VoIP is covered. The FCC settled that in 2005.
Interconnected VoIP has been covered by CALEA since the FCC's 2005 First Report and Order. If your service lets a subscriber call the public telephone network and receive calls from it, the obligation applies — regardless of how small the operation is or how much of it you resell.
Interconnected means covered.
The test is not the technology, it is the interconnection. A provider whose subscribers can place calls to and receive calls from the public switched telephone network is a covered provider, and a court order will arrive addressed to you, not to your upstream.
That catches a lot of businesses that do not think of themselves as carriers: cloud PBX operators, UCaaS platforms, wholesale SIP providers, and resellers who assumed the obligation travelled with the underlying network. It does not.
Wherever your voice path actually runs.
VoIP is not one architecture, and an intercept access point that suits one deployment is wrong for the next. The interface is engineered to the network you have.
Session border controllers
The natural access point in most interconnected deployments, where signalling and media both pass a controlled boundary.
Soft switches
Call control lives here, which makes it the right place to capture call-identifying information cleanly.
SIP proxies
Signalling-only visibility, useful where call data is authorized and content is not.
Media relays
Where content must be delivered, the media path is captured separately from the signalling that describes it.
Two ways in, chosen for your risk.
Deployment is a trade between visibility and intrusion, and it is your call rather than a vendor default.
Passive
The intercept observes a copy of the traffic and cannot alter it. Nothing sits in the call path, so nothing new can drop a customer call — the usual choice where the operations team's first question is "what happens if it fails?"
Active
The intercept sits in the path, which gives cleaner correlation between signalling and media where a passive tap would have to reconstruct it. Chosen where the network makes passive capture impractical rather than as a preference.
Tell us how your voice path is built.
A free technical analysis of your network, and the least-cost, minimally invasive path to compliance for it.