Comments on FCC's proposed Know-Your-Customer rules

The FCC received many comment filings from organizations on the proposed Know-Your-Customer (KYC) rules. In this blog post, we summarize their comments and identify recurring themes. Let’s have a look.

There were many comments filed by individuals. We summarized these in a previous blog post, Flood of comments received for FCC's proposed KYC rules. Most of these comments were from individuals, not organizations, and they mostly seemed opposed to the proposed KYC rules for privacy reasons.

We tallied the organization comment filings by our evaluation of whether the filer seemed in favor, mixed, or opposed to the proposed rules. Unlike the comments filed by individuals, organizations had a mix of support.

This rough tally can be deceptive, however. Even those organizations that were in favor had conditions for their support, especially in terms of privacy and accessibility concerns.

Recurring themes

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

Comments

There were 452 pages of comments from 41 comment submissions. We’ve summarized these comments below. Since there are many comment filings, we made the summaries brief. If you’d like to see more information, you can click the filer’s name above each summary to read that organization’s filing.

ABA and Associations

• Strongly support enhanced KYC for business callers
• Want robust information collection, per-call forfeitures, more FCC enforcement resources, and a SIM-box ban.
• Oppose lighter rules for low-volume business callers because bad actors could fragment operations to evade scrutiny.

America’s Communications Association - ACA Connects

• Supports clearer KYC rules but urges a risk-based framework, flexibility for low-risk retail and small business customers, limited new recordkeeping, and safe harbors for providers with reasonable compliance practices.
• Opposes overly prescriptive rules and draconian per-call liability for good-faith providers.

ACA International

• Supports enhanced KYC and independent verification, especially alignment between KYC and branded calling/caller identity.
• Warns that KYC should not become a reason to deny service to lawful callers or to block/mislabel vetted, compliant calls.

Accessibility Organizations

• Do not oppose KYC outright but urge the FCC to make accessibility and reasonable accommodations explicit compliance requirements.
• Primary concerns are inaccessible verification, rigid address rules, improper treatment of legitimate high-volume callers, service disruption without accessible notice/cure, and barriers for Deaf/Blind users.

Americans for Mobile Freedom

• Opposes the broad KYC mandate as overbroad and privacy-invasive.
• Argues mandatory ID/address collection would harm domestic violence survivors, journalists, whistleblowers, law enforcement, and prepaid users while doing little to deter sophisticated robocallers.
• Recommends behavioral monitoring, minimal data collection, STIR/SHAKEN, and privacy-protective safe harbors instead.

Better Identity Coalition

• Supports stronger identity verification to combat fraud, especially for organizations making calls at scale.
• Warns that government-ID mandates for ordinary consumers could block access for people without ID.
• Recommends focusing new KYC rules on “high volume” callers rather than individual consumers.

California Partnership to End Domestic Violence

• Argues expanded KYC could endanger survivors by treating privacy-protective practices—substitute addresses, new numbers, minimized digital footprints, limited documentation—as suspicious.
• Urges the FCC not to adopt broader KYC measures without a fuller survivor-safety and privacy record.

Cloud Communications Alliance

• Strongly supports FCC anti-robocall goals and robust KYC, but emphasizes independent third-party caller identity verification, portable cryptographic identity credentials, and alignment with branded calling rather than relying only on originating-provider KYC.

Consumer Access and Choice Coalition

• Supports stopping illegal robocalls but opposes broad “bank-style” KYC for ordinary consumer services.
• Says blanket KYC would raise costs, reduce competition, create privacy/cybersecurity risks, exclude vulnerable users, and fail to stop sophisticated bad actors.

CTIA

• Supports robust KYC and enforcement, especially for business/high-risk contexts, but urges the FCC to preserve flexible approaches.
• Warns consumer KYC mandates could harm onboarding, prepaid access, affordability, competition, privacy, and vulnerable populations.

