This article originally appeared in the March 2013 issue of INTERNET TELEPHONY.

Following up on the prior Regulatory Watch article, on Jan. 15, 2013, the FCC (News - Alert) released an order extending the commission’s international reporting requirements to international VoIP services connected to the public switched telephone network.

Importantly, the commission applied the requirements in this order to cover VoIP entities beyond those “interconnected VoIP” providers it has traditionally applied its requirements to. 

Instead, this order covers “international VoIP Service connected to the PSTN,” which: (1) enables real-time, two-way voice communications; (2) requires a broadband connection from the user's location; (3) requires Internet Protocol compatible customer premise equipment; and (4) permits users generally to receive calls that originate on the public switched telephone network (PSTN) or to terminate calls to the PSTN. This differs from “interconnected VoIP service” by including one-way VoIP services.

The order combines the two reports required of international carriers into a single manual. It also requires covered entities to file a Registration Form with the required reports, allows for the use of statistical sampling where actual data is not available, and sets new reporting thresholds based on service revenues. The new reporting requirements will not become effective until approved by the U.S. Office of Management and Budget under the Paperwork Reduction Act because they contain new information collection requirements. Once approved, the FCC will announce the final effective date of the requirements.

Since 2005 the FCC has applied a number of carrier-type requirements on VoIP providers. The new international reporting requirements remove another FCC distinction between unlicensed VoIP providers and traditional telecommunications providers in the U.S. The order also continues the trend toward greater regulatory scrutiny by the FCC of “one-way” VoIP providers.

William B. Wilhelm (News - Alert) is a partner and Jeffrey R. Strenkowski is counsel at the global law firm of Bingham McCutchen LLP (www.bingham.com).