Comments on FCC proposed rules for non-IP SHAKEN

There were many participants and comments on the FCC’s proposed rules for non-IP call authentication. Filers made interesting and thought-provoking comments. This article summarizes the comments and recurring themes.

Recurring themes

Here are a few of the recurring themes we noticed in these comments:

Comments

There were 182 pages of comments from 17 submissions. We’ve summarized these comments below. We tried to keep the summaries brief, but when in doubt, we erred on the side of including more information to reduce the risk of leaving out something important. If you’d like to see more information, you can click the filer’s name above each summary to read that organization’s filing.

AB Handshake Corporation

• Offers a proprietary fraud prevention solution, AB Handshake Call Validation, which enables service providers to confirm the validity of a call in real time by exchanging call event details via an encrypted out-of-band channel.
• The software captures call event details using a wide choice of standard telecom protocols, including but not limited to RADIUS, SIGTRAN, CAMEL, and APIs with core network nodes.
• AB Handshake encourages the Commission to include AB Handshake Call Validation into the scope of the regulations.

American Bankers Association and Joint Trades

• American Bankers Association and Joint Trades provide comments on behalf of The American Bankers Association, ACA International, American Financial Services Association, America’s Credit Unions, Mortgage Bankers Association, and Student Loan Servicing Alliance.
• Agree that providers have effective caller ID authentication solutions available to implement on their non-IP networks and should implement one of these solutions or upgrade their networks to IP.
• Urge the Commission to shorten the time required from two years to one year in light of the urgent need to stop criminals who are exploiting the absence of call authentication on non-IP networks to place fraudulent calls.
• Illegally spoofed calls continue to harm consumers and undermine businesses’ ability to communicate with customers.
• In 2022, the Commission asked how it could eliminate the non-IP gap.
  • Voice service providers asserted that investment in IP networks would lead to a reduction in TDM networks.
  • But today, nearly three years later, calls still traverse non-IP networks, allowing criminals to place unsigned calls.
• The Commission should require IP transition by a date certain.
• During the interim period before the transition is complete, the Commission should require implementation of caller ID authentication solutions on non-IP networks.
• The Commission should not deem effective any solution that does not enable the transmission of all STIR/SHAKEN information, particularly the identification of the original signing provider.

Cloud Communications Alliance and INCOMPAS

• The primary issue faced by Alliance and INCOMPAS members’ effective use of STIR/SHAKEN is the removal of STIR/SHAKEN information by TDM-in-the-middle networks that have refused to upgrade to IP.
• Our member companies have expended substantial resources to implement STIR/SHAKEN. Their efforts are being squandered because TDM-in-the-middle networks fail to upgrade to IP.
• Major providers echo the Commission’s assessment that transition to IP is the most efficient and effective way to ensure end-to-end transmission of STIR/SHAKEN information.
  • Yet they urge the Commission not to mandate such upgrades.
  • They claim that emergent solutions identified by the SIP Interconnection Working Group are right around the corner.
  • They urged the Commission to focus on reforming section 214 discontinuance requirements.
• In the three years since then, little progress has been made in upgrading TDM-in-the-middle networks.
  • The SIP Working Group’s recommendations have been bogged down in intractable negotiations or refusals to exchange traffic in IP.
  • The Commission did streamline section 214 requirements.
  • The expectations that all providers negotiate agreements in good faith have not materialized.
• The time for a mandate to upgrade TDM-in-the-middle networks to IP is ripe.
• The Commission should repeal the non-IP extension of STIR/SHAKEN obligations, at least for the TDM-in-the-middle providers.
• TDM-in-the-middle providers should be encouraged to adopt Internet Protocol Voice Service (IPVS) solutions identified by the SIP Interconnection Working Group.
• Whether the Commission mandates IP transition along with adoption of one of the ATIS-based solutions, the Commission should modify its definition of “effective” to ensure the end-to-end transmission of all STIR/SHAKEN information inserted by the originating provider.

