On September 22, 2025, the FCC’s Wireline Competition Bureau issued a Public Notice reminding interconnected VoIP providers of two key regulatory obligations intended to protect consumers:
Local Number Portability (LNP): Providers must facilitate number porting without unreasonable delay or procedural barriers.
Section 214 Discontinuance Requirements: Providers must obtain FCC authorization before discontinuing, reducing, or impairing service and must notify customers and state authorities before filing for discontinuance.
Key Compliance Requirements
Local Number Portability (LNP)
Who is Covered: All interconnected VoIP providers — whether they receive numbering resources directly or through a numbering partner — must comply with the FCC’s LNP rules.
Obligations: Providers must take all steps necessary to initiate or allow port-in/port-out requests without unreasonable delay, including coordinating with numbering partners and resellers.
Porting Timelines: Numbering partners and carriers must generally complete simple port requests within one business day, and intermodal (including VoIP) porting within four business days unless otherwise requested.
Section 214 Discontinuance
FCC Authorization Required: Providers must obtain Commission approval before discontinuing, reducing, or impairing service to a community or part of a community.
Notice Requirements: Providers must (1) notify affected customers, (2) notify relevant state authorities, and (3) file a discontinuance application with the FCC.
Customer Rights: Notices must inform customers of their right to object and alert the Commission if they cannot obtain reasonable substitute service.
Automatic Grant: Applications may be automatically granted 31 days after public notice unless the FCC intervenes.
Enforcement Risk: Providers that fail to comply with these rules may be subject to penalties, including in bankruptcy scenarios.
Immediate Steps for Providers
- Audit Porting Practices: Verify processes with numbering partners and resellers to ensure compliance with LNP rules and timelines.
- Review Discontinuance Plans: Confirm notice templates, state notifications, and FCC filing procedures are current and ready for use.
- Educate Staff: Train teams on Section 214 requirements to avoid unlawful discontinuance actions.
- Document Compliance: Maintain records of porting requests, completion intervals, and customer communications to demonstrate good faith compliance.
How We Can Help
The CommLaw Group routinely counsels VoIP providers on LNP and Section 214 discontinuance obligations. Our team can assist with compliance reviews, notice preparation, and FCC discontinuance filings.
Contact:
For questions or to coordinate participation, contact Jonathan S. Marashlian at jsm@commlawgroup.com.