FCC Adopts Certification Obligations For I-VoIP Providers Who Directly Obtained NANP Numbers Before August 8, 2024; Seeks Comment On Further Numbering Reforms By March 16; Reply Comments Are Due April 13

The Federal Communications Commission (FCC or Commission) recently adopted the Third Report and Order (R&O) and Further Notice of Proposed Rulemaking (FNPRM) that significantly expands certification obligations for interconnected Voice over Internet Protocol (I-VoIP) providers holding direct access to NANP numbering resources. The final rules have been published in the Federal Register on February 17, with an effective date of March 19, 2026. However, the compliance date for the new certification filing under § 52.15(g)(3)(x)(E) has not yet been announced, pending OMB review under the Paperwork Reduction Act. We will provide an update once the FCC announces the filing deadline.

The FCC also seeks public comment on the FNPRM proposing additional measures to strengthen oversight of numbering resources and safeguard national security. Comments are due March 16, 2026, and reply comments are due April 13, 2026.

1. New Certification Requirements for Existing Authorization Holders

In March 2023, the Commission adopted rules requiring numbering authorization applicants to make additional certifications and disclosures related to robocall prevention, public safety, and national security. The requirements applied only to new applications submitted on or after August 8, 2024.

The current R&O extends the same certification and disclosure requirements to all direct access numbering authorization holders. As a result, providers that received authorization before August 8, 2024, must now submit updated filings to the FCC. The filing deadline will be additionally announced in a future Federal Register publication.

Each affected provider must certify compliance with several existing FCC rules and state laws and regulations, including:

• Applicable Laws and Regulations: Commission numbering rules in 47 CFR Chapter I, Subchapter B Part 52; the state laws, regulations, and registration requirements applicable to businesses operating in each state where the applicant seeks numbering resources; and industry guidelines and practices regarding numbering as applicable to telecommunications carriers.
• Robocall mitigation and anti-spoofing rules under 47 CFR §§ 64.1200, 64.1604, and 64.6300, et seq., and 16 CFR § 310.3(b).
• STIR/SHAKEN caller ID authentication, robocall mitigation program, and Robocall Mitigation Database filing requirements under 47 CFR §§ 64.6301–64.6305.
• Public safety obligations, including evidence of compliance with 911 and Next Generation 911 rules in Part 9 of the Commission's rules.
• CALEA obligations under 47 U.S.C. 1001 et seq.
• Access stimulation rules under 47 CFR § 51.914.
• Proof of Forms 477 and 499 filings, or a statement why the form(s) do not apply.
• Law enforcement and regulatory compliance history, affirming that neither the provider nor key personnel are under investigation for unlawful robocalling or spoofing and certifying that the applicant possesses the financial, managerial, and technical expertise to provide reliable service, with the name of applicant's key management and technical personnel, such as the Chief Operating Officer and the Chief Technology Officer, or equivalent.
• Ownership and control disclosures consistent with 47 CFR §§ 63.18(h)–(i) or a certified statement explaining why these provisions do not apply.

The Wireline Competition Bureau (Bureau) will issue additional best practices Public Notice outlining guidance on administrative filing requirements.

Providers failing to provide timely or sufficient certifications risk suspension, termination, or revocation of their numbering authorization.

The Commission also reiterated that I-VoIP providers must file ownership updates within 30 days of any change. If new ownership information raises public interest concerns, the Bureau may suspend number assignments and refer matters to national security agencies for further review.

2. Further Notice of Proposed Rulemaking: Requests for Comment

The accompanying FNPRM outlines potential next steps for number management and seeks industry input on several key questions:

1. Reclaiming Numbering Resources: The FCC requests comment on the feasibility and impacts of reclaiming numbering resources from providers whose authorizations have been revoked, terminated, or abandoned (e.g., due to bankruptcy), and how to minimize disruption to end-users.
2. Restrictions on National Security Grounds: The Commission asks whether to restrict numbering authorizations for entities on the Covered List or those previously denied or revoked section 214 authorizations based on national security concerns.
3. Use of "Covered" Equipment: The FCC seeks input on whether to (1) restrict/reevaluate numbering authorizations for I-VoIP providers relying on "covered" telecommunications equipment in their network infrastructure, (2) require certification that networks are free of such equipment, or (3) prohibit providers from serving entities using such equipment.

The proposed rule was published in the Federal Register on February 12. Comments on the FNPRM are due March 16, 2026, and reply comments are due April 13, 2026.

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