Updated robocall mitigation filing rules

The FCC announced deadlines for compliance with new robocall mitigation rules. The deadlines are fast approaching! This article summarizes the requirements. Let’s have a look.

All providers are required to file certifications and robocall mitigation plans to the Robocall Mitigation Database (RMD). The deadline is February 26, 2024.

This requirement impacts every U.S. provider, including:

• All providers, regardless of whether they are required to implement STIR/SHAKEN,
• Providers that lack control over the network infrastructure necessary to implement STIR/SHAKEN, and
• All intermediate providers.

Existing filers must update their certification and robocall mitigation plan in the RMD by February 26, 2024.

Intermediate providers and voice service providers must refuse to carry traffic from any provider not listed in the RMD by May 28, 2024. This requirement includes traffic from non-gateway intermediate providers.

Robocall Mitigation Database

The online RMD certification form requires additional information. (This is why existing filers are required to update their certification.) The additional information to be collected includes:

1. The role(s) the provider plays in the call chain,
2. Detailed information about any claimed STIR/SHAKEN implementation extension or exemption,
3. Information about principals, affiliates, subsidiaries, and parent companies,
4. A statement about whether the filer is subject to official action or investigation due to suspected unlawful robocalling or spoofing,
5. The filer’s Operating Company Number (OCN).

Robocall mitigation plan

All providers must submit a robocall mitigation plan with their updated certification by February 26, 2024. Existing filers who provided a plan previously must update and file their robocall mitigation plan by the same date.

As before, these plans must describe the reasonable steps the provider has taken to avoid originating, carrying, or processing illegal robocalls. Gateway providers must also describe their know-their-upstream-provider program.

The new, additional requirements for robocall mitigation plans include the following:

1. Voice service providers must describe their affirmative, effective measures to prevent customers from originating illegal robocalls.
2. Non-gateway intermediate providers and voice service providers must describe their know-their-upstream-provider program.
3. All providers must describe any call analytics systems they use to identify and block illegal robocalls, including whether they use a third-party vendor and the name of the vendor(s).
4. All mitigation plans must be provided in PDF.

More information

• Public notice on robocall mitigation deadlines and instructions
• Robocall Mitigation Database Filing Instructions

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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 branded calling, toll fraud prevention, robocall mitigation and prevention, TDoS prevention, analytics, routing, billing support, STIR/SHAKEN and SHAKEN certificate services.

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