Reference: http://msdn.microsoft.com/en-us/library/bb975642.aspx
It says 3.1 right on there. But, just in case, my question is: has anything changed?
Let me summarize and comment.
1. PC to PC: Futile. Since XNA networking is not included in the redistributable, and you should not expect the players to download a development kid (XNA Game Studio) to play a game. I suppose with some clever trickery, you could include the necessary DLLs in your PC installation, but that is most likely illegal.
2. X-Box to X-Box: Futile. You must have a Creator's Club account to play multiplayer games. I cannot expect my players to pay 100 bucks to play my game for a year. (Heck, I'm a developer and I cringe to pay that. I don't even pay for X-Box gold membership!)
3. PC to X-Box and vice versa: A pie in the sky dream. The game I am working on would actually be pretty fair between the two. But, now you have the worst of both worlds. Players are required to have Creator's Club membership on PC, if somehow they were able to get the appropriate DLLs.
These limitations leave me to one solution: only PCs can do multiplayer, using my own networking library. X-Box can only play split screen.
These limitations just seem arbitrary. When will these limitations be changed?