CALEA compliance for IPES providers.
VoIP providers moving to IP-only networks are filing with the FCC for direct access to numbers — and finding that the filing requires a certification of CALEA compliance, with evidence. We already know the requirement. We already have solutions in place. Our VoIP clients are already compliant.
The filing asks for evidence, not intentions.
Since September 2023, an interconnected VoIP provider applying to the FCC for direct access to numbering resources must file "a certification with accompanying evidence that the applicant complies with its 911 obligations under part 9 of this chapter, and that it complies with the provisions of the Communications Assistance with Law Enforcement Act" — 47 CFR § 52.15(g)(3)(ii)(E), adopted in the Commission's Second Report and Order (FCC 23-75). In December 2025 the FCC extended the same certification to every provider that already holds a numbering authorization (FCC 25-86), due within 30 days of the rules taking effect.
The Commission did not prescribe the evidence. It noted that "technical specifications and call-flow diagrams" have helped its staff assess compliance, reserved the right to ask for more, and reminded VoIP providers of their existing duty to file a CALEA system security and integrity plan before commencing service. A provider that cannot show a working capability cannot complete the filing — and the FCC has said that an authorization holder found not to comply may see its numbering authorization suspended, terminated or revoked.
Who files
Interconnected VoIP providers — IP-enabled service providers, in the FCC's docket title — seeking or holding direct access to telephone numbers. Two-way PSTN reach is what makes a provider eligible for numbers, and what makes it a CALEA carrier.
What is certified
CALEA compliance and 911 compliance, each with accompanying evidence; plus the robocall, STIR/SHAKEN, access-stimulation and ownership certifications in the same application.
What "evidence" looks like
A capability that exists and can be shown: specifications, call-flow diagrams, the standard it delivers to, the SSI plan on file, the point of contact law enforcement can reach.
What has not changed
The obligation itself. Interconnected VoIP has been inside CALEA since the FCC's 2005 First Report and Order, with a compliance date of May 14, 2007. The numbering desk is where it now gets checked.
SIP to SIP changes where the intercept sits, not whether it is owed.
On a TDM network the intercept lived on the switch. On an IP-only voice network the access function attaches to the session border controller, the soft switch, the SIP proxy or the media relay — actively, by provisioning the element, or passively, on a mirror of the traffic. Either way the chain is the same one CALEA has always required: isolate the named subscriber, mediate the traffic into the standard the agency requires, deliver it securely, log it, and stop on the order's end date.
Validate the order
Authority, scope, target identifiers, dates. An order with an error goes back for correction before anything is provisioned.
Provision the target
On the element that actually carries the session — SBC, soft switch, proxy or relay — and only for the subscriber the order names.
Mediate to standard
Call-identifying information and, where authorized, content, converted to the current ATIS delivery standard for VoIP and handed off over a secured connection.
Deliver, log, terminate
To the agency named in the order, with every action recorded, for exactly the life of the order.
Subsentio has engineered this capability for large VoIP providers using unique, proven solutions already deployed in production. Whether a given approach fits a given network is decided by looking at the network — which is where every engagement starts. VoIP lawful intercept in detail →
A capability that exists, and the paper that proves it.
The FCC wants to see that the obligation is met, not that it is planned. For a Subsentio customer that is a short list, because it is what the company already operates for every VoIP client on its watch: the intercept capability engineered to the applicable standard; the system security and integrity plan and senior-officer designation the FCC's Part 1 rules require; the 24-hour desk that validates and executes orders; and the record of every action taken under one.
The rest of the filing — 911 and NG911, the robocall and STIR/SHAKEN certifications, the access-stimulation certification under § 51.914, ownership disclosures — is for the provider and its counsel. We stay on the CALEA half, and we make that half easy to show.
IPES and CALEA, answered.
What is an IPES provider?
IPES VoIP is the FCC's shorthand for an IP-enabled service provider — in practice, an interconnected VoIP provider that delivers voice over IP end to end, often SIP to SIP with no legacy TDM switching, and takes its telephone numbers directly from the numbering administrators rather than through a carrier partner. The FCC's numbering rules for these providers sit in the docket titled "Telephone Number Requirements for IP-Enabled Service Providers," and the term "IPES Provider" is also defined in the Commission's intercarrier-compensation rules at 47 CFR § 61.3(eee).
Why does an IPES provider have to show CALEA compliance to the FCC?
Because direct access to numbers is an FCC authorization, and since 2023 the application requires "a certification with accompanying evidence that the applicant … complies with the provisions of the Communications Assistance with Law Enforcement Act" (47 CFR § 52.15(g)(3)(ii)(E), adopted in FCC 23-75). In December 2025 the FCC extended the same certification to every provider that already holds a numbering authorization (FCC 25-86). A provider that cannot show its CALEA capability cannot complete the filing.
What counts as "accompanying evidence"?
The FCC deliberately did not prescribe a single form of evidence. It noted that technical specifications and call-flow diagrams have been helpful to Commission staff in assessing compliance, and that Bureau staff may request additional documentation. In practice a provider needs to be able to show a working lawful-intercept capability engineered to the applicable standard, and the system security and integrity plan the rules require — not a statement that it intends to comply later.
We are moving from TDM to SIP-to-SIP. Does that change our CALEA obligation?
No — an interconnected VoIP provider has been a CALEA telecommunications carrier since the FCC's 2005 First Report and Order, whatever the underlying switching. What changes is where the intercept capability sits: on an IP-only network the access function and mediation attach to the session border controller, soft switch, SIP proxy or media relay rather than to a class-5 switch. Subsentio engineers the IPES lawful intercept capability to that topology, using unique, proven solutions already deployed for large VoIP providers.
Is Subsentio the first to offer this?
No, and we would not say so. Interconnected VoIP providers have carried CALEA obligations since 2007, and providers that did what the statute required years ago are compliant today. What is new is the FCC requiring evidence of it at the numbering desk. We already know the requirement, we already have solutions in place, and we already have VoIP clients whose compliance the filing simply documents.
What does Subsentio actually deliver for an IPES filing?
The CALEA capability itself, engineered to the applicable ATIS standard for VoIP and operated end to end; the system security and integrity plan and the 24-hour point of contact the rules require; the court-order validation, provisioning, delivery and record that make the capability real; and the documentation — specifications, call-flow diagrams, the compliance program — a provider can put behind its certification. The 911, robocall and access-stimulation certifications in the same filing are for the provider and its counsel.
Filing for numbers? Bring us the network.
Tell us how your voice path is built and when your filing is due. We will tell you what the CALEA half needs, stand it up if it is not there, and hand you the documentation to put behind the certification.