On July 23, 2026, the FCC voted to initiate a Further Notice of Proposed Rulemaking (Further Notice) in Docket 24-213 to strengthen and improve the accuracy of the Robocall Mitigation Database (RMD). The Commission stated:
The RMD has become a central tool in the Commission’s efforts to stop illegal calls by promoting transparency and accountability for providers robocall mitigation practices. Today, all voice service providers are required to submit a filing in the RMD that includes critical information about their business and their robocall mitigation practices, and downstream providers are only permitted to accept calls from providers whose filings appear in the Database and have not been removed by a Commission enforcement action. (Further Notice at para. 2).
Unfortunately, as in every other industry, telecommunications must deal with occasional bad actors. In the robocall world, these companies illegally enter or reenter the RMD, and their traffic ultimately reaches end users as unwanted robocalls. The FCC has decided to take steps to end this cheating by strengthening the filings carriers must make in the RMD.
In the Further Notice, the Commission proposes that all providers of voice grade service must file into the database:
Any service that is interconnected with the public switched telephone network and that furnishes voice communications to an end user using resources from the North American Numbering Plan or any successor to the North American Numbering Plan adopted by the Commission under section 251(e)(1) of the Communications Act of 1934 [(the Act)], as amended; and [i]ncludes— transmissions from a telephone facsimile machine, computer, or other device to a telephone facsimile machine; and [w]ithout limitation, any service that enables real-time, two-way voice communications, including any service that requires internet protocol-compatible customer premises equipment and permits out bound calling, whether or not the service is one-way or two-way voice over internet protocol. (Id. At para. 11, quoting the definition of voice service in the TRACED Act).
Newly included in this definition are PBXs, dialing platforms, cloud service providers, over-the-top service providers, call centers, value-added service providers, and telephone number service providers (TNSP) to the extent the services furnish voice communications to an end user using resources from the North American Numbering Plan,” including if they enable real-time, two-way voice communications, whether or not the service is one-way or two-way [VoIP].
Providers will have to submit information to the RMD in five categories.
Certification
Providers must certify that they follow the STIR/SHAKEN requirements, that they have not submitted false, misleading, or inaccurate information to the Commission; they follow all robocall rules and must respond to traceback requests within 24 hours.
Robocall Mitigation Information
The Commission strengthens the obligations for providers claiming STIR/SHAKEN implementation exemptions, adopts a temporary exemption for providers in the process of obtaining an SPC token, clarifies requirements related to prior enforcement actions or investigations, and requires providers to submit additional information regarding their use of third parties.
Business Identifying Information
The agency proposes to codify the existing requirement that providers submit information regarding their principals, affiliates, subsidiaries, and parent companies and to better specify what information they must provide.
Provider Type and Service Information
Providers must provide information on where they are in the call chain, specifically:
A voice service provider must indicate whether it is a facilities-based provider and/or a non facilities-based provider;
A facilities-based provider must indicate whether it is: (i) an originating or terminating voice service provider directly serving end users; (ii) an originating or terminating provider acting as a wholesale provider originating or terminating calls for end users it does not directly serve on behalf of another provider or providers; (iii) a gateway provider; and/or (iv) a non-gateway intermediate provider;
A non-facilities-based provider must indicate whether it is directly serving end users and/or whether it is a wholesale provider to another provider or providers that does not directly serve end users.
Robocall Mitigation Plan
The Commission proposes to enhance the general requirement that providers implement a robocall mitigation program to align with our expectations set out in existing and proposed rules. The plan must include “affirmative, effective measures” to stop illegal robocalls.
Industry comments on the Further Notice are due 30 days after it appears in the Federal Register.