of both federal authorization and state notification compliance. The administrators will verify your OCN matches their authorization records before releasing any numbering resources.
Contacting NANPA and the Pooling Administrator:
NANPA (North American Numbering Plan Administrator):
Submit request via NASC portal (for NPA-NXX codes) or PA portal (for thousands-blocks)
Specify geographic area (rate center) and quantity needed
Provide utilization justification based on customer forecast
Allocation limits and utilization requirements:
Initial allocation: New providers typically receive thousands-blocks (1,000 numbers) initially
Growth allocation: Additional blocks allocated based on demonstrated utilization
Utilization threshold: Carriers must meet utilization thresholds before receiving additional numbers (specific thresholds vary by state and administrator policy)
Code opening: Full NPA-NXX codes (10,000 numbers) reserved for providers demonstrating high utilization and capacity
Processing timeline:
Simple thousands-block requests: 5-10 business days
NPA-NXX code requests: 10-15 business days
Requests requiring additional documentation: 15-30 business days
Ongoing VoIP numbering compliance obligations and FCC enforcement
Direct numbering authorization creates permanent compliance obligations:
Portability requirements: Honor all port-in and port-out requests without unreasonable delay. The Telecommunications Act of 1996 established number portability as a fundamental consumer right – you cannot impede customers from keeping their numbers when changing services.
Simple ports: Must be completed within one business day for wireline-to-wireline or intermodal (including VoIP) ports when the request is submitted by 1 PM local time
Complex ports: Must be completed within four business days for non-simple ports involving multiple lines or technical complexities
Port-out responsibilities: Cannot unreasonably delay or deny valid port-out requests; must process all legitimate customer requests
Port-in responsibilities: Must accept all valid port-in requests and complete porting within regulatory timeframes
LNP administration costs: Participation in number portability requires:
NPAC registration fees: Initial registration typically $1,000-$3,000
Monthly service fees: Ongoing fees based on number of ported numbers ($0.06-$0.12 per ported number per month)
Query costs: Per-query charges for LNP database lookups (typically $0.003-$0.005 per query)
Service order charges: Per-transaction fees for porting activities
General compliance: All applicable FCC numbering rules and industry guidelines apply. This includes accurate reporting, efficient number utilization, and participation in number pooling where required.
Specific reporting requirements and deadlines:
FCC Form 502 (NRUF): Numbering Resource Utilization/Forecast report due February 1 and August 1 each year, reporting numbers as of the prior December 31 or June 30
FCC Form 499-Q: Quarterly Universal Service Fund contribution report due quarterly within 30 days of quarter end
FCC Form 499-A: Annual telecommunications reporting worksheet due April 1 each year
Robocall Mitigation Database: Update filings within 10 business days of material changes to certification status, contact information, or robocall mitigation practices
STIR/SHAKEN compliance updates: Report implementation status changes as they occur
Efficient utilization thresholds: The FCC requires carriers to meet minimum utilization standards before receiving additional numbering resources. While specific thresholds have evolved through various FCC orders, generally maintain:
60% utilization of assigned numbers as a benchmark for requesting additional resources in many contexts
Contamination reporting: Must report blocks of numbers where more than 50% are unusable due to number contamination (negative reputation)
Forecasting accuracy: Submit accurate forecasts of numbering needs in NRUF reports; significant discrepancies may trigger scrutiny
Enforcement exposure: Authorized providers face the FCC's full enforcement and forfeiture authority. Non-compliance triggers penalties, authorization revocation, and reclamation of unassigned numbers. The Commission demonstrated willingness to pursue significant forfeitures in the PayG, LLC case, proposing $1,460,085 in penalties for regulatory payment violations.
Common violations and typical penalties:
Violation Type
Typical Penalty Range
Additional Consequences
Late or non-filing of NRUF reports
$2,000-$10,000 per report
Number allocation suspension
USF contribution underpayment
3x underpaid amount
Interest, audit costs
E911 compliance failures
$25,000-$100,000 per incident
Potential service shutdown
Number portability violations
$8,000-$40,000 per day
LNP suspension, consumer refunds
Robocall mitigation deficiencies
$10,000-$200,000
Removal from Robocall Mitigation Database, traffic blocking
False application statements
$100,000-$500,000
Authorization revocation, criminal referral
FCC audit procedures: The FCC may audit authorized providers through:
Random audits: Selected providers undergo periodic compliance reviews
Complaint-triggered investigations: Consumer or competitor complaints initiate review
Data-driven enforcement: Anomalous NRUF data or usage patterns trigger inquiries
Warning letters: Initial non-compliance often results in letter of inquiry requiring response within 30 days
Consent decrements: Many violations resolved through negotiated consent decrees involving penalties and compliance plans
Getting Started with FCC Direct Numbering Authorization
Direct numbering authorization represents both an opportunity and a responsibility for interconnected VoIP providers. The path requires demonstrating technical readiness, administrative competence, and ongoing compliance commitment.
