The Federal Communications Commission (FCC) required voice service providers (VSPs) to implement STIR/SHAKEN by June 30, 2021 on internet protocol (IP) portions of their network and file certifications on implementation status with the FCC via the Robocall Mitigation Database<https://commlawgroup.us2.list-manage.com/track/click?u=df51fe32659b5ffab92c23e59&id=c0df39b8b9&e=9a2c2871d7> (RMD) by September 28, 2021 to avoid having their calls blocked.
Subsequently, the FCC exempted small VSPs from STIR/SHAKEN implementation until June 30, 2023 (but is formally considering shortening the exemption period). However, small VSPs must still file robocall mitigation plans (RMPs) in the RMD by September 28, 2021.
The FCC Wireline Competition Bureau issued carriers a reminder<https://commlawgroup.us2.list-manage.com/track/click?u=df51fe32659b5ffab92c23e59&id=aa958ac7c3&e=9a2c2871d7> today to block calls from all carriers (including small VSPs) not listed in the RMD as of September 28, 2021 and provided an email subscription service to “ease compliance” with the call blocking obligation by providing a weekly update on RMD updates. The weekly update (sent Tuesdays at 11am for the preceding seven days) could result in calls blocked by carriers that choose not to manually review the RMD for updates. Any carrier submitting an RMP into the RMD as of today should work with counsel to ensure that terminating VSPs and intermediate providers are immediately notified to reduce or eliminate service disruptions and call blocking.
If you have not yet filed an RMP, the time is now!