Not a boolean. Describe what you are building and the answer names a tier and its obligations, because "do we need a licence" has three different right answers.
Members call members inside the app. No phone numbers, no calls to or from ordinary phones. Not interconnected VoIP, so none of the carrier obligations attach. ⭐ Build this first.
Real numbers, real calls, and the carrier carries the registrations and the E911 plumbing. Costs margin. This is how nearly every small phone app actually ships. ⚠️ Read the carrier agreement for what it does NOT cover.
⚠️ E911 is the obligation that ends projects. Do not choose this tier to save money — it does not.
Engineering and regulatory orientation, not legal advice. The FCC obligations named here are real and enforced; confirm your own position with counsel before carrying a single call to a phone number.