Reply comments on Know-Your-Upstream-Provider rules

The FCC received many reply comments on its proposed Know-Your-Upstream-Provider (KYUP) rules. This article summarizes the filings and recurring themes. Let’s have a look.

The Commission adopted a Further Notice of Proposed Rulemaking (FNPRM) on KYUP in its May 2026 Open Meeting. We summarized the proposed rules in a blog post. These rules address the following:

• Establish specific KYUP requirements
• Clarify STIR/SHAKEN attestation levels
• Expand STIR/SHAKEN implementation requirements

Recurring themes

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

• 28% supported the proposed KYUP rules, while 44% were opposed.
  • Those in favor prioritized consumer protection.
  • Those opposed thought the rules are too prescriptive and lack the necessary flexibility.
• 12% urged the Commission to coordinate and consolidate the proceedings with overlapping coverage of these issues.
• 16% advocated for increased use of delegate certificates.
• 16% oppose giving the STI Governance Authority a stronger vetting role (including the STI GA, which filed reply comments on this).
• 16% of reply comments were filed by TRS (Telecommunications Relay Service) providers, who do not provide their own authentication but advocate that their calls should be given full A-level attestation.

Reply comments

There were 406 pages of reply comments from 25 submissions. We’ve summarized these comments below very briefly. If you’d like to see more information, you can click the filer’s name above each summary to read that organization’s filing.

49 State Attorneys General

• Strongly support mandatory, prescriptive KYUP requirements.
• Want stricter upstream-provider vetting, verification, monitoring, and responsive action.
• Favor stronger STI-GA oversight and token vetting.
• There is a need for improved attestation accuracy.
• Concerned that existing flexible rules allow bad actors to remain in the ecosystem.

52 State Bankers Associations

• Strongly support KYC, STIR/SHAKEN attestation requirements, and KYUP rules.
• Want providers to take greater responsibility for preventing spoofed and fraudulent calls.

Alliance for Telecommunications Industry Solutions (ATIS)

• Supports robocall mitigation goals.
• Opposes addressing numbering issues through multiple proceedings.
  • Wants numbering issues consolidated into a dedicated rulemaking.
• Opposes inclusion of numbering data in the Robocall Mitigation Database.

AT&T Services

• Supports stronger robocall enforcement and RMD vetting.
• Wants expanded call-blocking safe harbors.
• Opposes prescriptive KYUP requirements, burdensome recordkeeping, mandatory blocking of unsigned traffic, and STIR/SHAKEN rules that bypass ATIS standards processes.

ClearCaptions, LLC

• Supports the proposed framework.
• Seeks special treatment for IP CTS (Internet Protocol Captioned Telephone Service) providers, including:
  • Mandatory A-level attestation for IP CTS calls
  • Streamlined KYUP compliance based on FCC certification and RMD registration.

Consumer Reports

• Supports stronger KYUP and STIR/SHAKEN rules.
• Wants mandatory due diligence, audits, rapid suspension of bad actors, tighter SPC token controls, shorter certificate lifetimes, elimination of exemptions, and stronger enforcement against improper attestations.

CTIA

• Supports robocall mitigation goals.
• Opposes prescriptive KYUP mandates.
• Prefers RMD reforms, IP transition, flexible industry best practices with safe harbors, and preservation of ATIS attestation flexibility.
• The STI-GA should be limited to administrative rather than enforcement roles.

First Orion Corp.

• Supports stronger attestation, verified right-to-use, and banning pay-for-attestation.
• Opposes treating A/B attestations as proof of legitimacy or shielding calls from analytics, labeling, or blocking.
• Insists that branded calling should remain separate from attestation.

Hamilton Relay, Inc.

• Supports the goals of the rules.
• Argues TRS (Telecommunications Relay Service) providers need special treatment.
• Opposes one-size-fits-all requirements.
• Seeks recognition that existing TRS certification satisfies KYC/KYUP.
• Requests default A-level attestation treatment for authenticated PSTN-TRS calls.

IP Network-to-Network (IP-NNI) Task Force

• Supports anti-robocall efforts.
• Opposes FCC attestation requirements that diverge from ATIS standards or constrain future industry standards development.

KJONGSys LLC

• Supports moving attestation decisions closer to end users.
• Argues small non-facilities-based providers cannot practically obtain SPC tokens.
• Advocates mandatory support for delegate certificates, removal of OCN/RespOrg barriers, and retention of existing exemptions until token access issues are resolved.

