Do outbound-only (one-way) VoIP providers have to file in the RMD and certify CPNI?

The RMD side

For the robocall rules, “voice service” includes “any service that requires internet Protocol-compatible customer premises equipment and permits out-bound calling, whether or not the service is one-way or two-way voice over internet Protocol” (47 CFR § 64.6300(o)(2)(ii)). An outbound-only SIP trunk or calling service is a voice service, with the full filing, know-your-customer and 24-hour traceback duties (§ 64.6305(d); § 64.1200(n)).

The CPNI side

The CPNI rules apply to telecommunications carriers, which for these rules include providers of interconnected VoIP “as that term is defined in section 9.3” (47 CFR § 64.2003(o)). Section 9.3 requires that the service “permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network.” A broader version without the receive element exists “solely for purposes of compliance with the Commission’s 911 obligations” (§ 9.3). The FCC’s CPNI advisory uses the four-part definition to say who must file (DA 26-139).

Where the line usually falls

• If any service you sell lets users both place and receive PSTN calls, you provide interconnected VoIP and the CPNI certification is due each March 1 (§ 64.2009(e)), one per Form 499 Filer ID (DA 26-139).
• If you also resell telecommunications service, the CPNI rules reach you as a carrier; resellers are on the FCC’s list (DA 26-139).
• Outbound-only VoIP fits the definition of “non-interconnected VoIP service” (§ 64.601(a)(34)), which has duties of its own: the 2026 Form 499-A instructions require new VoIP providers, “including interconnected and non-interconnected,” to register within 30 days of beginning service.

These are readings of the rule text, not legal advice. If your service mix is unusual, confirm it with counsel.

Last reviewed: September 30, 2026

General information drawn from the rule text and the FCC documents listed below — not legal advice. You review, sign and submit your own filings.