SHAKEN deadline for non-gateway intermediate providers

December 18, 2023

The FCC issued a public notice to remind non-gateway intermediate providers of an upcoming STIR/SHAKEN deadline. Let’s have a look.

The rule

The Commission adopted this rule on March 16, 2023, in their Sixth Report and Order on STIR/SHAKEN. We’ve broken this rule down into the following components:

A non-gateway intermediate provider
Must authenticate caller identification information (i.e., use STIR/SHAKEN)
For unauthenticated calls it receives directly from an originating provider
Which it will exchange with another provider as a SIP call
Not later than December 31, 2023.

The text for this rule is found in 47 CFR 64.6302(d).

Call scenario illustration

Non-gateway intermediate provider signing mandate

Figure 1. Non-Gateway Intermediate Provider STIR/SHAKEN Mandate

Figure 1 illustrates a call flow scenario to help explain the rule. The non-gateway intermediate provider (green box) must authenticate unauthenticated calls it receives directly from an originating service provider (blue box) that it will exchange with another downstream provider over the service provider SIP network.

Some non-gateway intermediate providers might receive calls from an upstream provider which sometimes is the OSP, and other times is an intermediate provider. How can the intermediate tell which calls the upstream provider originated?

The Commission addressed this question in footnote 74 of the Sixth Report and Order with the following observations:

“Intermediate providers should know whether they receive calls directly from an originating provider pursuant to contracts that provide information to the intermediate provider about the originating provider’s customers and expectations for handling their traffic.”
“Further, […] we require non-gateway intermediate providers to take reasonable steps to mitigate illegal robocall traffic. That duty, along with other requirements of our rules, may require an intermediate provider to perform the due diligence necessary to understand the sources of the traffic it receives.”

Providers should consult an attorney for appropriate guidance in applying this rule to their circumstances.

TransNexus solutions

TransNexus is a leader in developing innovative software to manage and protect telecommunications networks. The company has over 25 years’ experience in providing telecom software solutions including toll fraud prevention, robocall mitigation and prevention, TDoS prevention, analytics, routing, billing support, STIR/SHAKEN and SHAKEN certificate services.

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