# Toll-free numbering and RespOrg

Canonical: https://warmtransfer.net/knowledge/toll-free-numbering

Last verified: 2026-09-24

Under Federal Communications Commission (FCC) rules, a toll-free number is a telephone number for which the toll charges for completed calls are paid by the toll-free subscriber[^20]. A Responsible Organization (RespOrg) is the entity chosen by that subscriber to manage and administer its records in the toll-free Service Management System (SMS) database[^25].

## SMS database and registry administration

The SMS database serves as the administrative database for toll-free numbers, where RespOrgs enter and amend number data that is shared with regional Service Control Points[^28]. The Toll Free Numbering Administrator (TFNA) is appointed by the FCC to administer the SMS database day to day and provide user support for it[^44].

Somos provides a 3-step route to becoming a toll-free service provider (RespOrg): an online application with a deposit, training (in person or self-directed), and passing an examination on industry practices[^29]. In November 2022, Somos began integrating Resp Org Change (ROC) processing into the TFNRegistry[^27]. As of November 2023, TFNRegistry ROC bulk upload supports up to 20,000 numbers via the API and 5,000 numbers via the user interface[^26]. For critical numbers such as those of government agencies and hospitals, Somos describes the use of an xxx99 Resp Org ID; when a toll-free number sits under an xxx99 Resp Org ID, any completed Resp Org Change triggers an email and telephone alert to the controlling Resp Org[^30]. WarmTransfer's reading of the sources is that moving a US toll-free number between providers is carried out as a Resp Org Change in the Somos TFNRegistry rather than through the local number portability process[^21].

## Number statuses and lag times

- **Spare**: Available for assignment by a RespOrg[^35].
- **Reserved**: Reserved by a RespOrg from the SMS database for a subscriber[^34]. A number may stay in reserved status for up to 45 days[^24], though numbers assigned through competitive bidding may remain in reserved status indefinitely[^10].
- **Assigned**: The RespOrg has entered subscriber routing information in the SMS database and activation in the Service Control Points is pending[^32]. A number may remain in assigned status for at most 6 months before it must be converted to working status[^8].
- **Working**: Loaded in the Service Control Points and being used to complete toll-free calls[^39].
- **Disconnect**: Service has been discontinued and an exchange carrier intercept recording is being provided[^33].
- **Transitional**: Disconnected for less than 4 months with no exchange carrier intercept recording provided[^37]. Numbers must remain in disconnect or transitional status for no less than 45 days and no more than 4 months, and extensions are not permitted[^16].
- **Suspend**: Service has been temporarily disconnected and is scheduled to be reactivated[^36]. A number may remain in suspend status until changed to working status or for a maximum of 8 months, whichever comes first[^40].
- **Unavailable**: Cannot be assigned because of an unusual condition[^38].

## Allocation rules, hoarding, and warehousing

Toll-free numbers must be made available to RespOrgs and subscribers on an equitable basis[^17]. The FCC may assign toll-free numbers by competitive bidding, first-come first-served, an alternative assignment method, or a combination of these[^9]. 

Under FCC 19-75, published at 84 FR 50767 on September 26, 2019, the FCC adopted procedures for the 833 auction (Auction 103), scheduled for December 17, 2019[^2][^3]. The 833 auction offered 17,638 toll-free numbers in the 833 code as a single-round sealed-bid Vickrey auction in which each number's highest bidder won and paid the second-highest bid[^1][^4].

Federal rules impose strict safeguards against misuse of toll-free inventory:
- **Reservation caps**: A RespOrg may hold no more than the greater of 2,000 toll-free numbers or 7.5% of its working toll-free numbers in reserved status[^22].
- **Warehousing**: Warehousing is defined as a RespOrg reserving numbers from the SMS database without an actual subscriber, directly or through an affiliate[^45]. A reservation serves as certification that an identified subscriber has agreed to be billed[^23]. A rebuttable presumption of warehousing arises if a RespOrg lacks an identified subscriber agreeing to be billed for a reserved number, or lacks an identified billed subscriber before switching a number to working status[^46].
- **Hoarding and brokering**: Hoarding is prohibited and occurs when a subscriber acquires more numbers from a RespOrg than it intends to use to provide toll-free service[^19]. Brokering is also barred: no person or entity may acquire a toll-free number for the purpose of selling it to another person or entity for a fee[^11].

