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UK and EU Regulation of Voice

The last 10 years has seen numerous battles over the rights and obligations of VoIP providers. This articles outlines how the UK and EU regulators have changed their position over that period...

In the period 2003 2005, UK, European and US regulators had to consider various disputes concerning the provision of VoIP services as a direct replacement for traditional incumbent voice services, known as Public Access Telephony Service (PATS). Traditionally, an operator providing PATS service was required to meet certain obligations, and meeting these obligations automatically made the service a PATS service:

  • Access to Lifeline services
  • Access to location information for subscribers in the emergency services database
  • Priority for emergency calls within the network
  • Directory listings
  • Facilities for users with disabilities, such as text phones and text phone services
  • Access to Geographic numbering according to a national numbering plan

As start-up operators have attempted to offer primary line services across IP networks, the regulators in most countries have taken the view that this is acceptable, provided the customer is informed and protected from miss-selling. Consequently the obligations of PATS for VoIP providers were substantially relaxed. It was not necessary to provide emergency services access (999 calls in the UK) and location information (although desirable), or priority within the network (impossible without end-to-end management of the IP network), for example. However a VoIP operator who wishes to designate their service as PATS has access to the regulated relationships between providers, such as Local Number Portability (LNP). The result of this was to remove any regulatory impediment to start-up operators offering competing primary line services.

More recently Ofcom has determined that the designation of voice service as PATS is automatic if the obligations of PATS are met, and has furthermore consulted in mid 2007 on enforcing 999 access and location databases integration for all VoIP services which are PSTN replacements, while allowing services which do not interconnect with the PSTN not to comply with these obligations (and so not be designated PATS). This can be viewed as a tightening up the obligations on direct-replacement VoIP operators after a more liberal period during initial deployments.

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