Telecom - Staff Letter addressed to the Distribution List
Gatineau, 12 August 2025
Reference: 8695-J92-202402163
BY E-MAIL
Distribution List
Subject: Application to increase the $10 million minimum threshold for participation in the contribution regime and payment of telecommunication fees, request for information
On 30 April 2024, the Independent Telecommunications Providers Association (ITPA) filed an application requesting an increase to the $10 million revenue threshold, established in Telecom Decision CRTC 2000-745.
The minimum revenue threshold triggers participation in the Commission’s National Contribution Fund (NCF) and payment of annual telecommunications fees (Annual Telecom Fees) under the Telecommunication Fee Regulations, 2010 (the Regulations).
Section 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may request parties to file information, particulars or documents where needed.
Commission staff has reviewed the record of the proceeding and has concluded that further inquiry is necessary.
Staff is seeking input from impacted telecommunication service providers (TSPs)Footnote 1, as well as all intervenors, on a potential revenue threshold increase to either $25 million, $50 million, or $100 million.
As such, parties are requested to provide comprehensive answers, including rationale and supporting information, to the request for information by 12 September 2025. Given that the distribution list for this letter is confidential, Commission staff does not expect parties to provide copies of their responses to requests for information (RFIs) to other parties. Instead, the Commission will post all responses to the public record of this proceeding. Parties will therefore be required to consult the public record of this proceeding to obtain copies of responses received.
The NCF administrator calculates amounts owing for each TSP, issues invoices and collects all payments on a monthly basis. The amount charged is based on the annual revenue percent charge decision issued by the CRTC each year in the fall. Annual Telecom Fees are paid on an annual basis. Invoices are issued in late spring by the CRTC and payments are due within 30 days. Annual Telecom Fee amounts are based on a Telecom Order issued in the spring of each year which outlines the revenue percent that will be collected.
Under the current $10 million revenue threshold, 129 TSPs or 80 groups of related TSPs contribute to the NCF and Annual Telecom Fees. In 2025, TSPs will contribute $184.7 million to the NCF which is equal to 0.46% of contribution-eligible revenues of all TSPs that are required to contribute. For the 2025-2026 fiscal year, $61.1 million in Annual Telecom Fees were paid by TSPs.
The impacts of the thresholds being considered are summarized below.
Impact of a $25 million threshold based on 2024Footnote 2 figures:
- 42 of the 129 TSPs (or 32 of the 80 groups) generate between $10M and $25M
- These companies/groups make up 0.73% of the NCF contributions and Annual Telecom Fees paid, which represents $1,345,432 in NCF and $444,677 in Annual Telecom Fees ($1,790,110 total), which would need to be recovered by the remaining 87 TSPs (or 48 groups)
- Making up 0.73% of the $184.7M collected for the NCF, the revenue percent charge would have increased to 0.47% in 2024.
Impact of a $50 million threshold based on 2024 figures:
- 75 of the 129 TSPs (or 54 of the 80 groups) generate between $10M and $50M
- These companies/groups make up 1.90% of the NCF contributions and Annual Telecom Fees paid, which represents $3,501,816 in NCF and $1,157,382 in Annual Telecom Fees ($4,659,198 total), which would need to be recovered by the remaining 54 TSPs (or 26 groups)
- Making up 1.90% of the $184.7M collected for the NCF, the revenue percent charge would have increased to 0.47% in 2024.
Impact of a $100 million threshold based on 2024 figures:
- 89 of the 129 TSPs (or 61 of the 80 groups) generate between $10M and $100M
- These companies/groups make up 2.54% of the NCF contributions and Annual Telecom Fees paid, which represents $4,684,833 in NCF and $1,548,379 in Annual Telecom Fees ($6,233,212 total), which would need to be recovered by the remaining 40 TSPs (or 19 groups)
- Making up 2.54% of the $184.7M collected for the NCF, the revenue percent charge would have increased to 0.48% in 2024.
Request for information
- Comment on each of the proposed scenarios, with a focus on the impact each scenario may have on your business or on the businesses of your members (for example in the case of industry associations).
- Comment on potential implications related to each scenario were these thresholds to be implemented for the upcoming fiscal year.
If there is another scenario that should be considered, please provide a detailed description of the scenario, including the supporting rationale and the potential impact it would have on the number of TSPs required to contribute to the NCF and Annual Telecom Fees, and the potential impact on NCF and Annual Telecom Fees collected.
Interested persons and parties may file interventions on requests for information or responses to requests for information by 26 September 2025. The applicant may file its reply to new information on record by 3 October 2025. The Commission will also consider 3 October 2025 to be the close of record for issues considered in this Part 1 application. Where a document is to be filed or served by a specific date, the document must be received, not merely sent, by that date.
As set out in section 39 of the Telecommunications Act and in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin CRTC 2010-961, 23 December 2010, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.
The Commission requires that you submit your documents electronically using the secured service “My CRTC Account” (Partner Log In or GCKey) and fill in the “Broadcasting and Telecom Cover page” located on this web page. On this web page, you will also find a link to information on the submission of applications to the Commission “Submitting applications and other documents to the CRTC using My CRTC Account.”
A copy of this letter and all related correspondence will be added to the public record of the proceeding.
Thank you for your time and consideration.
Yours sincerely,
Ian Baggley
Director General, Strategic Planning, Broadband Fund and Networks
Telecommunications
c.c.: Michael Bergeron, CRTC, michael.bergeron@crtc.gc.ca
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