Electronic Frontier Foundation (EFF), American Civil Liberties Union (ACLU)

• Mass collection of consumer identity data will not stop robocalls.
• Creates privacy and cybersecurity risks.
• Telecom providers have poor data-security track records.
• Threatens anonymous speech.
• Could exclude vulnerable populations (unhoused individuals, people without IDs, abuse victims, immigrants, low-income consumers).

First Citizens Bank

• Supports stronger KYC requirements for originating providers.
• Believes inadequate customer vetting allows scam callers to originate fraud calls.
• Wants stricter verification to keep bad actors off telecom networks.

Gigs Wireless

• Supports anti-robocall efforts but opposes unnecessary duplicate KYC checks.
• Wants exemptions when identity has already been verified by trusted third parties (e.g., banks, employers, universities, healthcare systems).
• Concerned about privacy and data-retention risks from unnecessary collection.

Incognia

• Supports stopping illegal calls but argues document-based KYC is ineffective.
• Favors risk-based, outcomes-driven controls using behavioral monitoring, device intelligence, and automated fraud detection.
• Concerned about AI-generated identities, data breaches, privacy risks, and barriers to service adoption.
• Seeks a safe harbor for effective anti-abuse systems.

INCOMPAS

• Supports baseline KYC requirements and stronger anti-fraud measures but opposes rigid mandates.
• Advocates a safe-harbor framework, risk-based verification, and ongoing traffic monitoring (“Know Your Traffic”).
• Opposes mandatory IP collection, periodic re-verification, downstream blocking requirements, and broad per-call penalties.

Kansas Coalition Against Sexual & Domestic Violence (KCSDV)

• Expanded KYC would endanger survivors, impede access to emergency communications, require documents many survivors lack during crises, and expose location/privacy information.

Mackie Mobile LLC

• KYC creates a national identity-to-phone database, threatens privacy and constitutional rights, increases breach/security risks, burdens lawful users, and is less effective than conduct-based anti-robocall measures.

MBOA Technology Cooperative

• Opposes broad KYC expansion, government-ID retention, and alternate-number requirements.
• Favors stronger scrutiny for high-volume/business customers, safe harbors, and risk-based approaches.

National Network to End Domestic Violence (NNEDV)

• Proposed KYC could treat survivor safety practices as fraud indicators, create barriers for abuse survivors, increase risks from verification communications and data retention, and expose sensitive survivor information.

NCTA—The Internet & Television Association

• Supports combating robocalls and existing KYC practices but opposes prescriptive enhanced KYC requirements, sensitive-data collection/retention, mandatory re-vetting, and punitive provider liability.
• Favors flexible, risk-based rules and safe harbors.

Nevada Coalition to End Domestic and Sexual Violence (NCEDSV)

• Expanded KYC could endanger survivors, penalize use of PO boxes/mail forwarding, disadvantage people lacking documents or stable housing, and create privacy and data-retention risks.

New York State Public Service Commission (NYSPSC)

• Supports stronger KYC and blocking of traffic from noncompliant providers, but seeks strict privacy protections, minimal data retention, secure verification methods, and enhanced scrutiny of high-risk customers.

NTCA—The Rural Broadband Association

• Supports anti-robocall goals but opposes broad KYC mandates.
• Wants risk-based rules focused on high-volume callers, safe harbors, flexibility for providers, and protection against excessive compliance burdens on small rural carriers.

Numeracle, Inc.

• Strongly supports robust KYC as the most effective anti-fraud tool.
• Advocates risk-based enhanced verification, ongoing monitoring and re-verification, third-party identity vetting, stronger accountability at origination, and verified caller identity.

Private Tech Inc. (d/b/a Cape)

• Argues universal KYC creates major privacy, security, and national-security risks, lacks proven effectiveness, burdens vulnerable populations, and should be replaced with targeted, risk-based requirements focused on high-volume and foreign-originated traffic.

Prove Identity, Inc.

• Supports enhanced KYC but argues collection alone is insufficient.
• Advocates standardized, outcome-based multi-layer identity verification, identity persistence, verification of phone ownership, stronger controls for MVNOs, SIM swaps, SIM boxes, VoIP abuse, and beneficial ownership verification.