## 8YY access charge transition

Intercarrier compensation rules transitioned access charges for toll-free calls:
- From July 1, 2021, rate-of-return carriers were required to reduce Toll Free Database Query Charges to no more than $0.004248 per query[^6].
- The July 1, 2021 step also set transitional joint tandem switched transport access rates for toll-free calls to no more than $0.001 per minute[^7].
- From July 1, 2023, toll-free originating end office access transitioned to bill-and-keep, and Toll Free Database Query Charges were reduced to a transitional rate of no more than $0.0002 per query[^5].

## UCaaS platform implementations

| Provider | Requirement or limitation | Usage or ordering details |
| --- | --- | --- |
| Cisco Calling Plans | Numbers cannot be ordered as a block[^12]. | Applies to US and Canada[^12]. |
| Microsoft Teams Calling Plans | Pay-as-you-go billing (Communications Credits) is required to reserve and use numbers[^41]. | Granted in tiers by count of Teams Phone/Audio Conferencing licenses (e.g., 5 for 1-25 licenses, 20 for 50-99, 125 for 1,000-1,249; ported numbers do not count against limits)[^42]. Numbers are ordered with a service usage type rather than user numbers[^43]. |
| Zoom Phone | Requires account owner/admin permissions, toll-free licenses, and initial setup[^49]. | US/Canada port time is fixed at 11:30 am Eastern Time and cannot be changed[^50]. |

## See also

See also [Number porting and LNP workflows](https://warmtransfer.net/knowledge/number-porting).

## Applicability

Applies to: FCC 47 CFR Part 52 Subpart D, FCC 833 toll free auction (Auction 103), FCC 47 CFR 51.909, Somos TFNRegistry, Somos TFNRegistry ROC, Webex Calling - Cisco Calling Plans, Teams Phone - Microsoft Calling Plans, and Zoom Phone. Deployments: multi-tenant, registry, and regulatory. Sources checked 2026-09-24. Cisco Calling Plans limitations and Zoom Phone porting requirements apply to the US and Canada[^12][^49][^50]. The FCC regulations, Somos registry mechanisms, and 833 auction procedures apply to the US[^25][^29][^2].

## What remains uncertain

Resolving the Cisco Calling Plans toll-free availability contradiction is not covered by the sources below. Toll-free numbers on Webex Calling via Local Gateway or cloud-connected PSTN are not covered by the sources below. Toll-free SMS verification requirements in the US and Canada are not covered by the sources below. Toll-free numbers as caller ID and STIR/SHAKEN attestation are not covered by the sources below. TFNRegistry Functions Tariff fees and deposit amounts are not covered by the sources below. International toll-free service (ITFS/UIFN) under ITU-T E.169 is not covered by the sources below. Canadian toll-free administration and CRTC rules are not covered by the sources below. The origin of toll-free number portability rules is not covered by the sources below.

