Federal Communications Commission Washington, DC 20554 April 16, 2026 DA 26-375 SMALL ENTITY COMPLIANCE GUIDE Amendment of the Commission’s Rules Regarding Requirements for VoIP Numbering Authorizations (Numbering Policies for Modern Communications) FCC 25-86 WC Docket Nos. 13-97, 07-243, 20-67 Released December 19, 2025 In accordance with Section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996, this Small Entity Compliance Guide (Guide) is intended to help small entities—small businesses, small organizations (non-profits), and small governmental jurisdictions—comply with the rules adopted in the above-referenced Federal Communications Commission (FCC or Commission) rulemaking dockets. This Guide is not intended to replace or supersede these rules, but to facilitate compliance with the rules. Although we have attempted to cover all parts of the rules that might be especially important to small entities, the coverage may not be exhaustive. This Guide cannot anticipate all situations in which the rules apply. Furthermore, the Commission retains the discretion to adopt case-by-case approaches, where appropriate, that may differ from this Guide. Any decision regarding a particular small entity will be based on the statute and any relevant rules. In any civil or administrative action against a small entity for a violation of rules, the content of the Guide may be considered as evidence of the reasonableness or appropriateness of proposed fines, penalties or damages. Interested parties are free to file comments regarding this Guide in the above referenced docket and the appropriateness of its application to a particular situation. The Commission will then consider whether the recommendations or interpretations in the Guide are appropriate in that situation. The Commission may decide to revise this Guide without public notice to reflect changes in its approach to implementing a rule, or it may clarify or update the text of the Guide. Please direct comments and recommendations, or requests for further assistance, to the FCC’s Consumer Center: 1-888-CALL-FCC (1-888-225-5322) Videophone: 1-844-4-FCC-ASL (1-844-432-2275) Fax: 1-866-418-0232 TABLE OF CONTENTS I. OBJECTIVES OF THE PROCEEDING 1 II. COMPLIANCE REQUIREMENTS 1 III. RECORDKEEPING AND REPORTING REQUIREMENTS 3 IV. IMPLEMENTATION DATE 4 V. INTERNET LINKS 4 I. OBJECTIVES OF THE PROCEEDING The Third VoIP Direct Access Report and Order is another important step in fighting illegal robocalling and spoofing by requiring interconnected Voice over Internet Protocol (VoIP) providers that obtained direct access numbering authorizations prior to the Federal Communication Commission’s (Commission) more recent rule updates to meet the same obligations, disclosures and certifications that are applicable to new entities that apply for the numbering authorization. Numbering Policies for Modern Communications; Telephone Number Requirements for IP-Enabled Service Providers; Implementation of TRACED Act Section 6(a) — Knowledge of Customers by Entities with Access to Numbering Resources, WC Docket No. 13-97, WC Docket No. 07-243, WC Docket No. 20-67, Third Report and Order and Second Further Notice of Proposed Rulemaking, FCC 25-86 (Dec. 19,2025) (Third VoIP Direct Access Report and Order and Further Notice). This Guide also references modifications to the Commission’s rules in previous orders in this proceeding. See Numbering Policies for Modern Communications et al., WC Docket No. 13-97 et al., Second Report and Order and Second Further Notice of Proposed Rulemaking, 38 FCC Rcd 8951 (2023) (Second VoIP Direct Access Report and Order and Further Notice); see also Numbering Policies for Modern Communications et al., WC Docket No. 13-97 et al., Report and Order, 30 FCC Rcd 6839 (2015) (First VoIP Direct Access Report and Order). Specifically, the Third VoIP Direct Access Report and Order requires direct access authorization holders whose authorizations predate August 8, 2024 (when the updated requirements adopted in the 2023 Second Report and Order became effective), to file within 30 days of the effective date of the Third VoIP Direct Access Report and Order, the robocall-related, public safety, and national security certifications and information disclosures in order to maintain their authorizations. In adopting this rule change, the Commission continues to strengthen the direct access to numbers application and authorization process by requiring a uniform framework of safeguards. By mandating that all authorization holders submit the same disclosures and certifications regarding their ownership and control structures, and submit additional certifications of compliance with the Commission’s rules pertaining to illegal robocalling, public safety, and national security, all VoIP numbering authorization holders are evaluated equally, fostering consistent expectations, more efficient filings in the long-term, and greater transparency overall. II. COMPLIANCE REQUIREMENTS Pursuant to 47 CFR § 52.15(g)(3)(x)(E), adopted in the Third VoIP Direct Access Report and Order, authorization holders whose authorizations were issued prior to August 8, 2024, (that is, prior to the effective date of the updated certification and information disclosure requirements