---
title: "What are the CALEA requirements when an ISP adds business voice?"
topic: "Compliance & Legal"
updated: 2026-05-09
canonical: https://acrobits.net/resources/knowledge-base/calea-requirements-isp-business-voice/
summary: "Any ISP offering interconnected VoIP — service that can reach or receive calls from the public telephone network — is subject to CALEA. Requirements include: (1) maintaining technical capability to execute court-authorized lawful intercepts, (2) filing a System Security and Integrity (SSI) plan with the FCC, (3) designating a 24/7 CALEA point of contact, and (4) contributing to the Universal Service Fund. Most small operators fulfill the technical obligation by contracting with a Trusted Third Party (TTP) such as Subsentio or Yaana rather than building intercept infrastructure in-house."
---

# What are the CALEA requirements when an ISP adds business voice?

> Any ISP offering interconnected VoIP — service that can reach or receive calls from the public telephone network — is subject to CALEA. Requirements include: (1) maintaining technical capability to execute court-authorized lawful intercepts, (2) filing a System Security and Integrity (SSI) plan with the FCC, (3) designating a 24/7 CALEA point of contact, and (4) contributing to the Universal Service Fund. Most small operators fulfill the technical obligation by contracting with a Trusted Third Party (TTP) such as Subsentio or Yaana rather than building intercept infrastructure in-house.

Yes — once you offer **interconnected VoIP** (service that can call or receive calls from the public telephone network), you are subject to [CALEA](/voip-glossary/calea/): the Communications Assistance for Law Enforcement Act. The FCC's 2005 order extended CALEA from traditional carriers to interconnected VoIP and broadband internet access providers. Adding hosted PBX or UCaaS to a broadband product almost always crosses that threshold.

## Does CALEA apply to my service?

The trigger is **PSTN interconnection**. Ask one question: can a subscriber dial a regular phone number, or receive a call from one? If yes, you are an interconnected VoIP provider and CALEA applies.

  - **Not covered** — App-to-app-only services that never touch the PSTN (e.g., a closed in-network push-to-talk tool).

  - **Covered** — Any hosted PBX, UCaaS, or SIP trunk service where subscribers can reach or be reached from the PSTN.

  - **Pure reseller grey area** — If you resell a licensed carrier's trunks without providing service directly to end users, your CALEA obligation may rest with the underlying carrier. Confirm in writing before assuming you are exempt.

The FCC does not scale obligations by company size. A 200-line fiber ISP rolling out hosted PBX has the same CALEA requirements as a national carrier.

## What you must do

  - **Lawful intercept capability** — You must be technically capable of isolating and delivering the content of communications and call-identifying information to law enforcement under a valid court order. This capability must exist before you begin offering the service.

  - **System Security and Integrity (SSI) plan** — File an SSI plan with the FCC (Electronic Comment Filing System, docket 04-295). The SSI plan documents how your network protects the confidentiality of lawful intercepts and how you prevent unauthorized access to intercept capability.

  - **CALEA point of contact** — Designate and register a CALEA point of contact — a named individual law enforcement agencies can reach 24/7 to serve process and coordinate intercepts.

  - **USAC contributions** — Interconnected VoIP providers must contribute to the Universal Service Fund (USF). CALEA compliance and USF contribution come together as part of operating as an interconnected VoIP provider under FCC jurisdiction.

## How operators usually comply

Most small and mid-size ISPs and VoIP operators do not build intercept capability in-house. The standard approach is to contract with a **Trusted Third Party (TTP)** — a specialized intermediary that maintains FCC-compliant intercept infrastructure and fulfills court orders on your behalf.

Common TTPs in the US market:

  - **Subsentio** — widely used by regional carriers and ISPs; handles SSI plan filing assistance, intercept delivery, and POC services.

  - **Yaana Technologies** — cloud-based lawful intercept platform; integrates with softswitch and IMS environments.

  - **NeuStar / TransUnion** — provides CALEA mediation for carriers with existing number intelligence infrastructure.

Using a TTP does not eliminate your regulatory responsibility — you remain the provider of record. It does move the technical complexity and 24/7 operational burden to a specialist, which is typically the right trade-off for operators under a few thousand lines.

## How this fits with E911 and STIR/SHAKEN

CALEA is one of three primary regulatory obligations that attach when an ISP adds business voice. The others:

  - **E911** — Route emergency calls to the correct PSAP with location. Covered in detail in [E911 Requirements for ISPs Adding Voice](/resources/knowledge-base/e911-legal-isp-voice/).

  - **STIR/SHAKEN** — Caller ID authentication to combat robocalling. Your trunk provider handles signing; you choose who that trunk provider is. See [STIR/SHAKEN Obligations for White-Label Operators](/resources/knowledge-base/stir-shaken-white-label/).

All three obligations activate at the same moment — when you cross from broadband-only to interconnected VoIP. Budget time and cost for all three before you [launch your UCaaS product](/blog/cloud-softphone/launch-ucaas-product/).

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