Regulatory facts last verified 26 October 2026.
A mobile virtual network operator (MVNO) sells mobile service under its own brand on another operator’s radio network. In the US you do not need spectrum or a wireless license to start one. You get network access on AT&T, T-Mobile or Verizon, directly or through a partner, register with the FCC, set up SIMs, billing and support, and file recurring reports.
Most companies that ask this already have customers. Think of a device maker that wants to sell a plan with its hardware, an MSP or internet provider adding mobile lines, or a software platform that wants connectivity inside its product. For them the fastest US path is usually a light MVNO on an MVNE. This guide covers the three models, who files what with the FCC under each one, the timeline and what Spenza’s US launches looked like. It is a planning map, not legal advice.
How do you start an MVNO in the US?
To launch an MVNO in the US, define your customers and service, choose an operating model, secure wholesale network access and assign regulatory responsibilities. Then connect provisioning, billing and support, check the economics and run a controlled pilot before opening the service to more customers. In order:
- Decide what you will sell, to whom and on which devices.
- Choose an operating model: branded reseller, light MVNO or full MVNO.
- Get access to AT&T, T-Mobile or Verizon, directly or through an MVNE or aggregator.
- Map your FCC and state obligations, starting with one question: will you sell voice?
- Set up SIMs and eSIMs, number porting, billing, taxes and a self-service portal.
- Certify the devices you sell, if you sell hardware.
- Price plans after taxes and wholesale costs, then pilot on real devices and launch.
The opportunity if you already have customers
The hard part of a new mobile brand is acquiring subscribers. A company with an existing audience has already paid that cost: it has the distribution, the billing relationship and the support team. Adding mobile turns a one-time sale or a service contract into recurring connectivity revenue, and it keeps the customer inside your product instead of sending them to a carrier store. An existing audience gives you a distribution route, but demand and willingness to pay still need testing with real buyers.
Which of these are you?
| If you are | You would sell | Usual starting model | What matters most |
|---|---|---|---|
| A device maker (OEM) | A data plan sold with the device, often in one checkout | Light MVNO, often data-only | Device certification, eSIM, plans priced for the device (connected devices) |
| An MSP or internet provider | Mobile lines bundled with existing IT or broadband service | Branded reseller or light MVNO | Reseller billing, porting, one invoice (ISP to MVNO) |
| A software platform | Connectivity inside your app, sold as a subscription | Light MVNO through an API | Provisioning API, embedded checkout, usage data |
| A corporate group | Employee and subsidiary lines under your own brand | Branded reseller or light MVNO | Consolidated billing, spend limits, policy control |
| A new consumer brand | Retail mobile plans | Light MVNO | Customer acquisition, porting, support at scale |
Choose your MVNO model: what you own and what you rent
The three models differ in how much of the stack you run. An MVNE (mobile virtual network enabler) is the platform layer in the middle: it supplies provisioning, billing and the carrier integrations so you do not build them. Our guide to MNO, MVNO, MVNE and MVNA roles defines each party.
| Model | You own | You rent | Time to launch | Choose this if |
|---|---|---|---|---|
| Branded reseller | Brand, marketing, sales, often first-line support | Network, SIMs, billing platform and the carrier of record | Weeks | Mobile is an add-on and you want the least operational work. See white-label MVNO options |
| Light MVNO (on an MVNE) | Brand, plans and pricing, invoices, the customer relationship and your own FCC registration | Radio and core network from the host; OSS, BSS and integrations from the MVNE | Weeks to a few months | You want control of pricing and the customer experience without running a core network |
| Full MVNO | Core network, SIM ranges (IMSIs), OSS and BSS, all compliance | Radio network from the host | 12 to 18 months | Network control is part of your product and you have the capital and a telecom team |
The cost gap between the models is roughly an order of magnitude at each step. The MVNO launch cost breakdown itemizes each tier, and the MVNO launch cost calculator lets you model your own numbers. The OSS and BSS layer the MVNE supplies is explained in OSS and BSS in telecom.
Get network access: AT&T, T-Mobile or Verizon
The US has three national mobile networks: AT&T, T-Mobile and Verizon. There are three ways to reach them:
- Direct wholesale agreement. You negotiate with the carrier. Expect a business plan, volume forecasts, minimum commitments or deposits, and a long technical integration. In our experience the negotiation alone takes 6 to 12 months.