adopted in the Second Report and Order) are required to file updated certifications and ownership and control disclosures. Authorization holders must file the updated certifications and information disclosures by the compliance date listed in section IV of this Guide. The certifications require that an officer or responsible official of the company attests under penalty of perjury, pursuant to section 1.16 of the Commission’s rules, that all statements in the filing are true and accurate. All filings must be submitted via the Commission’s Electronic Comment Filing System (ECFS), through the newly established Direct Access Authorization Holder Post-Grant Communications intake docket, INBOX-52.15 (X), and via e-mail to DAA@fcc.gov. The Wireline Competition Bureau (Bureau) may request additional or follow-up documentation as necessary. A. Robocall-Related Certifications (47 CFR § 52.15(g)(3)) (as adopted in the Second Report and Order Second VoIP Direct Access Report and Order and Further Notice, 38 FCC Rcd at 8960, para. 15 (2023). The last clause of the 47 CFR § 52.15(g)(3)(ii)(M), “including the Commission’s rules applicable to unlawful robocalls or unlawful spoofing,” was adopted in the Second VoIP Direct Access Report and Order and Further Notice. Id. ) · Authorization holders must make a certification that the provider will not use the numbers obtained pursuant to an authorization to knowingly transmit, encourage, assist, or facilitate illegal robocalls, illegal spoofing, or fraud, in violation of robocall, spoofing, and deceptive telemarketing obligations under 47 CFR §§ 64.1200, 64.1604, and 64.63 through 64.6308 and 16 CFR § 310.3(b). (47 CFR § 52.15(g)(3)(ii)(C)). · Authorization holders must make a certification that the provider has fully complied with all applicable STIR/SHAKEN caller ID authentication and robocall mitigation program requirements and filed a certification in the Robocall Mitigation Database as required by 47 CFR §§ 64.6301 through 64.6305. (47 CFR § 52.15(g)(3)(ii)(D)). · Authorization holders must make a certification that neither the provider nor any of its key personnel identified in the application are or have been subject to a Commission, law enforcement, or any regulatory agency investigation for failure to comply with any law, rule, or order, including the Commission’s rules applicable to unlawful robocalls or unlawful spoofing. (47 CFR § 52.15(g)(3)(ii)(K)). B. Ownership and Control Disclosure Requirements (47 CFR § 52.15(g)(3)) (as adopted in the Direct Access Second Report and Order Id. at 8964-67, paras. 21-23. See also 47 CFR § 52.15(g)(3)(iii)(v) (“If an application discloses that the applicant has reportable ownership by a foreign person or entity, the Bureau shall remove the application from streamlined processing.”). ) · Authorization holders will provide the same information, disclosures, and certifications required by 47 CFR §§ 63.18(h) and 63.18(i). (47 CFR § 52.15(g)(3)(ii)(L)) o Section 63.18(h)(1) requires the name, address, citizenship, and principal businesses of any individual or entity that directly or indirectly owns ten percent or more of the equity interests and/or voting interests, or a controlling interest, of the applicant, and the percentage of equity and/or voting interest owned by each of those entities (to the nearest one percent). Where no individual or entity directly or indirectly owns ten percent or more of the equity interests and/or voting interests, or a controlling interest, of the applicant, a statement to that effect. (Subparts (i) and (ii) provide information on the calculation of voting and equity interests held indirectly).  o Section 63.18(h)(2) requires an ownership diagram that illustrates the applicant's vertical ownership structure, including the direct and indirect ownership (equity and voting) interests held by the individuals and entities named in response to paragraph (h)(1) of this section. Every individual or entity with ownership shall be depicted and all controlling interests must be identified. The ownership diagram shall include both the pre-transaction and post-transaction ownership of the authorization holder.    o Section 63.18(h)(3) requires that the applicant shall also identify any interlocking directorates with a foreign carrier.  o Section 63.18(i) requires a certification as to whether or not the applicant is, or is affiliated with, a foreign carrier. The certification shall state with specificity each foreign country in which the applicant is, or is affiliated with, a foreign carrier.  C. Public Safety Certification (47 CFR § 52.15(g)(3)) (as adopted in the Direct Access Second Report and Order Second VoIP Direct Access Report and Order and Further Notice, 38 FCC Rcd at 8970-71, paras. 37-39. ) · Authorization holders must make a certification with accompanying evidence that the provider complies with its 911 obligations and that it complies with the provisions of the Communications Assistance with Law Enforcement Act, 47 U.S.C. 1001 et seq, and comply with any Bureau requests for additional information to demonstrate compliance with these public safety obligations. (47 CFR § 52.15(g)(3)(ii)(E)) D. Access Stimulation Certification (47 CFR § 52.15(g)(3)) (as adopted in the Direct Access Second Report and Order Id. at 8971-73, paras. 