Telecom taxes and regulatory fees on UCaaS bills

See also

Sources

1. 1
   The instructions used for the 2026 FCC Form 499-A filing are dated September 2025 and were released as attachment A3 of DA 25-308.

   2026 Instructions to the Telecommunications Reporting Worksheet, FCC Form 499-A · Cover page · Checked 2026-10-02
2. 2
   The 2026 Form 499-A instructions state that a provider need not contribute directly to universal service for a year if its contribution for that year would be less than $10,000.

   2026 Instructions to the Telecommunications Reporting Worksheet, FCC Form 499-A · Section III.A.2.a · Checked 2026-10-02
3. 3
   The Form 499-A instructions require any customer bill charge represented as recovering federal or state universal service contributions to be reported separately on Line 403 as part of gross billed revenues.

   2026 Instructions to the Telecommunications Reporting Worksheet, FCC Form 499-A · Gross billed revenues instructions, Line 403 · Checked 2026-10-02
4. 4
   Under the 2026 Form 499-A instructions, non-interconnected VoIP providers with end-user revenues subject to TRS contributions must file the worksheet, but they contribute to TRS only and not to USF, NANPA or LNPA.

   2026 Instructions to the Telecommunications Reporting Worksheet, FCC Form 499-A · Section III.A.2 and Table 1 · Checked 2026-10-02
5. 5
   The Form 499-A instructions state that a telecommunications reseller is not a marketing agent and must file the worksheet.

   2026 Instructions to the Telecommunications Reporting Worksheet, FCC Form 499-A · Section IV.C.4 · Checked 2026-10-02
6. 6
   Under 47 CFR 54.706(c), an entity whose interstate revenues are less than 12 percent of its combined interstate and international revenues contributes only on its interstate end-user revenues.

   47 CFR 54.706 Contributions · 47 CFR 54.706(c) · Checked 2026-10-02
7. 7
   47 CFR 54.706(a)(18) lists interconnected VoIP services among the interstate telecommunications whose providers must contribute to universal service.

   47 CFR 54.706 Contributions · 47 CFR 54.706(a)(18) · Checked 2026-10-02
8. 8
   Under 47 CFR 54.706(b), contributors pay on projected collected interstate and international end-user telecommunications revenues, net of projected contributions.

   47 CFR 54.706 Contributions · 47 CFR 54.706(b) · Checked 2026-10-02
9. 9
   If a contributor recovers federal USF costs through a customer bill line item, 47 CFR 54.712(a) caps that line item at the interstate telecommunications portion of the customer's bill times the relevant contribution factor.

   47 CFR 54.712 Contributor recovery of universal service costs from end users · 47 CFR 54.712(a), second sentence · Checked 2026-10-02
10. 10
    47 CFR 54.712(a) permits, but does not require, contributors to recover federal USF contribution costs through interstate telecommunications-related charges to end users.

    47 CFR 54.712 Contributor recovery of universal service costs from end users · 47 CFR 54.712(a), first sentence ('may be recovered') · Checked 2026-10-02
11. 11
    47 CFR 9.23 limits acceptable uses of 911 fees to supporting and implementing 911 services in the imposing jurisdiction and PSAP operating expenses such as CPE, telecommunicator salaries and training, and 911 administration.

    47 CFR 9.23 (acceptable and unacceptable obligations or expenditures of 911 fees) · 47 CFR 9.23, list of acceptable purposes · Checked 2026-10-02
12. 12
    47 CFR 9.23 treats moving 911 fees into a general fund for non-911 purposes, or spending them on non-public-safety networks or first-responder equipment that does not directly support 911, as unacceptable.

    47 CFR 9.23 (acceptable and unacceptable obligations or expenditures of 911 fees) · 47 CFR 9.23, list of unacceptable purposes · Checked 2026-10-02
13. 13
    Cisco Calling Plan invoices go to the partner of record monthly in PDF or CSV, and recurring charges with their associated taxes are billed a month in advance.

    Cisco Calling Plan bill · Sections on invoice delivery and Recurring Charges · Checked 2026-10-02
14. 14
    US invoices for Cisco Calling Plan include a Tax Details table listing the taxes and fees assessed, such as E911 and FUSF; outside the US, VAT or similar taxes appear in the main invoice section.

    Cisco Calling Plan bill · Section describing the Tax Details table and Annexure · Checked 2026-10-02
15. 15
    An 'E911' line on a UCaaS bill can be either a government 911 fee or a vendor's own emergency-service charge, so the label alone does not show whether it is mandated or how it is set.inferred

    E911 Cost Recovery - Emergency Service Fee · E911 Cost Recovery page body, compared with Talkdesk 'E911' heading · Checked 2026-10-02
16. 16
    26 USC 4251 imposes a federal excise tax of 3 percent on amounts paid for communications services, defined as local telephone service, toll telephone service and teletypewriter exchange service, borne by the person paying.