## Sources

[^1]: The FCC's 833 auction offered 17,638 toll free numbers in the 833 code. Source: [Auction of Toll Free Numbers in the 833 Code; Notice and Filing Requirements, Upfront Payments, and Other Procedures for the 833 Auction; Bidding Scheduled To Occur on December 17, 2019](https://www.govinfo.gov/content/pkg/FR-2019-09-26/html/2019-20526.htm), 84 FR 50767, Public Notice paragraph 8. Checked 2026-09-24.
[^2]: Bidding in the 833 toll free number auction (Auction 103) was scheduled for December 17, 2019. Source: [Auction of Toll Free Numbers in the 833 Code; Notice and Filing Requirements, Upfront Payments, and Other Procedures for the 833 Auction; Bidding Scheduled To Occur on December 17, 2019](https://www.govinfo.gov/content/pkg/FR-2019-09-26/html/2019-20526.htm), 84 FR 50767, title and paragraph 11. Checked 2026-09-24.
[^3]: The 833 auction procedures were adopted as FCC 19-75, published at 84 FR 50767 on September 26, 2019. Source: [Auction of Toll Free Numbers in the 833 Code ... FCC 19-75](https://www.gao.gov/fedrules/197023), GAO CRA entry 197023, fields FCC number, Fed. Reg. citation, Published. Checked 2026-09-24.
[^4]: The 833 auction was a single-round sealed-bid Vickrey auction in which each number's highest bidder wins and pays the second-highest bid. Source: [Auction of Toll Free Numbers in the 833 Code; Notice and Filing Requirements, Upfront Payments, and Other Procedures for the 833 Auction; Bidding Scheduled To Occur on December 17, 2019](https://www.govinfo.gov/content/pkg/FR-2019-09-26/html/2019-20526.htm), 84 FR 50767, Public Notice paragraph 116. Checked 2026-09-24.
[^5]: From July 1, 2023, toll free originating end office access moved to bill-and-keep and Toll Free Database Query Charges were cut to a transitional rate of no more than $0.0002 per query. Source: [47 CFR § 51.909 - Transition of rate-of-return carrier access charges](https://www.law.cornell.edu/cfr/text/47/51.909), 47 CFR 51.909(o). Checked 2026-09-24.
[^6]: From July 1, 2021, rate-of-return carriers had to reduce Toll Free Database Query Charges to no more than $0.004248 per query. Source: [47 CFR § 51.909 - Transition of rate-of-return carrier access charges](https://www.law.cornell.edu/cfr/text/47/51.909), 47 CFR 51.909(m). Checked 2026-09-24.
[^7]: The July 1, 2021 8YY step set transitional joint tandem switched transport access rates for toll free calls of no more than $0.001 per minute. Source: [47 CFR § 51.909 - Transition of rate-of-return carrier access charges](https://www.law.cornell.edu/cfr/text/47/51.909), 47 CFR 51.909(m). Checked 2026-09-24.
[^8]: A toll free number may remain in assigned status for at most 6 months before it must be converted to working status. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(c). Checked 2026-09-24.
[^9]: The FCC may assign toll free numbers by competitive bidding, first-come first-served, an alternative assignment method, or a combination of these. Source: [47 CFR § 52.111 - Toll free number assignment](https://www.law.cornell.edu/cfr/text/47/52.111), 47 CFR 52.111 (single-paragraph section), second sentence. Checked 2026-09-24.
[^10]: Toll free numbers assigned through competitive bidding may remain in reserved status indefinitely, unlike the 45-day limit for other numbers. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(b). Checked 2026-09-24.
[^11]: No person or entity may acquire a toll free number for the purpose of selling it to another person or entity for a fee. Source: [47 CFR § 52.107 - Hoarding](https://www.law.cornell.edu/cfr/text/47/52.107), 47 CFR 52.107(a). Checked 2026-09-24.
[^12]: Toll-free numbers cannot be ordered as a block under Cisco Calling Plans. Source: [Get Started with the Cisco Calling Plans](https://help.webex.com/en-us/article/nousk9ab/Get-Started-with-the-Cisco-Calling-Plan), Section 'Cisco Calling Plans requirements and limitations', U.S./Canada subsection (stated twice). Checked 2026-09-24.
