Highlights from the FCC robocalls and SHAKEN draft order

The FCC will consider a draft order during their open meeting on May 19, 2022. There are many moving parts in this order. Here are the highlights.

The 133-page document discusses rules for both robocall mitigation and STIR/SHAKEN. It includes:

  1. Gateway provider Report and Order
  2. Order on Reconsideration
  3. Order
  4. Further Notice of Proposed Rulemaking

Many of the provisions in the draft were included in a Further Notice of Proposed Rulemaking (FNPRM) from October 2021. However, there are several new topics included in this draft document that emerged from ongoing discussions and ex parte filings with the Commission since then.

Gateway provider report and order

The order would require gateway providers to:

  1. Submit a certification and robocall mitigation plan in the Robocall Mitigation Database (RMD).
  2. Implement STIR/SHAKEN to authenticate SIP calls that are carrying a U.S. number in the caller ID field.
  3. Adopt specific provisions in a robocall mitigation program:
    • Fully respond to traceback requests within 24 hours.
    • Block illegal traffic when notified by the Commission or with calling numbers on a reasonable Do-Not-Originate (DNO) list.
    • Know Your Customer (KYC). For this rule, the customer is the immediate upstream provider, not the call originator.
    • Mitigate illegal robocalls regardless of whether the gateway provider has implemented SHAKEN. This is called the “general mitigation standard.”

Order on reconsideration

This order would resolve quirks in previous rules. Previously, domestic providers could only accept foreign-originated calls with U.S. NANP calling numbers received directly from voice service providers that are listed in the RMD.

What are the quirks? “Voice service providers” are defined in the rules as providers that serve end users. Gateway providers almost never receive foreign-originated calls directly from foreign voice service providers. They receive calls from intermediate providers.

Because of this, the listed-in-the-RMD requirement would rarely (okay, never) be enforced. It just doesn’t happen that way. For this reason, the FCC invoked a stay of enforcement on this rule.

The Order on Reconsideration would fix that. It says that domestic providers may only accept calls with U.S. NANP calling numbers directly from foreign-originating or intermediate providers listed in the RMD. Just two words, “or intermediate,” would fix it.


The order fixes a typo and defines an acronym in a previous order. Let’s move on.

Further notice of proposed rulemaking

The Commission asked for feedback on a whole slew of proposed rules. The proposed rules would require all U.S. providers to:

  • Authenticate calls with STIR/SHAKEN
  • Comply with the current version of the STIR/SHAKEN standards
  • Adopt a non-IP caller ID authentication solution
  • Extend certain mitigation duties to all domestic providers, like the obligations introduced for gateway providers
  • Become an approved SHAKEN service provider to claim a SHAKEN implementation in the RMD

The FNPRM asks for comment on other topics:

  • Obligations for providers that cannot do SHAKEN
  • Requirements for satellite service providers
  • Restrictions on using U.S. NANP numbers for foreign-originated calls
  • Differential treatment of conversational traffic

See the robocalls and SHAKEN draft order for more details.

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Our thoughts

The gateway provider order clears up some open questions when these rules were first proposed last October. The adjustments seem reasonable.

The order on reconsideration fixes a glaring problem and is a welcome change.

We think the FNPRM is the most interesting part of this document. It contains proposed rules that many have been advocating for a long time:

  • Require robocall mitigation and SHAKEN.
  • OSPs cannot claim a SHAKEN implementation if they are not approved to do SHAKEN.
  • Phase out the non-IP SHAKEN exclusion. SHAKEN for TDM standards have been approved. Lets bring calls that rely on non-IP technology somewhere along the call path into the SHAKEN ecosystem.
    • Our only quibble with the phrasing of this proposal is that non-IP SHAKEN methods should only be required of providers that rely on non-IP network technology. That’s how the standards were designed. All-IP providers don’t have to do anything to support SHAKEN for TDM.

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