Competitive Carriers Association

• The Commission should not adopt the proposed two-year blanket mandate.
• Instead, the FCC should remove barriers to IP interconnection and incentivize IP transition.
• If the Commission does proceed, it should target non-gateway intermediate providers and providers that have no plans to transition to IP.
• Imposing a non-IP call authentication mandate may encourage IP transition and improve end-to-end passage of call authentication.
  • But imposing a requirement and arbitrary timeline would undermine IP transitions in progress by many smaller and rural carriers.
  • A non-IP mandate could lead to costly vendor dependency and loss of provider network autonomy (e.g., through porting all numbers to a vendor).
• Smaller providers face nearly insurmountable challenges in obtaining fair interconnection terms from large LECs, which undermines both the IP transition and end-to-end call authentication.
  • CCA flagged this issue for the FCC during the NOI phase of this proceeding, and the issue has significantly worsened since 2022.
• CCA shares the views of NTCA, which emphasized the inability of its members to fully transition to IP on fair terms.

CTIA

• The NPRM risks delaying the IP transition by forcing providers to spend resources on legacy technologies.
• Instead, the Commission should prioritize enforcement against bad actors and incentivize the IP transition.
• Non-IP call authentication methods are not fully developed nor reasonably available, and still present security risks.
• The SHAKEN information needed to implement Out-of-Band may expose calling party CNPI.
• Out-of-Band Agreed CPS requires all providers in the call path to have invested in this solution.
• In-Band requires providers to remove call-identifying information.

Eliot Steele Robinson

• The FCC should review its Robocall Mitigation Database to evaluate progress by each provider to comply with STIR/SHAKEN.
• Perhaps some measure used to mitigate illegal robotexts could be applied to voice calls.
• The FCC should consider an IETF internet draft on a Caller ID Verification (CIV) protocol that authenticates the caller ID of an incoming call through a SIP message challenge-and-response process.
• Initial comments from this filer.

ICA AI

• ICA, formerly known as Intelligent Communications Assistant, Inc., has developed a patented, AI-driven platform that performs relationship fingerprinting of prior communications, including calls, texts, and emails, to assess whether a call may be fraudulent or unwanted. It can screen calls with a digital assistant. It can block calls.
• STIR/SHAKEN effectiveness is hampered by TDM-based networks that destroy authentication information.
• Addressing TDM networks will improve STIR/SHAKEN, but likely will not materially reduce scam calls.
• The Commission can foster innovation and the adoption of effective technologies, such as ICA’s, that can work with STIR/SHAKEN.
  • It should extend safe harbor from Communications Act liability for proven new technologies.

Michael Ravnitzky

• The TRACED Act gives the Commission not only clear authority but an affirmative obligation to act decisively and set firm deadlines for full deployment of caller ID authentication.
• The Commission should set a firm one-year deadline, with hardship waivers limited to a single six-month extension.
• Intermediate and gateway providers must forward caller-ID authentication information unchanged, regardless of network type.
• The Commission should verify compliance through active oversight, streamline future framework approvals, educate the public, and mandate that every provider—IP or non-IP—deliver authenticated caller ID.

NCTA – The Internet & Television Association

• Implementation of non-IP call authentication is an expensive band-aid solution that undermines the more important objective of completing the transition to IP.
• If the Commission does mandate non-IP call authentication, it should ensure that any new costs, including the costs of hardware and software upgrades and governance-related costs, are borne solely by TDM providers that will be using non-IP call authentication, not by IP-based providers that already have implemented STIR/SHAKEN.
• The Commission should press ahead with the IP transition, including convening an industry working group to coordinate a process for completing that transition.

NENA – The 9-1-1 Association

• NENA comments address 5 other dockets, in addition to caller ID authentication.
• Management oversight of the NG9-1-1 transition to ESInets and full i3-based NG9-1-1 is not occurring fast enough.
  • There will be an extended period where legacy E9-1-1 systems must be supported and maintained until the transition to NG9-1-1 is complete.
• ILECs and CLECs are grandfathering or discontinuing TDM services. NENA urges the Commission to ensure that TDM connectivity to/from PSAPs and selective routers is not adversely affected.
• The Commission should consider establishing a task force to ensure that the IP transition does not adversely impact legacy E9-1-1 calls during the full transition to NG9-1-1.