40-43. ) · Authorization holders must make a certification that they comply with the Access Stimulation rules under 47 CFR § 51.914. (47 CFR § 52.15(g)(3)(ii)(F)) E. FCC Form 477 and 499 Filings Requirements (47 CFR § 52.15(g)) (as adopted in the Direct Access First Report and Order First VoIP Direct Access Report and Order, 30 FCC Rcd at 6858, para. 37, n.131. and amended by the Direct Access Second Report and Order Second VoIP Direct Access Report and Order and Further Notice, 38 FCC Rcd at 8973, para. 44. ) · Authorization holders must provide proof that the provider has filed FCC Forms 477 and 499, or a statement explaining why each such form is not yet applicable. (47 CFR § 52.15(g)(3)(ii)(I)) F. Declaration Requirement (47 CFR § 52.15(g)) (as adopted in the Direct Access Second Report and Order Id. at 8979-80, paras. 54-55. ) · Authorization holders must provide a declaration under penalty of perjury pursuant to 47 CFR § 1.16 that all statements in the application and any appendices are true and accurate. This declaration shall be executed by an officer or other authorized representative of the applicant. (47 CFR § 52.15(g)(3)(ii)(N)) III. RECORDKEEPING AND REPORTING REQUIREMENTS The Third VoIP Direct Access Report and Order, contains new information collection requirements for the holders of a VoIP numbering authorization. As detailed above in section II, authorization holders are required to provide specific certifications, make disclosures and provide supporting documentation in order to comply with the update requirements now for all authorization holders and to ensure that the Commission receives sufficient information to make informed, public-interest-driven decisions to evaluate authorizations. Authorization holders are required to maintain the accuracy of their application filings and promptly update the Commission with any changes. See 47 CFR § 52.15(g)(3)(x)(A). · Authorization holders should make certifications consistent with the language of the Commission’s rules. · For disclosures pertaining to ownership and control, authorization holders should review the cross-referenced rules and provide all the necessary information, e.g., entity organization charts, disclosures of all individuals or entities with ten percent or greater ownership interests, etc. · Supporting documentation for public safety compliance should be a 911 service agreement and a CALEA (Communications Assistance for Law Enforcement Act) plan that has been filed with the Commission, or other appropriate compliance evidence. · Supporting documentation for compliance with FCC Form 477/BDC reporting and Form 499 can be screenshots that demonstrate filing compliance or written statements explaining why compliance is not required. IV. IMPLEMENTATION DATE The rules in the Third Report and Order became effective March 19, 2026. The new information-collection requirements in 47 CFR § 52.15(g)(3)(x)(E)—which requires holders of authorizations that were issued prior to August 8, 2024, to file updated certifications and ownership and control disclosures—is subject to review by the Office of Management and Budget (OMB) pursuant to the Paperwork Reduction Act. Compliance with this rule will not be required until the Commission publishes a notice in the Federal Register announcing OMB approval and the relevant compliance date. V. INTERNET LINKS A copy of the Direct Access First Report and Order is available at: https://docs.fcc.gov/public/attachments/FCC-15-70A1.pdf. A copy of the Direct Access Second Report and Order is available at: https://docs.fcc.gov/public/attachments/FCC-23-75A1.pdf. A copy of the Direct Access Third Report and Order is available at: https://docs.fcc.gov/public/attachments/FCC-25-86A1.pdf. A copy of the Federal Register Summary of the Direct Access First Report and Order is available at: https://www.govinfo.gov/content/pkg/FR-2015-10-29/pdf/2015-20900.pdf. A copy of the Federal Register Summary of the Direct Access Second Report and Order is available at: https://www.govinfo.gov/content/pkg/FR-2023-11-20/pdf/2023-24679.pdf. A copy of the Federal Register Summary of the Direct Access Third Report and Order is available at: https://www.govinfo.gov/content/pkg/FR-2026-02-17/pdf/2026-03066.pdf A copy of OMB Approval of the original Information Collection, OMB Control No. 3060-1214 is available at: https://www.govinfo.gov/content/pkg/FR-2016-02-04/pdf/2016-02013.pdf. A copy of the OMB Approval of the revised Information Collection, OMB Control No. 3060-1214 is available at: https://www.federalregister.gov/documents/2024/08/08/2024-17346/numbering-policies-for-modern-communications. The FCC maintains an Electronic Comment Filing System that is used to submit filings for the VoIP Numbering Application and Authorization. The newly established intake docket, “INBOX-52.15 (X),” should be used to make filings required by authorization holders and can be accessed at here. INBOX-52.15 (X), VoIP Numbering – Authorization Holder Post-Grant Communications, https://www.fcc.gov/ecfs/search/search-filings/results?q=(proceedings.name:(%22INBOX-52.15%20(X)*%22)). (The existing intake docket, INBOX-52.15, should continue to be used to VoIP Numbering application filings.). 2