Comment dates set for FCC non-IP SHAKEN rules

June 16, 2025

The FCC’s Notice of Proposed Rulemaking for non-IP call authentication has been published in the Federal Register. This sets the due dates for comments and reply comments. Let’s have a look.

Proposed Rules

The Commission adopted a Notice of Proposed Rulemaking (NPRM) for non-IP call authentication on April 28, 2025. The proposed rules require providers that rely on non-IP networks to implement one or more non-IP caller ID authentication frameworks.

The rules apply to all providers in the call path, including voice service providers, gateway providers, and non-gateway intermediate providers.

Providers can comply with the rules either by transitioning their networks to IP or by implementing one or more effective non-IP call authentication frameworks. The non-IP call authentication frameworks listed in the NPRM include the following:

Out-of-Band Multiple STI-CPS (ATIS-1000096)
Out-of-Band Agreed STI-CPS (ATIS-1000105)
In-Band (ATIS-1000095.v002)

The NPRM proposes criteria for determining whether effective non-IP call authentication frameworks exist in conformity with the TRACED Act. The proposed criteria include the following:

Developed
Reasonably available
Effective, i.e., they produce the intended result of authenticating calls as described in the applicable standard.

The proposed rules would repeal the non-IP continuing extension for the STIR/SHAKEN implementation requirement.

The NPRM proposes a two-year timeline for compliance. This would set the compliance deadline two years from the effective date of the rules. This effective date has not been set yet—that would happen after the Commission has considered reply comments, made its decisions for final rules, and published them in the Federal Register, probably after the Office of Management and Budget reviews information collection aspects of the rules per the Paperwork Reduction Act.

Comments and reply comments

The Commission has requested comments and reply comments on the NPRM. Publication of the NPRM in the Federal Register sets the deadlines for these comments:

Comments are due on or before July 16, 2025.
Reply comments are due on or before August 15, 2025.

Although the rules highlights are straightforward, the NPRM takes a methodical approach to review a wide range of issues and assumptions to support the proposed rules. There’s a lot to digest. In their NPRM, the Commission asks for comments every step of the way.

More information

Notice of Proposed Rulemaking on caller ID authentication in non-Internet Protocol Networks, WC Docket No. 17-97.
NPRM comment dates and summary published in the Federal Register.

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