NTCA – The Rural Broadband Association

• The TRACED Act mandated that all voice service providers implement caller ID authentication.
  • Congress clearly understood that non-IP facilities remained in service.
• Ideally, non-IP providers would upgrade their networks to IP.
  • In some cases, however, providers depend on routing through non-IP networks owned by other operators.
• The Commission should approach this proceeding with two goals in mind:
  1. Adopting and/or reforming rules to facilitate the IP transition to the greatest extent possible, while
  2. Ensuring the implementation of non-IP call authentication where needed.
• A non-IP authentication mandate could become practically irrelevant if the Commission takes effective further action to promote the IP transition.
• 83% of NTCA members have some IP-enabled switching capabilities within their network today.
  • These capabilities are undermined where other carriers’ non-IP networks operate as a barrier to successful call authentication.
• The Commission should remove regulatory obstacles to IP transition:
  • An IP transition made without changes to the rates, terms, or conditions of service should not trigger a discontinuance.
  • The Commission should clarify that a provider need not maintain a switch in a geographical service area.
  • A provider should be able to satisfy the owner-of-physical components requirement for universal service support by owning the distribution plant by which calls are routed to and from customers.
• The IP transition could potentially force RLECs to assume transport and routing costs they do not bear today.
  • This shift in cost responsibility could be profound for rural communities.
  • The Commission should address these concerns with reasonable, clear, and simple rules of the road, including cost apportionment, to clarify that RLECs will not be financially responsible for increased costs.
• The Commission should mandate implementation of non-IP call authentication with an effective date 18 or 24 months after the effective date of new IP interconnection rules.

Numeracle, Inc.

• The best time for the Commission to mandate an IP transition was 12 years ago. The second-best time is now. But other pressing needs dependent on the completion of this transition should not wait until this long-overdue process is completed.
• Numeracle has no confidence that the IP transition will be completed anytime soon. In the meantime, Out-of-Band SHAKEN, while not perfect, is the best alternative.
• Verified Rich Call Data will help the telecom industry finally achieve what many thought the TRACED Act would achieve through STIR/SHAKEN alone: enabling callers to prove they are who they claim to be to the call recipient.
  • Enabling non-IP and Out-of-Band STIR/SHAKEN to spur this along is necessary in light of our collective failure to eliminate legacy TDM networks in a timely manner.
• The Commission should mandate Out-of-Band SHAKEN on an expedited one-year implementation basis, maintain vigilance over the process, and step in to ensure that solutions are deployed in an open, fair, and competitive manner.

Teliax, Ringer

• Teliax supports ATIS-1000105, Out-of-Band Agreed CPS, and is prepared to implement it rapidly upon rule adoption.
  • It leverages existing STIR/SHAKEN frameworks, minimizing incremental costs.
• The Commission should reject exaggerated cost claims and recognize that competitive carriers like Teliax are ready to deploy these solutions without delay, underscoring their feasibility.
• Legacy TDM networks persist not due to technical necessity but as barriers to entry for competitive providers.
  • The facilities-based criteria for accessing telephone numbers favor ILECs with legacy TDM systems and disadvantage IP-based competitors reliant on leased or virtual infrastructure.
• By maintaining TDM infrastructure, incumbents enable robocalls, facilitating unauthenticated traffic through outdated systems.
• To quantify authentication gaps and expose TDM’s role as a robocall enabler, Teliax urges the Commission to require annual reporting by providers on TDM call volume.
• The Commission should launch a TDM mapping initiative to catalog TDM use and explore expiration horizons for TDM unless providers demonstrate necessity.

