The Federal Communications Commission has set a February 26, 2024 filing deadline for all providers in the call chain, regardless of STIR/SHAKEN status or whether they have the facilities to implement STIR/SHAKEN, to file updated certifications and expanded robocall mitigation plans to the Robocall Mitigation Database (RMD).
Beginning on May 28, 2024, all voice providers and intermediate providers must refuse to carry traffic from any provider that is not listed in the RMD as of that date. The FCC's Notice follows the Sixth Caller ID Authentication Report and Order which was released on March 17, 2023, and previously discussed here.
By February 26, 2024, all providers must submit or resubmit a filing to the RMD that includes the following:
- Certification. A certification stating that all calls originated on the provider’s network are subject to a robocall mitigation program meeting the FCC’s requirements, that a prior certification has not been removed by FCC action nor has the provider been prohibited from filing in the RMD, and whether the provider has fully, partially, or not implemented STIR/SHAKEN on the IP portions of their networks.
- Expanded Robocall Mitigation Plan. A robocall mitigation plan that describes the specific “reasonable steps” the provider has taken to avoid the origination, carrying, or processing of illegal robocall traffic as part of its robocall mitigation program. To fulfill the specificity requirement, the following must be included:
- Voice service providers must describe how they meet their existing obligation to take affirmative, effective measures to prevent new and nonrenewing customers from originating illegal calls (must describe any contractual provisions with end-users or upstream providers designed to mitigate illegal robocalls).
- Non-gateway intermediate providers and voice service providers must, like gateway providers, describe any “know-your-upstream provider” procedures in place designed to mitigate illegal robocalls (must describe any contractual provisions with end-users or upstream providers designed to mitigate illegal robocalls).
- All providers must describe call analytics systems used to identify and block illegal traffic, including whether they use a third-party vendor or vendors and the name of the vendor(s).
Gateway providers must also submit a description of how they have complied with “know-your-upstream provider” requirements.
- Additional Information. New and existing filers must also submit:
- The role(s) they play in the call chain (must disclose all, if multiple).
- Detailed information supporting any claimed implementation extension or exemption of STIR/SHAKEN requirements.
- Information regarding a provider’s principals, affiliates, subsidiaries, and parent companies.
- Whether they are subject to an FCC, law enforcement, or regulatory agency action or investigation due to suspected unlawful robocalling or spoofing and provide details on the same.
- The filer’s Operating Company Number, if they have one.
Non-gateway intermediate providers whose filings were imported into the RMD via the Intermediate Provider Registry will need to submit a new robocall mitigation plan and complete the certifications. Imported filings will be removed from the RMD as they are no longer sufficient.