The FCC's VoIP numbering framework achieves dual objectives: fostering a more competitive and innovative VoIP marketplace by eliminating dependence on carrier intermediaries, while strengthening oversight to protect numbering resource integrity and shield consumers from bad actors. Successfully navigate this process to gain operational independence and market flexibility – advantages that increasingly define success in modern communications markets.
Next steps and timeline estimate:
Pre-application phase (4-8 weeks):
Obtain OCN from NECA (2-4 weeks)
Secure interconnection agreements (2-6 weeks)
Register with Robocall Mitigation Database (1 week)
Prepare STIR/SHAKEN implementation plan (1-2 weeks)
Application phase (2-8 weeks):
Prepare and file ECFS application (1 week)
Pay filing fee via CORES (immediate)
Public notice and comment period (15 days minimum)
Deemed granted rule activation (31 days after public notice if no issues)
Foreign ownership review (add 120-180 days if applicable)
Post-authorization phase (5-7 weeks):
Send state notifications (immediate, but must wait 30 days before number requests)
Register with NANPA/PA (1 week)
Request and receive initial numbering resources (1-2 weeks)
Activate numbers in LERG (1-2 weeks)
Total estimated timeline: 3-6 months from start to active numbers (6-12 months if foreign ownership review required)
FCC direct numbering authorization for interconnected VoIP providers
Interconnected Voice over Internet Protocol (VoIP) providers can obtain telephone numbers directly from numbering administrators without relying on carrier partners. The Federal Communications Commission (FCC) established this authorization process in 2015 and strengthened it through subsequent rulemaking, fundamentally transforming how VoIP services operate within the North American Numbering Plan.
Who should use this guide: Compliance officers preparing regulatory applications, legal counsel evaluating operational independence strategies, and operational managers eliminating carrier intermediaries. This guide addresses providers scaling services across multiple states, those facing carrier relationship challenges, and companies needing direct control over numbering resources for technical or business reasons.
You'll learn the complete framework for securing and maintaining FCC VoIP numbering authorization – from understanding the regulatory foundation to navigating the application process and post-approval compliance responsibilities.
Understanding FCC VoIP Numbering Authorization Requirements
The FCC's jurisdictional role in telephone number allocation
The FCC maintains full jurisdiction over the U.S. telephone numbering system, managing nearly 1 billion telephone numbers with two primary objectives: promoting competitive markets and ensuring efficient resource utilization. This authority includes establishing rules for who can access numbering resources and under what conditions.
Penalties for non-compliance: Violations of FCC numbering rules result in substantial forfeitures. The PayG, LLC enforcement action demonstrates the consequences: underpayment of regulatory fees totaling $404,416.28 over four years led to a proposed forfeiture of $1,460,085 – more than three times the underpaid amount. The FCC can also revoke numbering authorizations and reclaim assigned numbers from non-compliant providers.
The Commission's approach to VoIP provider access reflects a deliberate policy shift toward market liberalization. Rather than maintaining traditional gatekeepers, the FCC recognized that direct access would foster innovation, reduce operational inefficiencies, and accelerate the deployment of advanced communication services.
The 2015 FCC Report and Order: How VoIP providers gained direct number access
On June 22, 2015, the FCC released its landmark Report and Order (FCC 15-70) establishing the framework for interconnected VoIP providers to obtain numbers directly from the North American Numbering Plan Administrator (NANPA) – the entity responsible for administering and assigning telephone numbers under the North American Numbering Plan – and the Pooling Administrator (PA) – which manages the allocation of blocks of 1,000 numbers (thousands-blocks) to carriers in specific rate centers. The Commission determined that the benefits of direct access – improved competition, deployment of advanced services, and elimination of inefficiencies – outweighed what it characterized as "perceived risks."
Addressing perceived risks: The FCC's 2015 Order acknowledged industry concerns that direct VoIP access could lead to number exhaustion, fraud, or reduced accountability. The Commission concluded these risks were manageable through: (1) applying the same stringent eligibility criteria used for traditional carriers, (2) requiring comprehensive compliance certifications, (3) maintaining oversight through ongoing reporting obligations, and (4) retaining full enforcement authority including the ability to revoke authorization and reclaim numbers. Subsequent implementation has validated this assessment, with no significant increase in numbering-related fraud or resource exhaustion attributable to VoIP providers.
The rules specifically address 10-digit NANP numbers, not IP addresses or other identifiers. The FCC rejected arguments that it must first classify interconnected VoIP as a telecommunications service before granting direct access, demonstrating commitment to technology-neutral regulation.
