At Award Consulting, part of our mission is to be your guide through the ever-evolving telecom landscape. While the issue we’re discussing today isn’t critical just yet, we believe it’s important to keep you in the loop – and we’ll continue to share updates about this issue as the situation evolves in the future. If this becomes a pressing concern, you’ll already be aware of what’s going on – and we’ll help you navigate it.
What’s Going On?
The FCC has released a Notice of Proposed Rulemaking (NPRM) to explore a possible future where incumbent LECs (like AT&T, Verizon, and Lumen) are no longer required to offer TDM-based tandem interconnection. They’ve floated a date of December 31, 2028.
This is not a rule – it’s just a proposal asking for public comment. The idea is to encourage the industry to move toward all-IP voice interconnection by removing the legal requirement for TDM-based interconnects.
In practice, even after this date, these carriers could still offer TDM interconnection if they wish, but they would no longer be obligated to do so. This would give the RBOCs the option of retiring their TDM tandems, to be replaced by an IP-based alternative.
What Might Change?
If the proposal is adopted (and that’s a big IF), it would:
- Lift the current obligation on incumbent LECs to support TDM tandem interconnection after Dec 31, 2028.
- Allow (but not require) the deployment of IP-only tandems.
Of course, a potential change like this sparks a lot of questions – perhaps most important is the question of POIs (points-of-interconnect). If the tandem becomes an IP switch, then where is the IP interconnect between the residential service provider (you) and the tandem operator, and who is responsible for the transport costs.
With this notice, the FCC is asking for feedback, and they’re very interested to hear arguments about how many POIs should be provided, how to avoid unfair cost burdens for smaller or rural carriers, and what guardrails are needed to ensure fair access.
What This Means for You
Today? Nothing.
It’s a potential change in the rules, and it would only impact you if it became law AND if the tandem operators decided to switch to IP-only tandems. So for today – read this email, and then you can forget about it until the FCC publishes all the feedback they receive. (I assume that groups like the NTCA will be providing strong feedback representing your interests.)
If this were to become law, and the the tandem operators started offering IP only tandems, then this could be very positive for small rural carriers – you might no longer need any SS7 signaling infrastructure, ISUP trunks or media gateways. So you could simplify your networks and reduce the costs – provided the IP transport costs to the POIs don’t undo all those positive benefits.
However – don’t expect anything to happen quickly. This is a long-term shift. Even if this rule is finalized in 2026, we’d be surprised to see any meaningful impact until well into the 2030s. Turning down all the TDM tandems, provisioning new IP POIs, and migrating trunks is a massive undertaking – and big telcos tend to move slowly.
Does This Mean Everyone’s Moving to the Cloud?
Not necessarily.
While it’s true that all-IP interconnection (if it happens) would remove a lot of the current challenges with cloud-hosted switching, a move to the cloud still involves significant architectural decisions, operational changes, and financial trade-offs. For some providers, it might become an attractive option down the road, but there’s certainly no need to rush.
We continue to believe that cloud infrastructure has both pros and cons, and we advise evaluating any such transition carefully, with a clear understanding of your specific needs and constraints.
What do we need to do right now?
Nothing. This proposed rule change from the FCC is one to watch, not one to panic over.
We’re at the very beginning of a regulatory process – comments, revisions, and more will follow – and even if the rules are updated, the impact will unfold slowly over many years.
At Award Consulting, we’ll continue monitoring developments, analyzing what they mean for regional service providers, and keeping you informed – so you’re ready to act if and when the time is right.
