FCC adopts new STIR/SHAKEN rules

The FCC adopted additional new rules for STIR/SHAKEN call authentication at their March open meeting. Let’s have a look.

Sixth Report and Order

Here’s a summary of the rules adopted in the Sixth Report and Order for Call Authentication Trust Anchor (WC Docket 17-97).

Intermediate provider obligations

• The first non-gateway intermediate provider in the call path must sign unsigned calls by December 31, 2023.
• Providers must comply with STIR/SHAKEN standards that were in effect at the time of their implementation deadline. They optionally may comply with subsequent versions.

Mitigation and Robocall Mitigation Database (RMD) filing obligations

• All providers must take reasonable steps to mitigate illegal robocalls.
• All providers must file their robocall mitigation plan in the RMD. Robocall mitigation plans must describe the following:
  • “Know-your-upstream-provider” procedures designed to mitigate illegal robocalls
  • Call analytics used to identify and block illegal traffic, including whether they use third-party vendor(s) and the name of the vendor(s).
• All providers with RMD filings, new and existing, must provide additional information in their filing:
  1. Filers must indicate the role(s) that the filing provider plays in the call chain.
  2. Providers claiming a SHAKEN extension or no obligation to implement it must explicitly state the rule that exempts it from compliance.
  3. New and existing filers must certify that they have not been prohibited from filing in the RMD by a law enforcement action.
  4. All providers must state whether the filing entity or related entities have been subject to action or investigation for illegal robocalls or spoofing.

The deadline for updated RMD filings will be 30 days after the publication of these rules in the Federal Register.

Stronger enforcement

• Increased forfeitures for failure to comply with mandatory blocking.
• Intermediate providers are subject to removal from the RMD for rule violations.
• Expedited removal from the RMD for facially deficient filings.
• Repeat violators are subject to revocation of their Section 214 operating authority.

Rule changes for satellite providers

• Satellite providers that don’t originate calls with NANP calling numbers don’t have to use STIR/SHAKEN.
• Small satellite providers have an ongoing extension from TRACED Act obligations.

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