National Consumer Law Center et al

The National Consumer Law Center (on behalf of low-income clients) filed a joint reply comment with National Consumers League, EPIC, and Consumer Action.

• Support stronger KYUP requirements.
• Advocate for no safe harbors, codified STIR/SHAKEN attestation standards, stronger enforcement, and clearer provider-role definitions.
• Want additional requirements to collect information about intended call traffic.

NCTA – The Internet & Television Association

• Supports incremental improvements.
• Opposes prescriptive, burdensome KYUP and attestation rules.
• Argues existing framework largely works; enforcement is the real problem.
• Seeks provider flexibility, risk-based approaches, centralized KYUP solutions, and liability safe harbors.

Pinger, Inc.

• Supports stronger enforcement against known bad actors.
• Opposes new burdens on compliant providers.
• Wants attestation authority assigned to the provider with customer knowledge.
• Opposes private-provider exclusion decisions.
• Favors Commission-controlled enforcement, notification frameworks, and due-process protections.

Somos, Inc.

• Supports codifying attestation rules and preserving caller right-to-use credentials.
• Wants responsibility tied to number assignment rather than routing.
• Favors delegate certificates, standards-based authentication, credential-based safe harbors, and coordination across related FCC proceedings.
• Questions some KYUP collection/retention approaches.

Sorenson Communications, LLC and CaptionCall, LLC

• Supports KYUP/STIR reforms but seeks TRS-specific accommodations.
• Wants Internet-based TRS (Telecommunications Relay Service) providers with direct end-user relationships to make attestation decisions.
• Supports delegate certificates.
• Opposes one-size-fits-all KYUP/KYC requirements.
• Urges coordination across related proceedings.

Secure Telephone Identity Governance Authority

• Supports robocall mitigation goals.
• Opposes expanding STI-GA into an investigative/enforcement body.
• Opposes subjective “unlikely to comply” standards.
  • Wants stronger RMD vetting instead, limited STI-CA responsibilities, longer implementation timelines, and safe-harbor protections.

TextNow, Inc.

• Supports the KYUP framework with modifications.
• Opposes facilities-based definitions that could prevent providers from signing their own calls.
• Opposes turning STI-GA into a vetting body.
• Seeks objective token eligibility rules, limits on mandatory discontinuance, preservation of due process.
• Rejects blocking or labeling based on signer reputation alone.

Transaction Network Services, Inc.

• Supports KYUP efforts but wants a technology-neutral, solution-agnostic framework.
• Opposes reliance on any single data source or technology.
• Supports use of multiple risk signals.
• Wants terminating providers to retain flexibility to block or label calls even when calls carry A- or B-level attestation.

USTelecom – The Broadband Association

• Supports robocall mitigation.
• Opposes prescriptive KYUP mandates.
• Advocates flexible risk-based best practices with safe harbors, stronger RMD gatekeeping, targeted enforcement against bad actors, proportional penalties, voluntary use of third-party vetting, and preserving blocking authority for suspicious calls even with high-level attestations.

Verizon

• Supports anti-robocall goals.
• Opposes prescriptive KYUP and attestation mandates.
• Favors strengthening the RMD, completing the IP transition, enforcing existing rules, preserving industry standards, and accommodating complex resale arrangements.

Voice on the Net Coalition

• Supports flexible, risk-based KYUP rules.
• Opposes proprietary verification mandates, disproportionate liability, third-party regulatory gatekeeping, and restrictions preventing initiating providers from signing calls.

WISPA – The Association for Broadband Without Boundaries

• Supports end-user providers making attestation decisions.
• Opposes mandatory SPC tokens.
• Seeks flexibility for smaller providers and resellers to use delegate certificates, billing systems, or other reliable mechanisms.

ZipDX LLC

• Supports mandatory signer-reputation tools, centralized FCC vetting through the RMD, intermediate-provider monitoring and remediation, expanded STIR/SHAKEN coverage, and stringent per-call liability with a narrow safe harbor.

ZP Better Together, LLC

• Supports robocall mitigation but seeks special treatment for TRS/VRS calls:
  • Mandatory A-level attestation by underlying providers,
  • Exclusion of TRS providers from the voice-service-provider definition,
  • No new TRS certification or signing mandates.

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