TRACED Act requirements and robocall mitigation for VoIP providers
Congress reinforced the importance of numbering oversight through the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence (TRACED) Act, which directed the FCC to examine ways to reduce access to telephone numbers by potential perpetrators of illegal robocalls.
The Commission's September 2023 updates (FCC 23-75) directly respond to this Congressional mandate. These enhanced rules safeguard U.S. numbering resources, protect consumers and national security interests, and reduce opportunities for regulatory arbitrage by bad actors who might exploit gaps in oversight.
Key changes in September 2023 (FCC 23-75): The updated rules introduced several critical requirements:
VoIP Provider Eligibility Requirements for Direct Numbering
Who qualifies for FCC direct numbering authorization
The direct numbering authorization process is available exclusively to interconnected Voice over Internet Protocol (VoIP) providers. This classification matters – you must offer real-time, two-way voice communications that connect to and receive calls from the public switched telephone network (PSTN).
Definition of interconnected VoIP: Under 47 CFR § 9.3, an interconnected VoIP service must:
Examples of services that qualify vs. don't qualify:
Qualify:
Do NOT qualify:
Obtaining direct access is a voluntary business decision. You can continue operating through carrier partnerships if you prefer that model. The authorization provides an alternative path for those seeking greater operational independence.
Meeting the facilities readiness requirement for VoIP numbering
You must demonstrate facilities in place – or will have them in place – to provide service within 60 days of the numbering resources activation date (also known as the LERG effective date – the date when telephone number assignments become active in the Local Exchange Routing Guide (LERG), the authoritative database of telecommunications numbering resources managed by iconectiv that is used for call routing across North American networks).
Documenting facilities readiness: Acceptable documentation includes:
You can establish facilities readiness through two primary methods:
Carrier partnership model: Present both an agreement between your VoIP provider and its carrier partner, plus an interconnection agreement between that carrier and the relevant Local Exchange Carrier (LEC) – a telephone company authorized to provide local telephone service in a specific geographic area, including incumbent LECs (ILECs) like regional Bell operating companies and competitive LECs (CLECs)
Direct interconnection model: Provide proof of PSTN interconnection via a tariffed offering or commercial arrangement, such as a TDM-to-IP (Time Division Multiplexing to Internet Protocol – a connection method that bridges traditional circuit-switched telephone networks with modern packet-switched IP networks) or VoIP interconnection agreement
The FCC accepts various forms of evidence, recognizing that interconnection arrangements vary significantly across markets and technologies.
How to obtain an Operating Company Number (OCN) for VoIP services
You must request numbers under your own unique Operating Company Number (OCN). This identifier must be associated with the NECA Company Code Category Type of "IPES" (Internet Protocol Enabled Services) – a designation that distinguishes VoIP providers from traditional carriers in numbering databases.
How to obtain an OCN: Operating Company Numbers are issued by the National Exchange Carrier Association (NECA). The process involves:
The OCN serves multiple purposes beyond numbering administration, often functioning as the Service Provider ID (SPID) in various industry systems. Ensure your OCN registration accurately reflects your corporate structure and operational scope.
Common OCN registration mistakes to avoid:
Required certifications and disclosures
The application requires several critical certifications that establish your legitimacy and capacity:
Compliance certification: Certify compliance with all applicable FCC obligations:
This certification carries significant weight – non-compliance results in substantial forfeitures, as demonstrated by the PayG, LLC case where underpayment of $404,416.28 over four years led to a proposed forfeiture of $1,460,085.
Verification before certifying:
Capacity certification: Certify that you possess the requisite technical, managerial, and financial capacity to provide service. This broad requirement encompasses everything from network infrastructure to customer support capabilities.
Specific capacity requirements and documentation:
Technical capacity:
Managerial capacity:
Financial capacity:
Foreign ownership disclosure: The FCC requires disclosure of foreign ownership information, with applications showing 10% or greater foreign ownership generally referred to Executive Branch agencies for national security review. This requirement reflects heightened concerns about foreign influence over critical communications infrastructure.
National security review timeline: When applications are referred for national security review:
Robocall mitigation: Make specific certifications regarding your robocall mitigation practices, demonstrating commitment to preventing illegal robocalling activities.
Specific robocall mitigation requirements:
Accuracy declaration: Include a signed declaration that submitted information is true and accurate, creating liability for false statements under 47 U.S.C. § 502.
Step-by-Step: How to Apply for FCC VoIP Numbering Authorization
Step 1: Filing your VoIP numbering application via ECFS
The Commission established a streamlined mechanism within its Electronic Comment Filing System (ECFS) specifically for VoIP numbering authorization applications. The filing process follows this path:
Required supporting documents for upload:
File format requirements:
The confirmation number links your application and payment – record it immediately upon submission.
