telecommunications regulatory consulting on de-tariffingOne of my responsibilities as an Associate Consultant at Technologies Management, Inc. is to ensure that our client’s tariffs are compliant with federal and state rules and regulations. This includes preparing revisions to implement any changes. As more and more states are relaxing the requirements for tariff filings and/or allowing optional or voluntary detariffing, it has become somewhat of a dilemma for carriers as to whether they should keep a tariff on file with the Commission or withdraw it.


At first, it may seem like a great option to withdraw the tariff and be done with the updating and filing of the sometimes cumbersome revisions as rules, services, or rates change. However, a tariff functions as much more than what it seems to be at first sight – a large voluminous bundle of paper. It provides a protection for the carrier. A tariff sets forth the carrier’s terms, rules, regulations, services, and rates and is in essence a contract between the carrier and the customer. Should the carrier withdraw this document and a dispute between a customer and a carrier arise, the void of not having a tariff on file with the Commission may leave more room for challenge and liability.


Certain states where tariffs are no longer maintained on file with the Commission may still require the carrier to post a price list on the carrier’s website. Even if public posting is not a requirement, it makes good business sense to maintain a publicly posted price list. This benefits not only the customer, but the carrier itself as it may serve as a valuable comprehensive document for the carrier’s in-house staff. It defines, at a glance, what the customer may expect from the carrier and what the carrier expects from the customer, as well as which services, rates, and promotions the carrier is currently offering.



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