Our post about the unique enforcement posture of interconnected VoIP quickly became the most popular post on the Telecom Law Monitor. One person asked if we could elaborate on the differences in regulatory treatment between traditional telecom services, interconnected VoIP and non-interconnected VoIP (like Skype). In response, we prepared a chart comparing applicability of the major telecom obligations to both types of VoIP.
As the chart shows, the FCC has imposed many telecom obligations on interconnected VoIP on an individual basis. In each instance, the FCC relied upon its ancillary authority to impose the obligation, even if it were ultimately to classify interconnected VoIP an information service. In a few instances, the FCC has not -- yet at least -- imposed a telecom obligation on interconnected VoIP. VoIP services that do not meet the FCC's definition of "interconnected VoIP" are not subject to any of the telecom service requirements today.
DISCLAIMER: This chart is for informational purposes only and is not intended to serve as legal advice or a comprehensive review of regulatory obligations. With that in mind, you may view the chart here.