Flood of comments received for FCC's proposed KYC rules
The Federal Communications Commission issued a Further Notice of Proposed Rulemaking to require Originating Service Providers to implement more extensive and explicit Know-Your-Customer (KYC) procedures. A flood of comments has been filed with the Commission on the proposed rules. Let's have a look.
The proposed rules
The KYC rules described in the Commission's Further Notice of Proposed Rulemaking (FNPRM) would enact the following requirements:
- Originating Service Providers (OSPs) would be required to obtain certain identification information from both new and renewing customers. At a minimum, this would include:
- Name
- Physical address
- Government-issued identification number
- An alternative telephone number.
- In addition, for business, high-volume, and foreign customers, OSPs would have to collect:
- Intended use of the service
- Customer's IP address from which each call will be placed.
Initial comments
The Commission seeks comments on the FNPRM. The adopted FNPRM was published in the Federal Register on May 26, 2026. Therefore, comments are due on or before June 25, 2026.
At press time, approximately 332 comments have already been received and disseminated on the Commission's Electronic Comment Filing System. This is a lot. Most appear to be from individual citizens. We did not read all of them, but reviewing a sample showed the following recurring themes:
- Commenters object to providing extensive personal information to get a phone. It's a privacy issue.
- Concerns that their personal information would be subject to a data breach.
- Unconvinced that collecting this information would be effective in deterring robocalls.
- Argue that some people have a legitimate need to protect their identity when using their phone.
- One organization commented that perhaps the Commission should distinguish between ordinary private citizens who make low-volume calls versus high-volume callers.
- The Commission mentioned this possibility in the FNPRM and requested comment.
Our perspective
This FNPRM has apparently touched a nerve among some consumers. The privacy concerns seem a fair point. We expect the Commission will weigh these concerns against the burden of illegal robocalls. Consumers have had it with unlawful robocalls, but some also have concerns about privacy and overreach by a “big brother” government. It's a balancing act to address both concerns, which seem to pull policy decisions in opposite directions.
Would stronger KYC procedures make a dent in unlawful robocalls? Well, we think it's more difficult to mitigate illegal traffic without knowing the customer well, and it's impossible to give a legitimate full A-level attestation without strong KYC.
However, our monthly STIR/SHAKEN and robocall statistics tell us that there are a small number of prolific robocall signers who seem intent on serving bad traffic no matter what. Stronger KYC rules might not prevent them from signing bad traffic, but they would provide additional tools for enforcement against the bad traffic that they originate and authenticate.
We will be watching developments on this initiative closely.

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