    26 U.S.C. 4251 Imposition of tax (communications services) · 26 USC 4251(a)(1), (a)(2) and (b) · Checked 2026-10-02
17. 17
    Section 1101(a) of the Internet Tax Freedom Act bars states and their political subdivisions from imposing taxes on Internet access and multiple or discriminatory taxes on electronic commerce.

    47 U.S.C. 151 with statutory notes (Internet Tax Freedom Act, sections 1100-1109) · 47 USC 151 note, ITFA section 1101(a) · Checked 2026-10-02
18. 18
    ITFA section 1105(5) excludes from 'Internet access' voice, audio, video or other IP-based products and services for which there is a separate charge.

    47 U.S.C. 151 with statutory notes (Internet Tax Freedom Act, sections 1100-1109) · 47 USC 151 note, ITFA section 1105(5) · Checked 2026-10-02
19. 19
    Because of the ITFA 1105(5) exclusion, the Internet-access tax moratorium does not on its own exempt a separately charged UCaaS calling service from state and local communications taxes.inferred

    47 U.S.C. 151 with statutory notes (Internet Tax Freedom Act, sections 1100-1109) · 47 USC 151 note, ITFA sections 1101(a) and 1105(5) read together · Checked 2026-10-02
20. 20
    For 911 compliance purposes only, 47 CFR 9.3 extends the interconnected VoIP definition to services that let users place calls to the PSTN even without receiving PSTN calls.

    47 CFR 9.3 Definitions (Code of Federal Regulations, 2024 annual edition) · 47 CFR 9.3, definition 'Interconnected VoIP service', paragraph (2) · Checked 2026-10-02
21. 21
    47 CFR 9.3 defines interconnected VoIP as real-time two-way voice that requires a broadband connection and IP-compatible CPE and generally lets users both receive calls from and place calls to the PSTN.

    47 CFR 9.3 Definitions (Code of Federal Regulations, 2024 annual edition) · 47 CFR 9.3, definition 'Interconnected VoIP service', paragraph (1)(i)-(iv) · Checked 2026-10-02
22. 22
    In FCC 06-94 (2006) the Commission required providers of interconnected VoIP services to contribute to the federal USF under the existing revenue-based methodology on an interim basis.

    Universal Service Contribution Methodology, Report and Order and Notice of Proposed Rulemaking (FCC 06-94, WC Docket No. 06-122) · Paragraph 34 · Checked 2026-10-02
23. 23
    Interconnected VoIP providers that do not report actual interstate revenues or use a traffic study may use a safe harbor treating 64.9 percent of their revenues as interstate for USF reporting.

    2026 Instructions to the Telecommunications Reporting Worksheet, FCC Form 499-A · Section IV.C.5.g Safe Harbors · Checked 2026-10-02
24. 24
    FCC 06-94 imposed the interconnected VoIP USF obligation under the Commission's permissive authority in section 254(d), because it had not decided whether interconnected VoIP is a telecommunications service.

    Universal Service Contribution Methodology, Report and Order and Notice of Proposed Rulemaking (FCC 06-94, WC Docket No. 06-122) · Paragraph 35 · Checked 2026-10-02
25. 25
    CSP invoices and reconciliation files in the US, Puerto Rico and Canada show separate line items for the PSTN and non-PSTN components of offers that include Microsoft voice services.

    Regional PSTN service taxes and fees - Partner Center · Section 'Invoice presentation and partner reconciliation file' · Checked 2026-10-02
26. 26
    Microsoft warns that a CSP partner who marks up the price of a Microsoft PSTN service might be responsible for calculating and remitting PSTN taxes and fees.

    Regional PSTN service taxes and fees - Partner Center · Introductory section, second paragraph, last sentence · Checked 2026-10-02
27. 27
    In the United States and Puerto Rico, Microsoft prices its PSTN services (Audio Conferencing, Calling Plans and Communication Credits) as tax-inclusive.

    Regional PSTN service taxes and fees - Partner Center · Introductory section, second paragraph · Checked 2026-10-02
28. 28
    Under 47 USC 615a-1(f)(1), a 911 fee on IP-enabled voice service may not exceed the fee applicable to the same class of telecommunications subscribers.

    47 U.S.C. 615a-1 Duty to provide 9-1-1 and enhanced 9-1-1 service (NET 911 Improvement Act) · 47 USC 615a-1(f)(1), proviso · Checked 2026-10-02
29. 29
    47 USC 615a-1(f)(1) allows states and other jurisdictions to impose 911 fees or charges on IP-enabled voice service and commercial mobile service for the support or implementation of 911 or E911.

