Do Enterprise Users/Private Switch Owners and Operators have to comply with the FCC’s Regulations?
Although the Order is ambiguous in many places, several aspects of the Order indicate that it applies only to commercial providers of VoIP, not corporate end users deploying VoIP for internal use on their private networks. In several sections, for example, the Order specifies that E911 functionalities must be provided to “customers” of VoIP services, suggesting that the FCC did not intend the regulations to apply to VoIP deployed for corporate self-use. Furthermore, the Order expressly states that the E911 requirements only apply to interconnected VoIP services; the rules do not apply to non-interconnected VoIP services or to the sale or use of IP-compatible CPE, such as an IP PBX, that itself uses other telecommunications or VoIP services to exchange traffic with the PSTN. Finally, the context in which this Order was adopted does not suggest that the FCC is targeting enterprise end-users for regulation: the FCC adopted the Order in response to the inability of residential consumers to