- Through an aggregator (MVNA). An aggregator holds the carrier contract and resells capacity to smaller MVNOs.
- Through an MVNE. The enabler already holds carrier agreements and integrations, so you sign one contract and configure plans on its platform.
Before you sign, ask which services the access includes (voice, texting, data, 5G), which devices are eligible, what the wholesale rate card and minimums are, who handles escalations and what happens to your lines if you leave. Access to two networks protects coverage and gives you a fallback, which is why IMZ launched on both T-Mobile and Verizon.
If you sell hardware, plan for device certification early. Cellular devices need FCC equipment authorization, most carriers expect industry certification such as PTCRB or GCF, and some networks, Verizon among them, require their own certification as well. For device makers this is often the slowest item on the plan.
US compliance: who files what
There is no single “MVNO license” in the US. There is a set of registrations and recurring filings. Two questions decide which apply to you: do you sell voice, and who is the carrier of record? The carrier of record is the company legally responsible for the service.
Voice or data-only?
Plans with calling bring most of the federal telecom rules into play. Data-only plans, common for IoT devices and tablets, carry a much shorter list, and the federal Internet Tax Freedom Act shields internet access from state and local taxes. Adding voice to a bundle brings back the full regulatory list, while the internet access part can stay tax-exempt if you can separate it in your books. Have counsel confirm how each of your plans is classified.
The obligations
| Obligation | Applies if | Timing | Rule |
|---|---|---|---|
| FCC registration: FRN in CORES, USAC Filer ID, agent for service of process in Washington, DC | You provide telecom service, including resold voice | Within 30 days of starting service | Form 499-A instructions, Table 2 |
| Form 499-A revenue report and Universal Service Fund contributions | You provide telecom service; resellers must file. If your estimated annual contribution is under $10,000 (de minimis), you do not contribute directly but may still need to file | April 1 every year | Form 499-A instructions |
| CPNI: protect customer account data and certify compliance | You sell voice | Officer certification by March 1; authenticate customers before discussing account details | 47 CFR 64.2009, 64.2010 |
| Robocall Mitigation Database: STIR/SHAKEN status certification and a robocall mitigation plan with your know-your-customer process | You resell voice | Before carrying calls; recertify by March 1; update within 10 business days of changes | FCC Enforcement Advisory 2026-02 |
| 911 and enhanced 911 access; sell only E911-capable handsets | You sell voice | Before launch | 47 CFR 9.10, paragraph (p) |
| Number porting | You assign phone numbers | Simple wireline and intermodal ports within one business day; wireless-to-wireless ports follow faster industry practice | 47 CFR 52.35 |
| International Section 214 authorization (global resale) | Your plans include international calling | Before offering international service | 47 CFR 63.18 |
| Broadband consumer label for each plan | You sell mobile data plans to consumers | At the point of sale | FCC broadband labels |
| State registrations, taxes and 911 fees | You sell in that state | Varies; California requires a CPUC Wireless ID Registration ($265 fee, adjusted each year for inflation) | CPUC registration |
Two more points come up in every launch review. There is no federal SIM registration law, but CPNI rules require you to authenticate customers before discussing their accounts, and the robocall rules expect voice providers to know their customers. The FCC also adopted SIM swap and port-out fraud protections in November 2023. Their compliance date was tied to federal paperwork review, so check the current status, and build strong authentication into SIM changes and port-outs from day one.
Who files under each model on Spenza
| Model | Federal registrations and filings | What you still own |
|---|---|---|
| Branded reseller on Spenza | Spenza or its carrier partner acts as carrier of record, contracts with and bills the end customer, and carries the federal registrations and filings. If you resell voice in your own name, you file too | Brand, sales and first-line support, following the carrier of record’s customer-data and authentication procedures |
| Light MVNO on Spenza | You are the carrier of record and file in your own name | The filings. Spenza supplies the revenue, usage and customer records they depend on, calculates and remits telecom taxes, prepares regulatory reports and runs porting operations |
| Full MVNO | You register and file | Everything above, plus network-facing duties for your own core |
For more detail, including CALEA lawful-intercept duties and state rules, see our guide to MVNO regulatory requirements.
