FCC Know-Your-Upstream-Provider and SHAKEN rules adopted

In its May 2026 open meeting, the Federal Communications Commission adopted proposed rules to strengthen requirements that voice service providers Know Their Upstream Providers. The rules also clarify STIR/SHAKEN rules with explicit definitions and requirements that voice service providers must comply with. Let’s have a look.

Know-Your-Upstream-Provider

Voice Service Providers (VSPs) must take effective measures to prevent any directly upstream provider from using their network to transmit illegal calls.

• Collect business information directly from the upstream provider, verify it, and retain records for four years.
• Monitor the upstream provider using call analytics on an ongoing basis.
• Watch for evidence that the upstream provider is transmitting illegal calls, failing to authenticate calls, or authenticating calls with improper attestation.
• Investigate inconsistent information about that provider.

Raising STIR/SHAKEN attestation standards

The rules define attestation levels by paraphrasing the STIR/SHAKEN standards document ATIS-1000074 and relating portions of the attestation level definitions to relevant portions of the Know-Your-Customer requirements in §64.1200 of CFR Title 47.

Closing STIR/SHAKEN implementation loopholes

Move attestation determination closer to the call source

Perhaps the most consequential rule is the proposal to require attestation levels to be determined by the provider having a direct relationship with the end user, even if that provider is a reseller. The document refers to this entity as the initiating provider.

This could be done by requiring the initiating provider to obtain an SPC token, use that token to obtain certificates, make attestation-level decisions, and arrange with the originating provider to sign calls with the initiating provider’s certificate and attestation level.

Alternatively, the initiating provider could use delegate certificates with such calls, which the originating service provider could consider using to justify full attestation.

These proposed rules would have a huge impact on bringing attestation information and accountability closer to the call initiator—a fundamental objective of call authentication.

Define key terms to clarify rules

The updated rules add nine definitions in §64.6300 of Title 47 in the Code of Federal Regulations (CFR) to clarify STIR/SHAKEN rules.

For example, “voice service provider” includes intermediate providers, facilities-based and non-facilities-based providers, VoIP resellers, and MVNO (Mobile Virtual Network Operators).

“Foreign voice service provider” includes any voice service provider that was created, incorporated, or organized outside of the U.S., regardless of whether it has an office within the U.S.

A “domestic voice service provider” is a VSP that is not a foreign VSP.

These definitions clarify the application of rules to specific carrier types.

End STIR/SHAKEN implementation exemptions

The Commission proposed ending STIR/SHAKEN implementation exemptions for satellite providers and providers that cannot obtain an SPC token, and seeks comment on this proposal.

More information

The Further Notice of Proposed Rulemaking is for WC Docket No. 17-97 and CG Docket No. 17-5. Its document reference is FCC 26-32.

Paragraphs 1-137 include the Commission’s explanation and discussion of the issues and their requests for comments.

Paragraphs 138-144 explain the Commission’s view of its legal authority to enact these rules. This is important because the FCC cannot do whatever it wants without legal authority.

Appendix A provides the text of the proposed rules. We find it helpful to read the text to better understand how the Commission intends to implement its ideas.

Comments will be due 30 days after publication in the Federal Register, and Reply Comments will be due 60 days after publication in the Federal Register.

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