FINAL REMINDER: Section 64.1900 Geographic Rate Averaging Certification due May 1st


The deadline for filing the Geographic Rate Averaging Certification (“Certification”) with the Federal Communications Commission (“FCC”) is May 1st.

All providers of interstate long-distance services, including services sold exclusively on a prepaid basis, are required to file this annual Certification with the FCC.  The Certification must be signed, under oath, by an officer of the company.

Section 64.1900 of the FCC‘s rules requires that all non-dominant providers of interexchange service providers (e.g. providers of de-tariffed interstate, domestic interexchange telecommunications service) must file with the FCC a certification that it is providing such service in compliance with its statutory geographic rate averaging and rate integration obligations under Section 254(g) of the Communications Act.

Geographic rate averaging and rate integration, as defined under Section 64.1801 of the FCC‘s rules, mandates that:

  • The rates charged by providers of interexchange telecommunications services to subscribers in rural and high-cost areas shall be no higher than the rates charged by each such provider to its subscribers in urban areas.
  • A provider of interstate interexchange telecommunications services shall provide such services to its subscribers in each U.S. state at rates no higher than the rates charged to its subscribers in any other state.


Due to stepped up enforcement of reporting obligations by the FCC‘s Enforcement Bureau, we are urging clients subject to the Section 64.1801 geographic rate averaging and Section 64.1900 annual Certification requirements to be particularly diligent with this and all other required FCC regulatory filings.

This Client Alert merely outlines the FCC‘s Certification requirements and upcoming deadline and does not provide specific legal guidance. As with many regulatory requirements, geographic rate averaging is not as simple a concept as it might appear.  The Certification must be signed under oath, therefore, clients who are uncertain about whether their domestic, interstate rate structure satisfies the geographic rate averaging and rate integration obligations should contact our firm immediately.

Due to the immediacy of the pending deadline, clients who require a legal opinion concerning compliance with Section 64.1801 of the FCC‘s rules prior to signing the annual Certification under oath should contact Chris Canter at or Jonathan Marashlian at

ATTORNEY ADVERTISING DISCLAIMER: This information may be considered advertising in some jurisdictions under the applicable law and ethical rules. The determination of the need for legal services and the choice of a lawyer are extremely important decisions and should not be based solely upon advertisements or self-proclaimed expertise. No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers

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