A comprehensive guide to FCC direct numbering authorization for interconnected VoIP providers
Interconnected Voice over Internet Protocol (VoIP) providers seeking independence from carrier partners now have a clear path to obtain telephone numbers directly from numbering administrators. This authorization process, established by the Federal Communications Commission (FCC) in 2015 and strengthened through subsequent rulemaking, fundamentally transforms how VoIP services can operate within the North American Numbering Plan.
This guide provides compliance officers, legal counsel, and operational managers with the complete framework for securing and maintaining direct numbering authorization – from understanding the regulatory foundation to navigating post-approval responsibilities.
The regulatory framework and its purpose
The FCC's jurisdictional role
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 extends to establishing rules for who can access numbering resources and under what conditions.
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 Report and Order: opening the door to direct 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) and the Pooling Administrator (PA). 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."
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 its commitment to technology-neutral regulation.
The TRACED Act and modern robocall mitigation
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 to the authorization process directly respond to this Congressional mandate. These enhanced rules aim to 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.
Eligibility and pre-application requirements
Who can apply
The direct numbering authorization process is available exclusively to interconnected Voice over Internet Protocol (VoIP) providers. This classification matters – the provider must offer real-time, two-way voice communications that connect to and receive calls from the public switched telephone network (PSTN).
Obtaining direct access remains a voluntary business decision. Providers can continue operating through carrier partnerships if they prefer that model. The authorization simply provides an alternative path for those seeking greater operational independence.
The "facilities readiness" requirement
Applicants must demonstrate they have 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). This requirement ensures providers can actually serve customers before consuming limited numbering resources.
Providers can establish facilities readiness through two primary methods:
Carrier partnership model: Present both an agreement between the VoIP provider and its carrier partner, plus an interconnection agreement between that carrier and the relevant Local Exchange Carrier (LEC)
Direct interconnection model: Provide proof of PSTN interconnection via a tariffed offering or commercial arrangement, such as a TDM-to-IP or VoIP interconnection agreement
The FCC accepts various forms of evidence, recognizing that interconnection arrangements vary significantly across markets and technologies.
Obtaining an Operating Company Number (OCN)
Every provider must request numbers under its 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.
The OCN serves multiple purposes beyond numbering administration, often functioning as the Service Provider ID (SPID) in various industry systems. Providers should ensure their OCN registration accurately reflects their corporate structure and operational scope.
Required certifications and disclosures
The application demands several critical certifications that establish the provider's legitimacy and capacity:
Compliance certification: Applicants must certify compliance with all applicable FCC obligations, including Universal Service Fund (USF) contributions, Telecommunications Relay Service (TRS) support, 911 service provision, and Local Number Portability (LNP) administration. This certification carries significant weight – non-compliance can result 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.
Capacity certification: Providers must certify they possess the requisite technical, managerial, and financial capacity to provide service. This broad requirement encompasses everything from network infrastructure to customer support capabilities.
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.
Robocall mitigation: Applicants must make specific certifications regarding their robocall mitigation practices, demonstrating commitment to preventing illegal robocalling activities.
Accuracy declaration: All applications must include a signed declaration that submitted information is true and accurate, creating potential liability for false statements.
The FCC application process: a step-by-step guide
Step 1: filing the 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:
Access ECFS at apps.fcc.gov/ecfs
Click "Non-Docketed Filing"
From the "FCC Inbox" dropdown menu, select "INBOX-52.15 | VoIP Numbering Authorization Application (Fee Required)"
Complete all required fields and upload supporting documentation
Submit the application and note the confirmation number
The confirmation number serves as the critical link between your application and payment – record it immediately upon submission.
Step 2: remitting the application fee
The filing fee of $1,485 must be paid through the Commission Registration System (CORES). This separate payment system requires careful attention to ensure proper crediting:
Access CORES and navigate to the fee payment section
Enter payment code "CDY" for VoIP Filing
Input the ECFS confirmation number in the "FCC Code 2" field
Complete the payment process and retain all receipts
Payment issues represent one of the most common causes of 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, applicants must 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
The FCC review 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.
The "deemed granted" rule provides certainty for compliant applications: on the 31st day after the Public Notice release, the application automatically becomes effective unless the Bureau notifies the applicant 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
Section 52.15(g)(3) of the Commission's rules governs this entire process, establishing both the procedures and the substantive requirements for authorization.
Post-authorization responsibilities and ongoing compliance
30-day state notification
After receiving FCC authorization, providers face an immediate obligation: sending notice to the public utility commission of each state where they intend to request numbering resources. This notice must be transmitted 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. When requesting numbers, providers must furnish both evidence of FCC authorization and proof that the state commission received the required 30-day notice.
Requesting numbers from administrators
With authorization secured and states notified, providers can request numbering resources from the appropriate administrators. Each request requires documentation of both federal authorization and state notification compliance. The administrators will verify the provider's OCN matches their authorization records before releasing any numbering resources.
Ongoing obligations and enforcement
Direct numbering authorization creates permanent compliance obligations:
Portability requirements: Providers maintain an affirmative obligation to honor all port-in and port-out requests without unreasonable delay. The Telecommunications Act of 1996 established number portability as a fundamental consumer right – providers cannot impede customers from keeping their numbers when changing services.
General compliance: All applicable FCC numbering rules and industry guidelines continue to apply. This includes accurate reporting, efficient number utilization, and participation in number pooling where required.
Enforcement exposure: Authorized providers face the FCC's full enforcement and forfeiture authority. Non-compliance can trigger penalties, authorization revocation, and reclamation of unassigned numbers. The Commission demonstrated its willingness to pursue significant forfeitures in the PayG, LLC case, proposing $1,460,085 in penalties for regulatory payment violations.
