The FCC has issued a rulemaking notice proposing a number of changes to the robocall mitigation database (RMD). The notice can be found here. Comments on the proposals are due on October 9, 2026 and replies on November 9, 2026. Many of the proposals build on the FCC’s know your upstream provider revisions summarized on a previous alert to CCA members.
The proposed revisions are extensive and CCA members are encouraged to review the FCC’s rulemaking notice. The RMD revisions convert the database into a greater screening and enforcement tool designed to better ensure bad actors are prevented from entering the RMD or can be quickly removed. Part of this effort entails more certifications and information from all providers, regardless of transmission technology used, whether they consider themselves information service providers, or whether they are facilities-based or non-facilities-based resellers. Following is a high level summary of the RMD proposals.
Who Must File in the RMD
The notice confirms that all voice service providers (VSPs) must file in the RMD and that VSPs include companies that provide voice service directly or indirectly (intermediate providers) to end users. In addition to traditional wireline, wireless, and VoIP services, the notice would require filing by PBXs, dialing platforms, cloud service providers, over-the-top service providers, call centers, value-added service providers, and telephone number service providers (TNSP) to the extent these entities furnish voice service to end users.
The notice also proposes changing the definition of foreign service providers that must file. Today, foreign provider that use NANP numbers must file or have their calls blocked. The notice proposes to define a foreign service provider as company created, incorporated, or organized outside of the United States and would require filing in the RMD even if they send calls using foreign numbers in the caller ID.
Proposed New or Revise Certifications
All VSPs serving end users, including non-facilities based resellers, must certify that they are making the appropriate STIR/SHAKEN attestations.
Providers must certify that they have not submitted false, misleading, or inaccurate information to the Commission, any agent or other third party designated by the Commission or acting on behalf of the Commission pursuant to Commission rules, including the industry traceback consortium and the North American Numbering Plan Administrator (NANPA).
Proposed Robocall Mitigation Plan Revisions
Providers claiming an exemption from the STIR/SHAKEN implementation must provide a more detailed explanation of why they qualify for the exemption. The notice would also a provide a new, temporary exemption for those seeking to obtain an SPC token.
The notices modifies current requirements for providers to indicate if they have been subject to enforcement actions during the past two years and provides more detail on the information required if a provider states that it has been subject to an enforcement action in the previous two years related to illegal robocalls.
The notice requires that voice service providers indicate whether or not they engage third
parties for the following: (1) performing call analytics; (2) performing the technological act of signing calls to satisfy STIR/SHAKEN obligations; (3) fulfilling KYC and KYUP obligations; and (4) submitting RMD submissions to the Commission if the FCC permits providers to use third parties for this purpose. VSPs must provide the name and basic information about the third party.
Confirm and Clarify Business Information
The Notice clarifies and confirms the business information that providers must include in their filing, including the requirement to identify the providers’ principals and include their title, telephone number, email address, physical address, country of residence, and citizenship. The FCC states that many providers fail to include this information. The notice seeks comments on whether to require more information, such as proof of identity documentation.
Role of Providers in the Call Flow
The notice would expand on the current requirement for providers to identify their place in the call chain. Specifically it proposes the following, to be determined on a call-by-call basis:
• a voice service provider must indicate whether it is a facilities-based provider and/or a non-facilities-based provider;
• a facilities-based provider must indicate whether it is: (i) an originating or terminating voice service provider directly serving end users; (ii) an originating or terminating provider acting as a wholesale provider originating or terminating calls for end users it does not directly serve on behalf of another provider or providers; (iii) a gateway provider; and/or (iv) a non gateway intermediate provider;
• A non-facilities-based provider must indicate whether it is directly serving end users and/or whether it is a wholesale provider to another provider or providers that does not directly serve end users.
The FCC also seeks comment on whether providers should be required to submit into the RMD information on their access to numbers, including what number blocks or ranges they use.
Proposed Changes to Robocall Mitigation Plans
The notice proposes to require that all voice service providers implement a robocall
mitigation plan that includes “affirmative, effective measures” rather than just “reasonable steps” to prevent carrying illegal calls. The FCC states that it does do not believe the “reasonable steps” requirement compels providers to institute an ongoing effort to ensure that the measures that comprise their robocall mitigation program are effective.
The plan must describe steps to stop all illegal calls, not just illegal robocalls.
The notice seeks comment on whether the mitigation plans should include detail on how providers comply with any new KYUP or KYC obligations, and the specific call analytics they use.
Filing Updates and Recertification
Current rules require providers to update RMD information within 10 business days and to recertify annually. The notice seeks comment on revisions such as eliminating the 10-day rule and instead require more periodic recertifications.
Keeping Bad Actors Out of the RMD
The notice seeks comments on various steps to keep bad actors out of the RMD. It propose to establish a new rule that a filing does not “appear” in the database unless and until the filing has been accepted and published in the database. A provider cannot have its calls completed until it appears in the RMD.
The notice also seeks comment on requiring some or all entities to obtain a letter of credit along with a bankruptcy opinion from counsel in support of their RMD filing.
The FCC also proposes to create technical tools to help identify deficient filings and proposes a long list of causes for removal or other enforcement action and to provide more detail on the process for removal. It also proposes to require providers to provide notice to their customers if they are removed for the RMD or subject to a mandatory blocking order.
The notice seeks comment on ways to prevent bad actors from attempting to refile in the RMD under a different name.
Under current rules, providers may not accept traffic from entities not in the RMD. The notice seeks comment on how often provider should check the RMD and whether the current two business day time to begin blocking is sufficient.
Next Steps
All providers should review the proposals and assess their impact on the company’s RMD filing and the need to provide additional information. Please contact the CCA regulatory committee if you have any questions. As noted, initial comments on the proposals are due October 9, 2026.