Robocall Mitigation Database recertification guidance

The FCC provided guidance on how a service provider should recertify their Robocall Mitigation Database (RMD) filing. The first annual mandatory recertification deadline is approaching fast. Let’s review the highlights.

Recertification requirements

Updated RMD rules require service providers to:

• Recertify annually
• Pay a $100 fee with certification filings
• Update filings within 10 business days after a change in information occurs

The new rules include stiff penalties for failure to comply:

• $10,000 per violation of submitting false or inaccurate information
• $1,000 for failure to update information that has changed within 10 business days

The recertification deadline is March 1, 2026.

Recertification guidance

Instructions

TransNexus does not provide legal guidance. However, we are happy to share the information we find in the Commission documents with our readers. If you feel that you need guidance above and beyond what the Commission has provided, then we encourage you to consult with your legal counsel.

Since its inception, the Commission's RMD webpage has provided a link to an instructions document. They updated this document in January 2026 with instructions for Submitting an Annual Recertification on pages 26–28. The recertification process involves the following steps:

1. Log in to the account used to file your RMD certification.
   • This uses a CORES username and password.
2. You will see a list of your submitted filings. Click the filing that you want to recertify.
3. Click the Recertify button at the top right of the form.
   • The Recertify button will only appear during the annual recertification filing window, which opens on February 1 each year.
4. Make any changes to the editable fields and upload a robocall mitigation plan document as necessary to bring this filing up to date with the current requirements.
5. Fill out the Declaration section and click Submit.

Frequently Asked Questions

The RMD Frequently Asked Questions is a new document that the Commission provided on January 20, 2026. It includes eight pages of questions and answers that cover a wide range of topics. Here are a few examples (not a complete list):

• Who must file?
• What should be included in the “Principals, Affiliates, Subsidiaries, and Parent Companies” section of the form?
• When should a provider certify a complete STIR/SHAKEN implementation?
• What is required of providers who certify to less than complete STIR/SHAKEN implementation?
• How should a provider certify when it uses a third party to authenticate its calls?
• Are providers required to use data analytics in robocall mitigation?
• Are providers required to have Know-Your-Customer (KYC) procedures?

And there are other topics covered, too. As you can see, one can learn a lot by reviewing this information.

Filing fee

The new filing rules stipulate that both new and recertifying filers will be required to pay a $100 fee. However, page 7 of the FAQ document clarifies this as follows:

In the future, providers will also be required to pay a $100 annual recertification fee, and the Commission will announce when this requirement becomes effective.

More information

• FCC Robocall Mitigation Database
• RMD Submission Instructions
• RMD Frequently Asked Questions
• Public Notice announcing the effective date for the recertification and other rules.
• Rules published in the Federal Register
• Report and Order

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