[^13]: The Cisco Calling Plans article says toll-free numbers aren't currently available and that customers can neither order new toll-free numbers nor port existing ones to Cisco Calling Plans (disputed). Source: [Get Started with the Cisco Calling Plans](https://help.webex.com/en-us/article/nousk9ab/Get-Started-with-the-Cisco-Calling-Plan), Section 'Cisco Calling Plans requirements and limitations', general limitations list. Checked 2026-09-24.
[^14]: The 'Port in phone numbers' section of the Cisco Calling Plans article says existing numbers, including toll-free numbers, can be moved from the current PSTN carrier (disputed). Source: [Get Started with the Cisco Calling Plans](https://help.webex.com/en-us/article/nousk9ab/Get-Started-with-the-Cisco-Calling-Plan), Section 'Port in phone numbers'. Checked 2026-09-24.
[^15]: The Cisco Calling Plans article says toll-free numbers are available only for U.S. and Canada locations (disputed). Source: [Get Started with the Cisco Calling Plans](https://help.webex.com/en-us/article/nousk9ab/Get-Started-with-the-Cisco-Calling-Plan), Section 'Cisco Calling Plans requirements and limitations', U.S./Canada subsection. Checked 2026-09-24.
[^16]: A toll free number must remain in disconnect or transitional status for no less than 45 days and no more than 4 months, and extensions are not permitted. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(d). Checked 2026-09-24.
[^17]: Toll free numbers must be made available to RespOrgs and subscribers on an equitable basis. Source: [47 CFR § 52.111 - Toll free number assignment](https://www.law.cornell.edu/cfr/text/47/52.111), 47 CFR 52.111, first sentence. Checked 2026-09-24.
[^18]: The hoarding and brokering rules exempt toll free numbers assigned through competitive bidding, and certain transfers of such numbers. Source: [47 CFR § 52.107 - Hoarding](https://www.law.cornell.edu/cfr/text/47/52.107), 47 CFR 52.107(c). Checked 2026-09-24.
[^19]: Hoarding is a toll free subscriber acquiring from a RespOrg more toll free numbers than it intends to use to provide toll free service, and the rules prohibit it. Source: [47 CFR § 52.107 - Hoarding](https://www.law.cornell.edu/cfr/text/47/52.107), 47 CFR 52.107(a). Checked 2026-09-24.
[^20]: FCC rules define a toll free number as a telephone number for which the toll charges for completed calls are paid by the toll free subscriber. Source: [47 CFR § 52.101 - General definitions](https://www.law.cornell.edu/cfr/text/47/52.101), 47 CFR 52.101, definition of Toll free number. Checked 2026-09-24.
[^21]: Moving a US toll-free number between providers is carried out as a Resp Org Change in the Somos TFNRegistry rather than through the local number portability process (inferred). Source: [Empowering Toll-Free Businesses: Exploring Somos' Innovation with TFNRegistry Enhanced ROC Features](https://www.somos.com/insights/empowering-toll-free-businesses-exploring-somos-innovation-tfnregistry-enhanced-roc-features), Enhanced ROC Features article, overview (ROC as processing of Toll-Free Number change requests) and feature item 5 (porting requests). Checked 2026-09-24.
[^22]: A RespOrg may hold no more than the greater of 2000 toll free numbers or 7.5% of its working toll free numbers in reserved status. Source: [47 CFR § 52.109 - Permanent cap on number reservations](https://www.law.cornell.edu/cfr/text/47/52.109), 47 CFR 52.109(a). Checked 2026-09-24.
[^23]: When a RespOrg reserves a toll free number, the reservation serves as its certification that an identified subscriber has agreed to be billed for the number. Source: [47 CFR § 52.105 - Warehousing](https://www.law.cornell.edu/cfr/text/47/52.105), 47 CFR 52.105(d). Checked 2026-09-24.
[^24]: A toll free number may stay in reserved status for up to 45 days. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(b). Checked 2026-09-24.
[^25]: Under FCC rules a Responsible Organization (RespOrg) is the entity chosen by a toll free subscriber to manage and administer that subscriber's records in the toll free Service Management System. Source: [47 CFR § 52.101 - General definitions](https://www.law.cornell.edu/cfr/text/47/52.101), 47 CFR 52.101, definition of Responsible Organization. Checked 2026-09-24.