Not legal advice This map shows which rules to review and who usually handles them. Your contracts define the final split, and telecom counsel should confirm it before you sell. The deadlines above were checked against FCC and state sources on 26 October 2026.
Build the stack: SIMs, eSIM, porting, billing and taxes
| Component | What it does | Notes for a US launch |
|---|---|---|
| eSIM and physical SIM | Delivers the subscriber profile to each device | US models of the iPhone 14 and later are eSIM-only, so eSIM activation is required. Keep physical SIMs for older phones and many IoT devices. See remote SIM provisioning |
| Number porting | Moves customers’ existing numbers in and out | The main conversion lever for consumer and business lines. Protect port-outs with strong authentication |
| Billing and rating | Prices usage, issues invoices, handles prepaid and postpaid | Needs real-time usage for allowances, plus reseller billing if partners sell for you. Compare MVNO billing platforms |
| Tax engine | Calculates federal, state and local taxes and fees per line | Taxes and fees add about 28.8 percent to a typical bill, according to the Tax Foundation’s 2026 study, so this blocks launch if missing |
| Self-service portal and checkout | Purchase, activation, top-ups, usage and porting | Can start white-labeled and become a native app later |
| Support and monitoring | Handles activation failures, outages and billing disputes | Needs an escalation path into the host network |
For a vendor checklist of this layer, use the OSS/BSS checklist: 10 questions before you sign an MVNE.
Price for margin after tax
Work out contribution per line before you publish a price. Start with the plan price excluding pass-through taxes, then subtract the wholesale network cost, platform fees, payment fees, support and any channel commission. Divide your acquisition cost by that monthly contribution to get payback in months. Then decide how you show taxes. At the national average, a $25 plan reaches the customer at about $32 after taxes and fees, and that gap drives churn when it comes as a surprise.
Model heavy users as well as typical ones, and check the cash timing: deposits and minimum commitments can leave you paying the network before customers pay you. Unbilled lines and carrier invoice errors are where margins leak, so read our list of telecom revenue leaks in MVNO billing before launch.
Launch timeline
These are Spenza’s planning ranges for the work that blocks a first activation. The MVNE path is shorter because carrier access, the platform and SIM provisioning already exist.
| Workstream | Full MVNO, built yourself | Light MVNO on an MVNE |
|---|---|---|
| Wholesale network agreement | 6 to 12 months | Days to weeks |
| OSS and BSS platform | 6 to 18 months | 1 to 2 weeks to configure |
| SIM and eSIM provisioning | 2 to 4 months | 1 to 2 weeks |
| Number ranges and porting | 2 to 6 weeks | Included through the MVNE |
| FCC and state registrations | 4 to 8 weeks as your own carrier of record | 4 to 8 weeks as your own carrier of record; none for a branded reseller |
| Robocall, messaging and KYC setup (voice and texting) | 2 to 4 weeks | 2 to 4 weeks, with the MVNE’s tooling |
| Pilot on real devices | 2 to 4 weeks | 2 to 4 weeks |
| Typical total | 12 to 18 months | Weeks to a few months |
What the pilot must prove
Run the pilot on the devices you will sell, with a small group of real customers. Before opening sales, check:
- Activation and recovery on each device model.
- Port-in and port-out, including authentication.
- A 911 test placed through the host network’s approved process, never a casual live call.
- The first bill, with taxes and proration, and a mid-cycle plan change.
- A cancellation and its final charges.
- One support escalation into the network.
Fix every launch-blocking defect before you grow.
What Spenza's US launches show
- IMZ, a US technology company, added a nationwide wireless offering for its customers and resellers. Spenza supplied T-Mobile and Verizon access, prepaid billing that switches each customer to the cheapest suitable unlimited plan, physical SIM and eSIM provisioning, a white-label portal inside IMZ’s Shopify store and a reseller dashboard with automated commission payouts. IMZ was live within weeks, onboarded 25 resellers, cut manual finance work by 30 percent and reduced support tickets by 20 percent.
- RocketPhone, a Salesforce-native calling platform for sales teams, launched a branded business mobile service on Spenza without building its own telecom stack.
