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Compliance EngineeringTelecommunications10 min read · 2026-06-09

MVNO Engineering: Building a Mobile Virtual Network That Satisfies FCC and State PUCs

CALEA
Lawful intercept obligation applies to MVNOs — MVNE must hold an FCC-approved technical solution
A Mobile Virtual Network Operator carries all the regulatory obligations of a full facilities-based carrier without owning any spectrum or radio infrastructure. FCC CPNI (Customer Proprietary Network Information) rules under 47 CFR Part 64, Subpart U apply directly to MVNOs. CALEA (Communications Assistance for Law Enforcement Act) requires that MVNO systems support lawful interception — the MVNE must have a CALEA solution approved by the FCC. Local Number Portability (LNP) obligations, E911 subscriber location requirements, and state PUC tariff or registration requirements vary by state. The commercial architecture of an MVNO (light MVNO, enhanced MVNO, or full MVNO) determines where the compliance boundaries sit between the MVNO and its hosting MNO.

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