    47 U.S.C. 615a-1 Duty to provide 9-1-1 and enhanced 9-1-1 service (NET 911 Improvement Act) · 47 USC 615a-1(f)(1) · Checked 2026-10-02
30. 30
    RingCentral states that its Compliance and Administrative Cost Recovery Fee is not a tax and is not mandated by any level of government.

    Compliance and Administrative Cost Recovery Fee · Compliance and Administrative Cost Recovery Fee page, body text · Checked 2026-10-02
31. 31
    RingCentral's cost recovery fee recovers government-imposed fees such as the Federal Regulatory Fee, TRS, LNP and STI-GA, plus compliance, number management, network, IP and administrative costs.

    Compliance and Administrative Cost Recovery Fee · Compliance and Administrative Cost Recovery Fee page, list of recovered costs · Checked 2026-10-02
32. 32
    RingCentral's E911 Emergency Service Fee is a monthly recurring service fee for providing 911 and E911 calling, and RingCentral states it is not a government-mandated charge.

    E911 Cost Recovery - Emergency Service Fee · E911 Cost Recovery - Emergency Service Fee page, body text · Checked 2026-10-02
33. 33
    RingCentral charges its Emergency Service Fee at the same rate for all applicable lines.

    E911 Cost Recovery - Emergency Service Fee · E911 Cost Recovery - Emergency Service Fee page, body text · Checked 2026-10-02
34. 34
    RingCentral states that all telecommunications and interconnected VoIP providers, including RingCentral, must pay into the federal USF and that those contributions may be recovered from customers.

    Federal Universal Service Recovery Fee · Federal Universal Service Recovery Fee page, body text · Checked 2026-10-02
35. 35
    Talkdesk's Administrative Fee recovers telecommunications compliance costs and is not mandated by any government agency.

    Taxes and Regulatory/Administrative Fees · Heading 'Administrative Fee' · Checked 2026-10-02
36. 36
    Talkdesk states that taxes are driven by the address where its services are consumed.

    Taxes and Regulatory/Administrative Fees · Introductory text · Checked 2026-10-02
37. 37
    Talkdesk lists E911 as a government-mandated monthly recurring charge, imposed under state or local law as a flat amount per voice-capable access line, to fund emergency service programs.

    Taxes and Regulatory/Administrative Fees · Heading 'E911' under government-mandated taxes · Checked 2026-10-02
38. 38
    Talkdesk applies the Federal USF charge, along with TRS, NANPA, LNP and FCC regulatory fee recovery, to its Dialer product.

    Taxes and Regulatory/Administrative Fees · Headings under government-mandated regulatory fees (Federal USF, TRS, NANPA, LNP, FCC Regulatory Fees) · Checked 2026-10-02
39. 39
    Talkdesk applies the Federal USF charge, based on the FCC's quarterly contribution factor, to its Talkdesk Phone product.

    Taxes and Regulatory/Administrative Fees · Heading 'Federal USF' under government-mandated regulatory fees · Checked 2026-10-02
40. 40
    47 CFR 64.2401(b) requires charges on telephone bills to carry a brief, clear, non-misleading, plain-language description of the service rendered.

    47 CFR 64.2401 Truth-in-billing requirements · 47 CFR 64.2401(b) · Checked 2026-10-02
41. 41
    The FCC's proposed federal universal service contribution factor for the fourth quarter of 2026 (October through December 2026) is 0.42, or 42.0 percent.

    Proposed Fourth Quarter 2026 Universal Service Contribution Factor (public notice, DA 26-946) · Paragraph 1 · Checked 2026-10-02
42. 42
    Projected Q4 2026 universal service demand totals $2,082.43 million: Schools and Libraries $597.25M, Rural Health Care $122.72M, High Cost $1,099.40M and Lifeline $263.06M.

    Proposed Fourth Quarter 2026 Universal Service Contribution Factor (public notice, DA 26-946) · Table in section 'USAC Projections of Demand and Administrative Expenses' · Checked 2026-10-02
43. 43
    USAC projected collected interstate and international end-user telecommunications revenues of $6.909925 billion for Q4 2026, the revenue base against which the Q4 2026 factor is computed.

    Proposed Fourth Quarter 2026 Universal Service Contribution Factor (public notice, DA 26-946) · Section 'USAC Projections of Industry Revenues' · Checked 2026-10-02
44. 44
    RingCentral states that the FCC sets the applicable federal USF rate on a quarterly basis and that it is subject to change.

