FCC's November draft adds Covered List certifications to VoIP direct access

The FCC votes November 19 on a Fourth Report and Order and Fourth Further Notice (FCC-CIRC2611-03, WC Docket Nos. 13-97, 07-243 and 20-67) covering the rules under which interconnected VoIP providers get numbers directly from NANPA. The order would require applicants and existing authorization holders to certify that they are not on the Covered List or affiliated with an entity on it, that they use no covered equipment or services, and that they have never had a section 214 authorization denied or revoked on national security or law enforcement grounds. New applicants would also list the states where they first plan to request numbers.

The further notice proposes that an applicant certifying to a Covered List link is presumed unqualified, rebuttable only by “clear and convincing evidence.” It asks whether to extend that presumption to entities “owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary,” to foreign-adversary financing and strategic partnerships, and to senior officials working from a foreign-adversary country. It also asks about five years of ownership and leadership history, a business-model narrative, a list of affiliates that will resell the numbers, periodic recertification or renewal, and a physical address that is a bona fide place of business. Bureau staff, the draft says, have seen applicants list co-working spaces, virtual offices and mail centers.

The address proposal quotes the definition already proposed for upstream providers in the KYUP further notice (FCC 26-49) and the call authentication further notice (FCC 26-32). The draft’s background cites the Enforcement Bureau’s 2025 removals of 185 and then 1,203 providers from the Robocall Mitigation Database. Comment dates are blank in the circulated draft; the filings will show up in the Regulatory Watch dispatches once they’re set.