Issues of note, as pointed out by Atty. JJ Disini:
- VoIP service providers are to have paid-up capitalization of at least PhP 10 million.
- Each VoIP service provider is to post a performance bond of PhP 5 million, while resellers are to post a bond of PhP 1 million.
(In contrast, existing telcos are not subjected to the capitalization requirements.)
Atty. Disini also raised telco interconnectivity and preferential treatment concerns. After all, it’s the big players who have the legal muscle and the big bucks to control the game, if left unwatched (remember the Globe-Smart SMS and PLDT-Bayantel landline interconnectivity issues?).
Another observation, from my end: the last statement stipulates,
All VoIP calls/traffic, outgoing and incoming, shall pass through duly registered/authorized VoIP service providers.
Will this apply to end-users using free VoIP applications/protocols such as Skype, FWD, Google Talk? If so, then I would be breaking the law if I were to use Skype to call abroad using VoIP. Will the ISP I’m using to make/receive such calls be liable if they are not a registered VoIP service provider or re-seller (inasmuch as it is not the use of VoIP is not actually what I’m paying form but the connectivity)? Will someone/anyone be liable for receiving a call on his/her landline or mobile that originated from a VoIP terminal or client such as SkypeOut?
Here’s a link to an inq7.net report on the Guidelines, which cites,
The entry of fly-by-night VoIP providers had been one of the concerns raised by Internet Service Providers and telecommunications companies, NTC Deputy Commissioner Jorge Sarmiento had previously told INQ7.net.