TransNexus

• We have observed a steady increase in the number of SHAKEN-authorized providers, accompanied by an alarming decrease in the percentage of calls received at termination with SHAKEN information still intact.
  • We think more calls are being routed over call paths with non-IP segments, where the call authentication information is lost. TNS has observed a similar drop.
  • Clearly, rulemaking for non-IP call authentication is sorely needed.
• For STIR/SHAKEN to achieve its intended purpose, call authentication information generated at origination must survive transit to the Terminating Service Provider, which will verify the results into call analytics to protect its subscribers from illegal calls.
  • This must include all PASSporT information, especially the identity of the entity that authenticated the call.
• We do not believe that In-Band Authentication mechanisms that simply relay the attestation level and/or require the creation of a new PASSporT with a new authentication provider identity achieve the intended purpose of call authentication.
• The Commission’s rules must not enable an authentication provider to “launder” its identity from its calls by routing them to call paths where the authentication provider’s identity is lost.
• The Out-of-Band mechanisms are effective in fulfilling the intended purpose of call authentication.
• Out-of-Band mechanisms are highly scalable. We have performed a load test on an STI-CPS, which is used to exchange PASSporTs out-of-band, in which we sent publish and retrieve requests at a volume and rate that is greater than that of the entire U.S. mobile phone subscriber market. The STI-CPS processed these requests with no increased latency.
• The Commission rules should mandate that providers that rely on non-IP networks either transition to IP or implement and use an effective non-IP call authentication mechanism within 12 months of the effective date of the rules.
  • Providers that have not previously implemented STIR/SHAKEN at all because of exclusive use of non-IP interconnections should be given 18 months.

USTelecom – The Broadband Association

• The Commission does not have legal authority to mandate an IP transition.
  • The Commission should not inadvertently back into the same outcome by adopting a non-IP authentication mandate that forces an IP transition by a date certain.
• The IP transition will be successful and swift if it happens through marketplace investment and flexible stakeholder collaboration.
• Alternative solutions can help expand caller ID authentication while supporting the IP transition. Examples include:
  • IP-based Voice Service (IPVS), suggested in 2022 by the SIP Interconnection Working Group.
  • End-user solutions such as AT&T’s Phone-Advanced (AP-A).
• The Commission should confirm that offering these alternative solutions would satisfy any non-IP caller authentication rule that it adopts.
  • If the Commission decides that these alternative solutions do not satisfy the requirement for effective call authentication framework in non-IP networks, then it should instead clarify that they satisfy the obligation to upgrade to IP.
• Although the proposed non-IP call authentication standards are developed, they are not reasonably available and effective.
• Out-of-Band solutions give bad actors the opportunity to listen to, intercept, manipulate, and abuse authentication information.
• The In-Band and Out-of-Band solutions make Customer Proprietary Network Information (CPNI) vulnerable to malicious actors.
• Non-IP solutions require bilateral agreements between every provider in the call path, which creates scalability difficulties.
• In-Band solutions have insurmountable problems with interoperability.
• The STI-GA may not be able to take on additional oversight capabilities. There could be ethical concerns with potential conflicts of interest and confidentiality.
• Non-IP solutions would be unreasonably costly to implement.

Voice on the Net Coalition

• VON encourages the Commission to require all voice service providers (VSPs) to transition to IP networks by December 31, 2028, or two years after the effective date of rules adopted in this proceeding, whichever is later.
• VON opposes the proposal to allow VSPs the option to instead implement a non-IP caller ID authentication framework.

ZipDX

• Consumers are not benefiting from providers’ implementations of STIR/SHAKEN because the Big Three mobile operators are not leveraging the technology in consumers’ interest.
  • Terminating service providers could use the call signer’s identity to inform call treatment.
• Any mandate must be supported with data.
  • ZipDX supports the approach suggested by Teliax in their comments on May 30, 2025, to develop a quantified TDM map showing where TDM exists and how much traffic flows over these links.
  • Once the TDM gap is quantified, solution elements need to be prioritized according to scope and impact.
• The Commission should cap call traffic volume traversing TDM at the current levels.
• The In-Band authentication alternative must be discarded as unacceptable. The identity of the original signer is lost.
  • The most important element of STIR/SHAKEN is the identity of the signer.
• There are two versions of branded calling. One uses a centralized server that accepts call details from the originator and allows the terminating provider to retrieve those details before the call is delivered.
  • This version of branded calling is currently supported by AT&T, Verizon, and T-Mobile.
  • It is remarkably similar to the Call Placement Service that is part of two alternatives in the NPRM.
  • If these providers can figure out how to deploy CPS for branded calling, they can figure it out for non-IP STIR/SHAKEN.

TransNexus solutions

TransNexus is a leader in developing innovative software to manage and protect telecommunications networks worldwide. The company has over 25 years of experience in providing telecom software solutions including toll fraud prevention, robocall mitigation and prevention, CDR and call analytics, advanced call routing, billing support, STIR/SHAKEN, and branded calling.

Contact us today to learn more.