Provenant, Inc.

• Takes no position on whether enhanced KYC should be adopted, but supports rules that can leverage open, standards-based organizational identity infrastructure.
• Opposes prescriptive requirements that foreclose interoperable identity verification frameworks or favor specific vendors.

Somos, Inc.

• Supports stronger KYC but urges a risk-based framework tied to verified right-to-use (RTU) of telephone numbers, caller identity, continuous verification, standards-based interoperability, and minimized retention of sensitive identity documents.

Sorenson Communications, LLC and CaptionCall, LLC

• Supports anti-robocall KYC efforts but seeks exemption for internet-based Telecommunications Relay Service (TRS) providers until broader STIR/SHAKEN and TRS issues are resolved.
• Argues existing TRS identity-verification requirements already address KYC concerns.

Telnyx LLC

• Opposes prescriptive, one-size-fits-all KYC mandates.
• Argues identity checks are easily bypassed, create privacy and data-security risks, burden consumers and providers, and should be replaced with risk-based KYC, traffic monitoring, AI-driven fraud detection, traceback cooperation, and safe harbors.

TextNow, Inc.

• Opposes universal front-end identity collection (government ID, address, alternate number).
• Argues that it would exclude lawful users, create privacy/security risks, burden free consumer services, and should be replaced with a risk-based, behavior-triggered safe harbor using analytics, traceback, and targeted verification.

Transatel

• Supports KYC generally but seeks exemptions for Closed User Group (CUG) services such as connected vehicles, emergency devices, and IoT endpoints.
• Argues such services cannot originate robocalls, and requiring end-user identification would impose unnecessary costs, privacy risks, and operational burdens.

Twilio Inc. and Twilio US Technology Inc.

• Supports enhanced KYC requirements for originating voice providers, especially business customers.
• Advocates mandatory identity verification, KYT (Know Your Traffic) monitoring, heightened scrutiny for high-risk and foreign-affiliated customers, and a safe harbor for providers with enhanced compliance programs.

Unified Office, Inc.

• Supports a national KYC baseline and reasonable business-customer onboarding requirements.
• Opposes downstream carrier call blocking and spam labeling after KYC vetting is completed.
• Opposes per-call forfeitures absent settled rules and seeks safe-harbor protections for compliant providers.

USTelecom—The Broadband Association

• Supports KYC best practices but opposes prescriptive, one-size-fits-all mandates.
• Advocates flexible, risk-based, industry-developed safe harbors focused on business customers.
• Raises concerns about privacy, compliance costs, prepaid service impacts, excessive record-retention requirements, and proposed per-call penalties.

Verizon

• Supports robocall enforcement goals but opposes prescriptive, universal KYC mandates.
• Favors stronger enforcement against known bad actors, expanded call-blocking authority, and risk-based/provider-specific KYC.
• Raises privacy, cybersecurity, consumer access, and compliance burden concerns.

Violence Free Minnesota

• Argues KYC requirements would harm domestic violence survivors by requiring physical addresses, government IDs, alternate contacts, and automated verification.
• Raises safety, privacy, and accessibility concerns.

Voice on the Net (VON) Coalition

• Supports risk-based KYC and safe harbors but opposes rigid mandates, per-call penalties, mandatory re-verification, mandatory third-party vetting, IP-address collection, and technology-specific requirements.

Wisconsin Bankers Association (WBA)

• Strongly supports enhanced KYC requirements and per-call penalties.
• Argues stronger customer verification is needed to stop bank impersonation scams, spoofing, and fraud.

WISPA—The Association for Broadband Without Boundaries

• Supports enhanced KYC but advocates risk-based tiering.
• Opposes universal ID collection, annual re-verification, mandatory tools, and burdens on small/rural providers.
• Seeks safe harbors and extended implementation timelines.

ZipDX LLC

• Supports stronger KYC tied to caller authentication and accountability.
• Advocates mandatory A-level STIR/SHAKEN attestation, branded calling for high-risk traffic, verified caller identity information, and greater transparency for call recipients.

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