FCC proposes robocall scorecard for providers
The FCC has proposed establishing and publishing a robocall mitigation scorecard for voice service providers. The scorecard would provide the public with an assessment of the effectiveness of robocall mitigation efforts of voice service providers.
Scorecard goals
FCC Chairman Brendan Carr explained the purpose of the robocall mitigation scorecard.

“[T]he FCC aims to develop a Scorecard that will give consumers more information about the measures providers are taking to fight illegal robocalls,” said FCC Chairman Brendan Carr, “and it will also incentivize providers to improve their efforts.”
Which providers would be rated?
The notice proposes that only domestic voice service providers with retail customers would be included. This would exclude the following provider types (note that these terms are overlapping and duplicative):
- Wholesale
- Intermediate
- Gateway
- Non-gateway intermediate
Data sources and metrics
The notice suggests the following data sources:
- Robocall Mitigation Database
- Provider-offered consumer tools or services
- FCC Consumer Complaints Center data
- FCC enforcement action data
- Industry traceback data
- FTC complaint data
The notice describes two categories of metrics to be gathered from these sources:
Conduct-based metrics
- Offers consumer tools to block or label calls
- Shows efforts to label or block calls in their network
- Responsiveness to traceback requests
Outcome-based metrics
Outcome-based metrics would include the volume, percentage, and trend data of:
- Illegal robocalls received by subscribers
- Consumer complaints
- Calls blocked
- False positives
Our first take
We are strongly in favor of using STIR/SHAKEN information and call analytics to protect subscribers from illegal robocalls.
At first glance, however, we think it might be difficult to implement a fair, impartial process to collect, analyze, and distribute this information.
Here are some questions that occurred to us right off the bat:
- How would the process protect against a flood of invalid complaints made for anticompetitive reasons?
- We find that the identity of the SHAKEN authentication provider is often an important data point in identifying and mitigating bad calls.
- In our most recent STIR/SHAKEN statistics blog post, we found that only 54.8% of calls at termination had STIR/SHAKEN information intact, usually because the call traveled a non-IP segment along the call path. This is no fault of the terminating provider, yet they would be at a disadvantage in a scorecard rating because they would have less data for call analytics.
- These providers would be incentivized to block unsigned calls, which is unfair to callers and originating service providers whose calls were routed over non-IP segments through no fault of their own.
- The Registered Traceback Consortium has explained that it does not investigate every traceback request. It prioritizes the ones that it believes might have the greatest impact on consumers.
- While this makes sense from an optimization perspective, it would introduce a potentially unfair random aspect into service provider scorecard analytics.
- Perhaps call blocking notification activity with SIP 603+ should be another metric?
- Perhaps intermediate providers should be included?
- We know that some of them route calls over non-IP segments, which removes STIR/SHAKEN information from the call.
- This has a big impact on the ability of downstream providers to mitigate illegal calls. Shouldn’t these intermediate providers be held accountable for this in their scorecard?
These questions leave us with mixed feelings about the proposed scorecard. We’re strongly in favor of robust call analytics, but it should be fair to all participants in evaluating the things they control.
We’ll be watching this closely.
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