What is an International 214 License?
And Who Needs One?
The Federal Communications Commission (FCC) requires
any person that provides telecommunications services
to or from the United States to receive an authorization
under Section 214 of the Communications Act of 1934.
This authorization is called an International Section
214 Authorization, or, commonly, an International 214
License. The definition of "telecommunications
services" is very broad and includes private line,
switched long distance, prepaid services, calling cards,
VOIP services and many similar services. Whether you
resell the telecommunications services of another company
or provide services using your own facilities, you will
need the International 214 Authorization.
Frequently Asked Questions
Why should I use an attorney to obtain my International
214 License from the FCC?
Attorneys at Thomas Lynch & Associates have filed hundreds
of applications with the FCC for the International 214
License. As a result, we are very familiar with the
FCC's filing requirements and understand the regulations.
We also know the FCC staff and the staff of the Department
of Homeland Security that reviews the applications.
To date, every one of our applications has been granted.
That includes applications with foreign ownership. Most
are granted within two to three weeks. If you review
the applications that have been filed by others, including
those that advertise heavily, you will find that some
have taken six or more months to be processed. And others
are still not granted after more than a year.
Be careful when choosing someone to assist with your
application. We have the experience, the contacts and
the track record to get your application granted --
promptly and affordably.
How long does it take to get an International 214
License from the FCC?
If the application qualifies for "streamlined
processing," and there is no objection to the application,
either by individuals, entities or other branches of
the government, the application will be granted after
14 days on public notice and a notice of the grant will
be published by the FCC. If the application does not
qualify for streamlined processing (because of certain
foreign affiliations, for example), there is no time
frame during which the FCC must process the application.
Most applications submitted by our firm qualify for
streamlined processing and are granted within 20 days
after you contact us (see below for how to begin the
process). Note, however, that applications with foreign
ownership are being heavily scrutinized by the Department
of Homeland Security because of 9/11. If your company
has 10% or more foreign ownership, call Mr. Lynch at
Thomas Lynch & Associates for more information.
How much does it cost to get an International 214
The FCC charges a filing fee of $1,130. Brennan Lynch
charges a flat fee of $550 to prepare the application
and prosecute it at the FCC if you have foreign ownership
less than 10%. Therefore the total is $1,680. If you
have foreign ownership of 10% or more, the legal fees
are $950, making the total $2,080. Our flat-rated fees
are among the lowest offered for expert assistance and
reflects the firm's efficiency and experience in filing
and prosecuting Section 214 applications. In addition,
if you obtain your International 214 Authorization
through Thomas Lynch & Associates, you will receive
a comprehensive table of common regulatory requirements
that includes a summary of the requirement, the code
section applicable and the due date for any associated
filing. The table also contains many web links to
manuals and other helps in satisfying the regulatory
requirements. This table was developed by our firm and
is free for our 214 clients. It is worth hundreds of
dollars of legal time (we sell the table individually
for $550) and is an added value that is not available
Once I have my International 214 License, what regulatory
The regulatory requirements that apply to a telecommunications
provider depend on the type of service offered. For
almost all carriers, the most time consuming and expensive
regulatory obligation involves the Universal Service
Fund (USF) and its associated Form
499 filings (499-A and 499-Q). Other regulations
include Circuit Status Reports, the Regulatory Fee filing
and the International Telecommunications Traffic Report.
But these obligations do not apply to all service providers.
If you obtain your International 214 Authorization through
Thomas Lynch & Associates, you will receive a comprehensive
table of common regulatory requirements that includes
a summary of the requirement, the code section applicable
and the due date for any associated filing. The table
also contains many web links to manuals and other helps
in satisfying the regulatory requirements. This table
was developed by Mr. Lynch and is free for his 214 clients.
It is worth hundreds of dollars of legal time (we sell
the table individually for $550) and is an added value
that is not available from others. If you need assistance
with making regulatory filings, we can assist you in
all aspects of compliance. For more information about
the most important filing, the 499A, please click here.
I want to provide services using Voice-over-IP (VOIP).
Do I need an International 214 License from the FCC?
The short answer is yes. The FCC does not presently
regulate VOIP the way it regulates circuit-switched
services, but the FCC requires VOIP providers to comply
with certain regulations that apply to traditional phone
service, such as E911 and law-enforcement requirements
under CALEA. The FCC also decided that VOIP providers
must pay into the Universal Service Fund. Although previously
the FCC had taken the position that an international
214 license was not required for VOIP providers, in
a 2008 decision it was determined that VOIP providers,
and even wholesale VOIP providers, are providers of
"telecommunications services" and are subject
to many additional regulations - including the international
214 license requirements.
Do I need a license from a state as well as from
The type of service you provide will determine whether
a state's regulatory requirements apply. Generally,
if you are only providing international services, or
services between states, state registration is not necessary.
But the regulatory requirements of each state are different
and you must check to make sure, especially if you are
providing prepaid or calling card services. We can assist
you with state filings as well. Click here
for more information.
Do I need to cancel my 214 license if I am no longer
Click here for more information.