On January 17, 2017, the Canadian Radio-television and Telecommunications Commission (the "Commission") published Telecom Regulatory Policy CRTC 2017-11 (Application of regulatory obligations directly to non-carriers offering and providing telecommunications services) ("Policy 2017-11").

Under Policy 2017-11, the Commission directed resellers (also known as non-carriers), as a condition of offering and providing any telecommunications services in Canada, to abide by all applicable existing consumer safeguard obligations set out in Policy 2017-11, including the obligation to register with the Commission (the "registration obligation").

Pursuant to the registration obligation, all resellers are required to register with Commission prior to receiving telecommunications services for resale from Canadian carriers and other non-carriers.

Policy 2017-11 required resellers to register with the Commission by no later than July 17, 2017.

On July 10, 2017, the Commission published Telecom Regulatory Policy CRTC 2017-11-1 ("Policy 2017-11-1").

In Policy 2017-11-1, the Commission notes, in part, that "the Commission has received a large number of inquiries and applications regarding registration. Given this, and to avoid any disruptions to existing telecommunications services, the Commission is postponing the registration deadline to 17 July 2018."

Policy 2017-11-1 also states, in part, that "The Commission intends to initiate a proceeding shortly, by way of notice of consultation, to examine, among other things, which types of non-carriers should be subject to registration."

We anticipate that this consultation will be welcomed by several organizations, including some which sell Internet of Things (IoT) devices. Some of these organizations do not consider themselves resellers, and consultations with the Commission will, hopefully, enable all parties to engage in open dialogue to reach a consensus.