As previously mentioned in a Client Advisory, the California Public Utilities Commission (CPUC) has approved a comprehensive overhaul of the state’s regulatory framework that will reshape the requirements and compliance obligations applicable to interconnected Voice over Internet Protocol (I-VoIP) providers operating in the state.
Registered Providers
Registration Status
- I-VoIP providers previously registered as “Digital Voice Services” (DVS) providers were automatically migrated to Digital Voice Fixed (DVF) status unless they filed an attestation with the CPUC seeking nomadic status by December 27, 2024
- Nomadic providers who failed to file the attestation but wish to convert to nomadic status must:
- File an advice letter voluntarily relinquishing the existing registration
- File a new nomadic I-VoIP registration
Compliance Requirements
- ALL registered providers (DVF & DVN) must:
- Report and remit California Public Purpose fees (existing requirement; applies retroactively to service start date)*
- Begin reporting/remitting CPUC User Fees (July 1, 2025)*
- Begin filing the annual Affiliate Transaction Report (May 1, 2026)*
- Secure and remit a qualifying performance bond between March 1st and May 1, 2025**
- DVF providers must also begin submitting annual Operations and Financial reports (March 31, 2026)*
Additionally, DVF providers must seek CPUC approval for any Transfer of Control (ToC) whereas DVN providers must only notify the CPUC of a ToC.
Providers Not Currently Registered in CA
Nomadic and fixed I-VoIP providers not yet registered must do so by May 11, 2025. The registration process varies by registration type (DVF or DVN).
For more information or specific guidance related to the implications of the CPUC rulemaking, please contact the attorney assigned to your account or Jackie McHugh at jrm@commlawgroup.com.
We are standing by to advise and assist your company’s efforts to navigate the new regulatory regime, including exploring options for challenging the new rules at the FCC or in court.
