On September 25, 2025, the FCC’s Enforcement Bureau released an Order and Consent Decree resolving a multi-year investigation into Vonage Holdings Corp. (Vonage) and its wholly-owned subsidiary, Vonage Business Inc. The investigation examined alleged failures to:
- Maintain current registration information in the FCC’s CORES database;
- File timely and accurate annual and quarterly Telecommunications Reporting Worksheets (Forms 499-A and 499-Q); and
- Fully and timely contribute to the Universal Service Fund (USF), Telecommunications Relay Service (TRS) Fund, North American Numbering Plan (NANP) administration, and annual FCC regulatory fees.
To resolve these matters, Vonage agreed to:
- Pay a $2,000,000 settlement;
- Implement a three-year Compliance Plan overseen by a designated Compliance Officer;
- Adopt enhanced operating procedures, internal compliance manuals, and mandatory training for employees involved in reporting and contributions; and
- File periodic compliance reports with the FCC.
Key Takeaways for the Industry
- Accuracy and Timeliness Are Critical – The FCC emphasized that late or inaccurate Form 499 filings undermine the integrity of federal support mechanisms and give violators an unfair competitive advantage. The Vonage matter underscores the Bureau’s increasing intolerance for even inadvertent lapses, particularly when they affect USF and TRS contributions.
- Systemic Failures Attract Significant Penalties – Vonage’s issues spanned several years, involving at least 28 separate filing violations and subsequent underpayments exceeding $4 million across USF, TRS, NANP, and regulatory fees. Although Vonage ultimately made true-up payments, the FCC still imposed a significant monetary penalty and a binding compliance program.
- Compliance Plans as an Enforcement Tool – The Consent Decree highlights the FCC’s reliance on forward-looking compliance measures. Companies subject to similar investigations should expect not just monetary penalties but also structural reforms—including training, reporting obligations, and senior management accountability.
- Implications for Competitive Carriers, VoIP Providers, and SaaS-Telecom Hybrids – The decision signals that all service providers with federal reporting and contribution obligations remain firmly on the FCC’s enforcement radar, regardless of size or market segment. This includes VoIP providers, CPaaS platforms, and other hybrid service providers that may underestimate their compliance burdens.
This enforcement action serves as a reminder that regulatory compliance lapses—even when corrected—can result in multimillion-dollar penalties and long-term oversight obligations. Providers should carefully evaluate their internal compliance systems, verify the accuracy of past and current reporting, and proactively remediate deficiencies before they draw regulatory scrutiny.
The Commpliance Group Can Help!
The Commpliance Group (TCG)—the consulting affiliate of Marashlian & Donahue, PLLC, The CommLaw Group—offers an integrated, “right professionals on the right projects at the right price” approach to federal and state telecom compliance. Working hand-in-glove with our attorneys, TCG delivers practical, technology-enabled support across the full lifecycle: CORES and 499 registration/maintenance; Form 499-A/Q preparation and true-ups; USF/TRS/NANP and FCC regulatory fee modeling and remittance; revenue mapping and service classification (including bundled/offering optimization); KYC, robocall mitigation, and STIR/SHAKEN program design; internal policies, training, and managed compliance operations via our AccuCompliance platform. This coordinated legal-plus-consulting model helps providers close gaps quickly, withstand audits and investigations, and reduce total cost of compliance without sacrificing defensibility. To learn more about how TCG and The CommLaw Group partner to protect your business, visit our newly updated site at www.CommplianceGroup.com.
If you have questions about the Vonage Consent Decree, or if you would like to assess your own compliance risks in this area, please contact the attorney assigned to your account, or reach out to Jonathan Marashlian at jsm@commlawgroup.com.