Last January, the FCC adopted new rules regarding required filings in the Robocall Mitigation Database (RMD). The January 2025 order is available here: FCC-24-125A1.pdf. CCA summarized those rules in a previous alert, available here: New Robocall Mitigation Database Filing Requirements. The FCC has now announced effective dates for compliance with these new rules: Improving the Effectiveness of the Robocall Mitigation Database; CORES Registration System. The new rules take effect on February 5, 2026, except for those subject to approval by the Office of Management and Budget (OMB), as described below. For convenience, CCA provides the following high-level summary of the new requirements. Providers should consult their counsel if they have questions, or feel free to contact the CCA regulatory committee or Michael Pryor, mpryor@bhfs.com.
Key Changes and Requirements
Update CORES Information. To improve accuracy and enforcement, the FCC will now require all entities registered in the Commission Registration System (CORES) to update any changes to their information within ten business days. This requirement ensures that CORES and the RMD remain aligned, reducing confusion and strengthening compliance oversight.
New Penalties. The FCC has also introduced significant penalties for noncompliance, which apply on a continuing basis until corrected. Providers that submit false or inaccurate information to the RMD face a base forfeiture of $10,000 per violation, while those failing to update their filings within ten business days will incur a $1,000 penalty. These measures underscore the importance of maintaining accurate and timely data.
Filing Fees and Annual Recertification. Providers must recertify annually that their RMD filings are accurate and pay a $100 fee for both initial and annual submissions. Failure to meet these requirements may result in enforcement actions, including removal from the database, ensuring that only compliant providers remain active in the system.
Enhanced Oversight and Security
The FCC is also introducing several measures to strengthen the integrity and security of the RMD.
Reporting Deficiencies The Wireline Competition Bureau will establish a dedicated reporting portal, providing a streamlined way for anyone to flag deficient RMD filings and help ensure timely corrective action.
More Guidance. The Bureau will also issue clear guidance and best practices to assist providers in meeting their compliance obligations, including instructions on how foreign providers should identify themselves.
Multifactor Authentication to Access the RMD. To further protect the system, the FCC will implement a multifactor authentication process, adding an extra layer of security to prevent unauthorized access and safeguard sensitive information.
Additional Measures
The FCC considered, but declined to adopt, proposals such as requiring PINs for filing, implementing data validation tools, and authorizing permissive blocking of traffic from providers with deficient filings. However, the FCC directed further exploration of technical solutions and potential database enhancements.
Effective Date
Most of the new rules described above will take effect on Feb. 5, 2026, with a few key exceptions. Changes related to updating existing reporting and recordkeeping requirements for CORES will not become effective until OMB completes its review under the Paperwork Reduction Act. In addition, the $100 fee for RMD applications will not take effect until the FCC provides the required notice to Congress (pursuant to the Communications Act ยง9A(b)(2)), and updates its information technology systems and internal procedures to process the revised fee schedule. The FCC will publish separate notices in the Federal Register announcing the effective date of these rules once those conditions are met.