Conclusion
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 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. Providers who successfully navigate this process gain operational independence and market flexibility – advantages that increasingly define success in modern communications markets.
A comprehensive guide to FCC direct numbering authorization for interconnected VoIP providers
Interconnected Voice over Internet Protocol (VoIP) providers seeking independence from carrier partners now have a clear path to obtain telephone numbers directly from numbering administrators. This authorization process, established by the Federal Communications Commission (FCC) in 2015 and strengthened through subsequent rulemaking, fundamentally transforms how VoIP services can operate within the North American Numbering Plan.
This guide provides compliance officers, legal counsel, and operational managers with the complete framework for securing and maintaining direct numbering authorization – from understanding the regulatory foundation to navigating post-approval responsibilities.
The regulatory framework and its purpose
The FCC's jurisdictional role
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 extends to establishing rules for who can access numbering resources and under what conditions.
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 Report and Order: opening the door to direct 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) and the Pooling Administrator (PA). 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."
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 its commitment to technology-neutral regulation.
The TRACED Act and modern robocall mitigation
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 to the authorization process directly respond to this Congressional mandate. These enhanced rules aim to 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.
Eligibility and pre-application requirements
Who can apply
The direct numbering authorization process is available exclusively to interconnected Voice over Internet Protocol (VoIP) providers. This classification matters – the provider must offer real-time, two-way voice communications that connect to and receive calls from the public switched telephone network (PSTN).
Obtaining direct access remains a voluntary business decision. Providers can continue operating through carrier partnerships if they prefer that model. The authorization simply provides an alternative path for those seeking greater operational independence.
The "facilities readiness" requirement
Applicants must demonstrate they have 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). This requirement ensures providers can actually serve customers before consuming limited numbering resources.
Providers can establish facilities readiness through two primary methods:
Carrier partnership model: Present both an agreement between the VoIP provider and its carrier partner, plus an interconnection agreement between that carrier and the relevant Local Exchange Carrier (LEC)
Direct interconnection model: Provide proof of PSTN interconnection via a tariffed offering or commercial arrangement, such as a TDM-to-IP or VoIP interconnection agreement
The FCC accepts various forms of evidence, recognizing that interconnection arrangements vary significantly across markets and technologies.
Obtaining an Operating Company Number (OCN)
Every provider must request numbers under its 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.
The OCN serves multiple purposes beyond numbering administration, often functioning as the Service Provider ID (SPID) in various industry systems. Providers should ensure their OCN registration accurately reflects their corporate structure and operational scope.
Required certifications and disclosures
The application demands several critical certifications that establish the provider's legitimacy and capacity:
Compliance certification: Applicants must certify compliance with all applicable FCC obligations, including Universal Service Fund (USF) contributions, Telecommunications Relay Service (TRS) support, 911 service provision, and Local Number Portability (LNP) administration. This certification carries significant weight – non-compliance can result 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.
Capacity certification: Providers must certify they possess the requisite technical, managerial, and financial capacity to provide service. This broad requirement encompasses everything from network infrastructure to customer support capabilities.
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.
Robocall mitigation: Applicants must make specific certifications regarding their robocall mitigation practices, demonstrating commitment to preventing illegal robocalling activities.
Accuracy declaration: All applications must include a signed declaration that submitted information is true and accurate, creating potential liability for false statements.
The FCC application process: a step-by-step guide
Step 1: filing the 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:
The confirmation number serves as the critical link between your application and payment – record it immediately upon submission.
Step 2: remitting the application fee
The filing fee of $1,485 must be paid through the Commission Registration System (CORES). This separate payment system requires careful attention to ensure proper crediting:
Payment issues represent one of the most common causes of 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, applicants must 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:
The FCC review 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.
The "deemed granted" rule provides certainty for compliant applications: on the 31st day after the Public Notice release, the application automatically becomes effective unless the Bureau notifies the applicant otherwise. The Bureau may delay or deny applications for several reasons:
Section 52.15(g)(3) of the Commission's rules governs this entire process, establishing both the procedures and the substantive requirements for authorization.
Post-authorization responsibilities and ongoing compliance
30-day state notification
After receiving FCC authorization, providers face an immediate obligation: sending notice to the public utility commission of each state where they intend to request numbering resources. This notice must be transmitted 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. When requesting numbers, providers must furnish both evidence of FCC authorization and proof that the state commission received the required 30-day notice.
Requesting numbers from administrators
With authorization secured and states notified, providers can request numbering resources from the appropriate administrators. Each request requires documentation of both federal authorization and state notification compliance. The administrators will verify the provider's OCN matches their authorization records before releasing any numbering resources.
Ongoing obligations and enforcement
Direct numbering authorization creates permanent compliance obligations:
Portability requirements: Providers maintain an affirmative obligation to honor all port-in and port-out requests without unreasonable delay. The Telecommunications Act of 1996 established number portability as a fundamental consumer right – providers cannot impede customers from keeping their numbers when changing services.
General compliance: All applicable FCC numbering rules and industry guidelines continue to apply. This includes accurate reporting, efficient number utilization, and participation in number pooling where required.
Enforcement exposure: Authorized providers face the FCC's full enforcement and forfeiture authority. Non-compliance can trigger penalties, authorization revocation, and reclamation of unassigned numbers. The Commission demonstrated its willingness to pursue significant forfeitures in the PayG, LLC case, proposing $1,460,085 in penalties for regulatory payment violations.
Conclusion
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 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. Providers who successfully navigate this process gain operational independence and market flexibility – advantages that increasingly define success in modern communications markets.