[^26]: As of November 2023, TFNRegistry ROC bulk upload supported up to 20,000 numbers through the API and 5,000 through the user interface. Source: [Empowering Toll-Free Businesses: Exploring Somos' Innovation with TFNRegistry Enhanced ROC Features](https://www.somos.com/insights/empowering-toll-free-businesses-exploring-somos-innovation-tfnregistry-enhanced-roc-features), Enhanced ROC Features article, feature list item 6 (Bulk Upload). Checked 2026-09-24.
[^27]: Somos began integrating Resp Org Change (ROC) processing into the TFNRegistry in November 2022. Source: [Empowering Toll-Free Businesses: Exploring Somos' Innovation with TFNRegistry Enhanced ROC Features](https://www.somos.com/insights/empowering-toll-free-businesses-exploring-somos-innovation-tfnregistry-enhanced-roc-features), Enhanced ROC Features article, overview section. Checked 2026-09-24.
[^28]: The Service Management System (SMS) database is the administrative database for toll free numbers, in which RespOrgs enter and amend number data that is shared with the regional Service Control Points. Source: [47 CFR § 52.101 - General definitions](https://www.law.cornell.edu/cfr/text/47/52.101), 47 CFR 52.101, definition of Service Management System database. Checked 2026-09-24.
[^29]: Somos's route to becoming a toll-free service provider (RespOrg) has three steps: an online application with a deposit, training (in person or self-directed), and passing an exam on industry practices. Source: [Become a Toll-Free Service Provider](https://www.somos.com/our-solutions/enduring-power-voice/modern-day-value-toll-free/become-toll-free-service-provider), Become a Toll-Free Service Provider page, process steps section. Checked 2026-09-24.
[^30]: When a toll-free number sits under an xxx99 Resp Org ID, any completed Resp Org Change triggers an email and phone alert to the controlling Resp Org; Somos describes this ID for critical numbers such as government agencies and hospitals. Source: [Staying Organized with Resp Org IDs](https://www.somos.com/insights/staying-organized-resp-org-ids), Staying Organized with Resp Org IDs, paragraph on the xxx99 Resp Org ID. Checked 2026-09-24.
[^31]: A RespOrg may not reserve more than 3% of the toll free numbers available in spare status, measured weekly. Source: [47 CFR § 52.109 - Permanent cap on number reservations](https://www.law.cornell.edu/cfr/text/47/52.109), 47 CFR 52.109(b). Checked 2026-09-24.
[^32]: A toll free number is in assigned status when the RespOrg has entered subscriber routing information in the SMS database and activation in the Service Control Points is pending. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(a)(1). Checked 2026-09-24.
[^33]: A toll free number is in disconnect status when service has been discontinued and an exchange carrier intercept recording is being provided. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(a)(2). Checked 2026-09-24.
[^34]: A toll free number is in reserved status when a RespOrg has reserved it from the SMS database for a toll free subscriber. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(a)(4). Checked 2026-09-24.
[^35]: A toll free number in spare status is available for assignment by a RespOrg. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(a)(6). Checked 2026-09-24.
[^36]: A toll free number is in suspend status when its service has been temporarily disconnected and is scheduled to be reactivated. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(a)(7). Checked 2026-09-24.
[^37]: Transitional status covers toll free numbers disconnected for less than four months for which no exchange carrier intercept recording is being provided. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(a)(10). Checked 2026-09-24.
[^38]: A toll free number in unavailable status cannot be assigned because of an unusual condition. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(a)(8). Checked 2026-09-24.
[^39]: A toll free number is in working status when it is loaded in the Service Control Points and is being used to complete toll free calls. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(a)(9). Checked 2026-09-24.