    Federal Universal Service Recovery Fee · Federal Universal Service Recovery Fee page, body text · Checked 2026-10-02
45. 45
    After Wayfair, a cloud UCaaS vendor with no offices in a state can still be required to collect that state's sales or communications taxes, which is why national vendors bill state and local taxes based on customer address.inferred

    South Dakota v. Wayfair, Inc., 585 U.S. ___ (2018), No. 17-494 · Syllabus (holding) · Checked 2026-10-02
46. 46
    A vendor's USF-style fee percentage need not equal the FCC contribution factor: Vonage's 35.10 percent for Q4 2026 differs from the 42.0 percent factor, presumably because of a different base and bundled programs.inferred

    Federal Program Fee (USF) · Article body, rate statement, compared with DA 26-946 paragraph 1 · Checked 2026-10-02
47. 47
    Vonage's Federal Program Fee rate effective October 1, 2026 is 35.10 percent.

    Federal Program Fee (USF) · Article body, rate statement · Checked 2026-10-02
48. 48
    Vonage's Federal Program Fee recovers its Federal USF, Federal TRS Fund and Federal Regulatory Fee costs plus other regulatory administrative and compliance costs.

    Federal Program Fee (USF) · Article body, first paragraph · Checked 2026-10-02
49. 49
    Vonage's RCIP Fee is a taxable $3.50 monthly charge on each extension, company number and conference bridge, and Vonage states it is not government-mandated.

    Regulatory, Compliance and Intellectual Property (RCIP) Fee · Article body · Checked 2026-10-02
50. 50
    In South Dakota v. Wayfair (June 21, 2018) the Supreme Court overruled the Quill physical-presence rule, so states may require remote sellers without physical presence to collect sales tax.

    South Dakota v. Wayfair, Inc., 585 U.S. ___ (2018), No. 17-494 · Syllabus (holding) · Checked 2026-10-02
51. 51
    Zoom describes its FUSF recovery charges as discretionary charges the FCC allows, not a tax, and its state USF charges as permissible pass-through surcharges not mandated by government.

    Federal & State Universal Service Fund (USF) FAQ · FAQ entries describing FUSF and state USF charges · Checked 2026-10-02
52. 52
    Zoom invoices list each tax or fee with its name, the jurisdictional level imposing it, and the amount.

    US Sales and Telecom Tax Information · Section on reviewing taxes on your invoice · Checked 2026-10-02
53. 53
    Zoom states that a Zoom Phone offering in which the customer maintains its own phone carrier is not subject to Federal and State USF charges from Zoom.

    Federal & State Universal Service Fund (USF) FAQ · FAQ entry on products subject to USF · Checked 2026-10-02
54. 54
    Zoom says Zoom Phone collects federal excise taxes where applicable and charges state and local telecommunications taxes as required.

    Frequently asked questions about taxes · Question 'What fees should I be seeing?' · Checked 2026-10-02
55. 55
    Zoom says Zoom Phone is taxed differently from its other services because state taxing authorities generally treat voice services differently, and Zoom Phone carries regulatory fees that apply to interconnected VoIP.

    Frequently asked questions about taxes · Question 'Why do certain taxes apply only to Zoom Phone?' · Checked 2026-10-02
56. 56
    Zoom uses the customer-provided sold-to address to determine the sourcing of a sale for USF charges.

    Federal & State Universal Service Fund (USF) FAQ · FAQ entry on sourcing · Checked 2026-10-02
57. 57
    Zoom passes the Federal USF charge through to government, school, non-profit and other tax-exempt customers; sales-tax exemption does not remove it.

    Federal & State Universal Service Fund (USF) FAQ · FAQ entry on exemptions · Checked 2026-10-02
58. 58
    Zoom began passing Federal and State USF charges through to Zoom Phone customers on July 1, 2021.

    Federal & State Universal Service Fund (USF) FAQ · FAQ entry on when Zoom began collecting USF · Checked 2026-10-02
59. 59
    For Zoom United bundles, Zoom applies Federal and State USF charges only to the portion of the bundle allocated to Zoom Phone.

    Federal & State Universal Service Fund (USF) FAQ · FAQ entry on Zoom United · Checked 2026-10-02

Documents

Cite this page

WarmTransfer. (2026, October 2). Telecom taxes and regulatory fees on UCaaS bills. WarmTransfer. https://warmtransfer.net/knowledge/telecom-taxes-fees

@misc{warmtransfer-telecom-taxes-fees,
  title  = {Telecom taxes and regulatory fees on UCaaS bills},
  author = {{WarmTransfer}},
  year   = {2026},
  url    = {https://warmtransfer.net/knowledge/telecom-taxes-fees},
  note   = {Verified 2026-10-02}
}