- Angel Watch, a kids’ smartwatch brand, sells the watch and its plan in one checkout, with plans priced for a watch rather than a phone, in the US and the UK.
Outside the US, Butlr, a maker of smart building sensors, cut the time to launch connectivity in a new country from 60 days to 7 on the same platform.
The split is deliberate: you define the product, pricing, customer experience and distribution. Spenza runs the telecom underneath, through TelecomHub for network access and SIMs, ControlHub for plans and billing, UXHub for the branded portal and checkout, and an MCP server that lets AI agents run SIM, plan and billing operations.
| Choose | When |
|---|---|
| A light MVNO on Spenza | You want your own plans, pricing and customer experience, you sell through channels you already have, and you want to go live in weeks |
| A direct carrier agreement | You can commit large volumes, need one network’s full feature set and can staff carrier integration and compliance yourself |
| A branded reseller arrangement | Mobile is an add-on to your core business and you would rather not hold FCC registrations |
Five mistakes that delay US launches
- Signing for network access before deciding whether you will sell voice, which changes the whole compliance list.
- Pricing before taxes and fees, then losing customers when the first bill arrives about 29 percent higher.
- Treating eSIM as optional when US models of the iPhone 14 and later have no SIM tray.
- Leaving porting and port-out authentication until the end, when they are the main conversion and fraud risks.
- Having no named owner for the recurring dates: March 1 for CPNI and robocall recertification, April 1 for Form 499-A.
More pitfalls, with fixes, are in common MVNO launch mistakes.
Conclusion
Starting an MVNO in the US takes no spectrum and, with an MVNE, no telecom build. It does take three decisions made early: which model you will run, whether you will sell voice and who will be the carrier of record. Get those right and the rest is configuration, testing and a filing calendar with named owners.
If you already have customers, the economics favor you. You have the distribution and the billing relationship that new mobile brands spend most of their budget acquiring. The work is choosing the lightest model that still gives you control of pricing and the customer.
FAQs
Do you need an FCC license to start an MVNO?
No. An MVNO uses a host operator’s licensed spectrum, so it needs no spectrum license of its own. It still has to register with the FCC and file annual reports. If it sells voice, customer-data, 911 and robocall rules apply too, and international calling needs international Section 214 authority. Under a branded reseller arrangement in which the carrier of record contracts with and bills your customers, the carrier of record carries those duties.
How much does it cost to start an MVNO in the US?
Spenza’s published estimates are $10K to $50K for a branded reseller, $100K to $400K in the first year for a light MVNO on an MVNE, and $2M to $10M or more for a full MVNO with its own core. The MVNO launch cost breakdown itemizes each range.
How long does it take to launch an MVNO?
A branded reseller or light MVNO on an MVNE can go live in weeks to a few months, depending on devices, voice support and testing. A full MVNO that negotiates directly with a carrier and builds its own core and systems usually needs 12 to 18 months.
Do you need a direct contract with AT&T, T-Mobile or Verizon?
No. Most new MVNOs reach a national network through an MVNE or an aggregator that already holds the carrier agreement. A direct wholesale contract makes sense when you can commit large volumes and staff the integration, testing and compliance work it brings.
What is a carrier of record?
The carrier of record is the company legally responsible for the telecom service a customer receives: it registers with the FCC, files the required reports and answers for compliance. A branded reseller usually sells under another company’s carrier of record. A light or full MVNO is normally its own carrier of record.
Do MVNOs have to file in the Robocall Mitigation Database?
Yes, if they resell voice. FCC Enforcement Advisory 2026-02 states that MVNOs reselling voice are voice service providers. They must file a certification and a robocall mitigation plan that describes their know-your-customer process, and recertify every year by March 1.
Can you launch an eSIM-only MVNO in the US?
Yes. US models of the iPhone 14 and later are eSIM-only, so eSIM support is required anyway. Going eSIM-only removes SIM logistics, but older phones and many IoT devices still need physical SIMs. See how eSIM-only MVNOs handle activation and support.
Can an MSP or internet provider add mobile service?
Yes. MSPs and internet providers already own the billing relationship, support team and local brand that an MVNO needs. Most start as a branded reseller or light MVNO, bundle mobile lines with existing services and bill everything on one invoice. Our guide to adding mobile as an ISP covers the bundle.