[^40]: A toll free number may remain in suspend status until it is changed to working status or for a maximum of 8 months, whichever comes first. Source: [47 CFR § 52.103 - Lag times](https://www.law.cornell.edu/cfr/text/47/52.103), 47 CFR 52.103(e). Checked 2026-09-24.
[^41]: Microsoft Teams Calling Plans require pay-as-you-go billing (Communications Credits) to reserve and use toll-free phone numbers. Source: [Get Microsoft Calling Plan telephone numbers for your organization](https://learn.microsoft.com/en-us/microsoftteams/manage-phone-numbers), Section 'How many telephone numbers can you get?', Toll-free service number row and the Important note below the table. Checked 2026-09-24.
[^42]: Microsoft grants toll-free service numbers in tiers by the count of Teams Phone and/or Audio Conferencing licenses, for example 5 numbers for 1-25 licenses, 20 for 50-99 and 125 for 1,000-1,249; ported numbers do not count against the limit. Source: [Get Microsoft Calling Plan telephone numbers for your organization](https://learn.microsoft.com/en-us/microsoftteams/manage-phone-numbers), Section 'How many telephone numbers can you get?', Toll-free service number row and the Important note above the table. Checked 2026-09-24.
[^43]: In the Teams admin center, toll-free numbers from Microsoft are ordered with a service usage type (Dedicated conference bridge (Toll Free), Call Queue (Toll/Toll Free) or Auto Attendant (Toll/Toll Free)) rather than as user (subscriber) numbers. Source: [Get Microsoft Calling Plan telephone numbers for your organization](https://learn.microsoft.com/en-us/microsoftteams/manage-phone-numbers), Section 'Get new phone numbers', step 5.2 (Number type). Checked 2026-09-24.
[^44]: The Toll Free Numbering Administrator (TFNA) is the entity appointed by the FCC to administer the toll free SMS database day to day and provide user support for it. Source: [47 CFR § 52.101 - General definitions](https://www.law.cornell.edu/cfr/text/47/52.101), 47 CFR 52.101, definition of Toll Free Numbering Administrator. Checked 2026-09-24.
[^45]: Warehousing is a RespOrg, directly or through an affiliate, reserving toll free numbers from the SMS database without an actual toll free subscriber for whom they are reserved. Source: [47 CFR § 52.105 - Warehousing](https://www.law.cornell.edu/cfr/text/47/52.105), 47 CFR 52.105(a). Checked 2026-09-24.
[^46]: A rebuttable presumption of warehousing arises if a RespOrg lacks an identified subscriber agreeing to be billed for a reserved number, or lacks an identified billed subscriber before switching a number to working status. Source: [47 CFR § 52.105 - Warehousing](https://www.law.cornell.edu/cfr/text/47/52.105), 47 CFR 52.105(b). Checked 2026-09-24.
[^47]: Zoom's Technical Library porting guide says toll-free port request attachments must be dated within the last 30 days, and that the request is submitted as a support ticket (disputed). Source: [US, Canada, and Puerto Rico Porting (Number Porting and Management Field Guide)](https://library.zoom.com/zoom-workplace/zoom-phone/number-porting-and-management-field-guide/us-canada-and-puerto-rico-porting), Section 'How to Request a Toll-Free Number Port'. Checked 2026-09-24.
[^48]: Zoom's US/Canada toll-free port article requires the uploaded invoice to be dated within the last 90 days (disputed). Source: [Requesting a toll-free number port (US, Canada)](https://support.zoom.com/hc/en/article?id=zm_kb&sysparm_article=KB0064099), Section 'How to request a toll-free number port for the US or Canada'. Checked 2026-09-24.
[^49]: Porting a US or Canada toll-free number to Zoom Phone requires account owner or admin permissions, Zoom toll-free phone licenses, and completed Zoom Phone initial setup. Source: [Requesting a toll-free number port (US, Canada)](https://support.zoom.com/hc/en/article?id=zm_kb&sysparm_article=KB0064099), Section 'Requirements for requesting a toll-free number port for the US or Canada'. Checked 2026-09-24.
[^50]: Zoom sets the port time for US/Canada number ports at 11:30 am Eastern Time, and it cannot be changed. Source: [Requesting a toll-free number port (US, Canada)](https://support.zoom.com/hc/en/article?id=zm_kb&sysparm_article=KB0064099), Toll-free port article, FAQ / timing note. Checked 2026-09-24.