Voice over Internet Protocol
Produced in partnership with Peter Elliott of DLA Piper and Mike Conradi of DLA Piper

The following TMT practice note produced in partnership with Peter Elliott of DLA Piper and Mike Conradi of DLA Piper provides comprehensive and up to date legal information covering:

  • Voice over Internet Protocol
  • The regulatory position
  • Ofcom’s classification of VoIP services
  • GCs A3.2 and A3.3 (Availability of services, including access to emergency services)
  • GCs A3.4–A3.6 (Emergency call numbers and caller location identification)
  • Further developments
  • 5G
  • The move from the PSTN to fibre
  • The European Electronic Communications Code

Voice over Internet Protocol

This Practice Note examines specific issues within the Ofcom’s regulatory framework related to Voice over Internet Protocol (VoIP) technology and gives practical suggestions for dealing with future developments.

VoIP technology is now widely used for the transmission of voice calls over the internet. Increasingly, the technology is being used by individuals and corporations as a more cost-effective alternative to public switched telephone network (PSTN) services.

The regulatory position

In an early statement on the subject, Ofcom, the UK telecommunications regulator, set out three objectives that it considered important in formulating policy in relation to VoIP services:

  1. enabling innovation in a technologically neutral way

  2. ensuring consumers are well informed, and

  3. ensuring maximum availability of emergency services access

Service providers (including providers of VoIP services) are required to comply with Ofcom’s General Conditions of Entitlement (GCs). As a result of a review of the GCs with the stated aim of seeking to update them to 'reflect Ofcom’s current priorities and concerns, and [ensure they] are simpler and clearer for industry to comply with', a revised set of GCs came into force on 1 October 2018. The GCs have been updated by Ofcom on several occasions since then—culminating in Ofcom publishing an updated consolidated version of the GCs in December 2020, which reflected updates made to them in order to support the implementation of Directive (EU) 2018/1972 (the

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