Step 2: Paying the FCC VoIP numbering authorization fee
The filing fee of $1,560 (updated from the previous $1,485 fee) must be paid through the Commission Registration System (CORES). This separate payment system requires careful attention to ensure proper crediting:
Accepted payment methods:
Troubleshooting payment issues:
Payment issues cause the most common application delays. Verify that your payment properly links to your application before proceeding.
Step 3: submitting courtesy and confidential copies
Beyond the formal ECFS filing, email a courtesy copy of the complete application package to DAA@fcc.gov. This parallel submission helps Commission staff process applications efficiently.
For applications containing highly confidential information:
What qualifies as "highly confidential":
Standard business information (interconnection agreements, corporate structure, compliance certifications) typically does not require confidential treatment.
Understanding the FCC review process and public notice period
The Wireline Competition Bureau reviews each application for procedural compliance before accepting it for filing. Once accepted, the Bureau issues an "Accepted-For-Filing Public Notice" that opens a public comment period – typically 15 days.
Who can comment and valid objections: During the public comment period:
Parties who may file comments:
Types of valid objections:
The "deemed granted" rule provides certainty for compliant applications: on the 31st day after the Public Notice release, your application automatically becomes effective unless the Bureau notifies you otherwise. The Bureau may delay or deny applications for several reasons:
If application is delayed or denied:
Delay scenario:
Denial scenario:
Section 52.15(g)(3) of the Commission's rules governs this entire process, establishing both the procedures and the substantive requirements for authorization.
After Authorization: VoIP Provider Compliance Requirements
Required 30-day state notification before requesting numbers
After receiving FCC authorization, send notice to the public utility commission of each state where you intend to request numbering resources. Transmit this notice at least 30 days before requesting any numbers from NANPA or the Pooling Administrator.
The Industry Numbering Committee (INC) created a template for this notification, available on the ATIS website at https://www.atis.org/. When requesting numbers, providers must furnish both evidence of FCC authorization and proof that the state commission received the required 30-day notice.
State commission contacts: A comprehensive list of state public utility commissions is available through:
Proof of receipt requirements:
How to request telephone numbers from NANPA and the Pooling Administrator
With authorization secured and states notified, request numbering resources from the appropriate administrators. Each request requires documentation of both federal authorization and state notification compliance. The administrators will verify your OCN matches their authorization records before releasing any numbering resources.
Contacting NANPA and the Pooling Administrator:
NANPA (North American Numbering Plan Administrator):
Pooling Administrator:
Number request process and allocation limits:
Initial request preparation:
Request submission:
Allocation limits and utilization requirements:
Processing timeline:
Ongoing VoIP numbering compliance obligations and FCC enforcement
Direct numbering authorization creates permanent compliance obligations:
Portability requirements: Honor all port-in and port-out requests without unreasonable delay. The Telecommunications Act of 1996 established number portability as a fundamental consumer right – you cannot impede customers from keeping their numbers when changing services.
Porting timeframes: Under 47 CFR § 52.35:
LNP administration costs: Participation in number portability requires:
General compliance: All applicable FCC numbering rules and industry guidelines apply. This includes accurate reporting, efficient number utilization, and participation in number pooling where required.
Specific reporting requirements and deadlines:
Efficient utilization thresholds: The FCC requires carriers to meet minimum utilization standards before receiving additional numbering resources. While specific thresholds have evolved through various FCC orders, generally maintain:
Enforcement exposure: Authorized providers face the FCC's full enforcement and forfeiture authority. Non-compliance triggers penalties, authorization revocation, and reclamation of unassigned numbers. The Commission demonstrated willingness to pursue significant forfeitures in the PayG, LLC case, proposing $1,460,085 in penalties for regulatory payment violations.
Common violations and typical penalties:
FCC audit procedures: The FCC may audit authorized providers through:
Getting Started with FCC Direct Numbering Authorization
Direct numbering authorization represents both an opportunity and a responsibility for interconnected VoIP providers. The path requires demonstrating technical readiness, administrative competence, and ongoing compliance commitment.
The FCC's VoIP numbering framework achieves dual objectives: fostering a more competitive and innovative VoIP marketplace by eliminating dependence on carrier intermediaries, while strengthening oversight to protect numbering resource integrity and shield consumers from bad actors. Successfully navigate this process to gain operational independence and market flexibility – advantages that increasingly define success in modern communications markets.
Next steps and timeline estimate:
Pre-application phase (4-8 weeks):
Application phase (2-8 weeks):
Post-authorization phase (5-7 weeks):
Total estimated timeline: 3-6 months from start to active numbers (6-12 months if foreign ownership review required)
Key resources: