SHAKEN deadline for small non-facilities-based providers

The FCC published a notice to remind non-facilities-based small voice service providers of the imminent deadline for STIR/SHAKEN implementation. The notice also recaps the filing requirements. Let’s have a look.

The Small Provider Order

Voice service providers with fewer than 100,000 subscriber lines originally received a two-year extension on the STIR/SHAKEN implementation, which set their implementation deadline on June 30, 2023.

In December 2021, the Commission adopted their Fourth Report and Order on SHAKEN, also known as the Small Provider Order. In this order, the Commission moved the deadline forward one year for non-facilities-based small voice service providers. The revised deadline is June 30, 2022.

Non-facilities based

A voice service provider is non-facilities-based if it offers voice service to end users solely using connections that are not sold by the provider or its affiliates. Such voice service “rides atop” another provider’s transmission service.

Filing requirements

The Fourth Order and this recent public notice also remind affected providers of filing deadlines:

1. Within 10 business days of the effective date of the Small Provider Order, affected providers must update their Robocall Mitigation Database (RMD) filing to indicate that they are no longer subject to the two-year extension. Instead, they are now subject to the deadline on June 30, 2022. The Small Provider Order became effective on February 24, 2022, so, the deadline for this RMD update was March 10, 2022.
2. Within 10 business days of completion of their STIR/SHAKEN implementation, voice service providers must update their RMD filing to reflect the change in their STIR/SHAKEN implementation.

Enforcement

If an affected voice service provider fails comply with these requirements, it may be subject to enforcement actions, which may include imposition of a forfeiture.

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