On July 1, 2026, the FCC circulated a Further Notice of Proposed Rulemaking (NPRM) that would significantly strengthen the Robocall Mitigation Database, the filing system that determines whether providers may send traffic into the U.S. voice network. If adopted, the proposal would make the RMD a more active compliance gatekeeper by expanding practical filing exposure, increasing required disclosures, and giving the FCC stronger tools to screen, suspend, remove, and potentially bar non-compliant providers.
Key Takeaways on the FCC Proposal
- Broader Practical Coverage: Traditional voice providers, gateway providers, non-gateway intermediate providers, VoIP resellers, MVNOs, and relevant foreign providers are already within the RMD framework, but the NPRM could bring new scrutiny to PBXs, dialing platforms, cloud service providers, OTT providers, call centers, value-added-service providers, and telephone number service providers that furnish voice communications using NANP resources.
- More Demanding Filings: Current filers would face more detailed certification, ownership, business-identification, STIR/SHAKEN exemption, vendor, KYC, KYUP, and robocall mitigation plan requirements.
- Faster Enforcement Tools: The FCC proposes stronger screening, pending-status, suspension, removal, reinstatement, and participation-bar mechanisms, including expedited removal for serious violations and potential financial assurance requirements such as letters of credit.
Why the FCC Proposal Matters
The FCC’s stated objective is to improve the “reliability, integrity, and effectiveness” of the RMD as part of its broader illegal-call prevention framework. Today, downstream providers may accept calls only from providers whose RMD filings appear in the database and have not been removed through Commission enforcement action. The Commission is concerned that deficient filings, false business information, recycled entities, and evasive re-filings can undermine that system.
The NPRM therefore proposes to strengthen both sides of the RMD regime. First, it would require more complete and verifiable information from filers. Second, it would give the FCC more tools to screen, suspend, remove, and potentially bar providers and associated individuals from RMD participation.
This is certainly not the first time the Commission has proposed strengthening RMD filing requirements, but the proposals included in the current NPRM are far more impactful in their potential scope.
FCC Filing Obligations Expand to Cover Voice-Adjacent Platforms and Services
The most important coverage issue is the FCC’s proposed clarification of who qualifies as a “voice service provider.” Existing RMD filers include originating and terminating providers, gateway providers, non-gateway intermediate providers, VoIP resellers, MVNOs, and foreign providers whose RMD status is necessary for domestic providers to accept certain traffic using U.S. NANP resources.
If adopted as drafted, the proposal could reach well beyond companies that traditionally view themselves as telecommunications carriers. The FCC states that “voice service” may include PBXs, dialing platforms, cloud service providers, over-the-top service providers, call centers, value-added-service providers, and telephone number service providers to the extent they furnish voice communications to an end user using NANP resources or enable real-time, two-way voice communications.
In practical terms, companies already filing in the RMD would face more detailed compliance obligations, while voice-adjacent platforms and service providers that have not historically viewed themselves as RMD filers should reassess their role in the call path. The FCC says it does not intend to change the scope of who is a voice service provider, but its proposed clarification would likely create new compliance pressure for entities that have relied on narrower interpretations of the existing rules.
What Would Change for RMD Filings
For current filers, the NPRM would make filings more structured and easier to validate. The FCC proposes to codify five filing categories: certifications, robocall mitigation information, business identifying information, provider type and service information, and the robocall mitigation plan.
The proposal would also require stronger certifications, including certifications regarding compliance with illegal-call rules, lack of false or misleading submissions, traceback cooperation, and certain STIR/SHAKEN attestation obligations. Providers claiming STIR/SHAKEN exemptions would need to cite the specific rule supporting the exemption and explain, with provider-specific facts, why the exemption applies.
The FCC also proposes to require more detailed ownership, affiliate, business-address, service, and third-party vendor information. Notably, the Commission seeks disclosures about third parties used for call analytics, STIR/SHAKEN signing, KYC and KYUP functions, and RMD filing assistance, while making clear that the provider remains responsible for compliance.
A Higher Mitigation Standard
The NPRM would raise the general mitigation standard from “reasonable steps” to “affirmative, effective measures” to prevent a provider’s network or services from being used to transmit illegal calls. The FCC also proposes to broaden the focus from “illegal robocalls” to “illegal calls,” aligning the RMD rules more closely with KYC, KYUP, call blocking, and traceback obligations.
Mitigation plans would need to contain more detailed descriptions of the provider’s practices, including KYC and KYUP processes, call analytics measures, and contractual provisions addressing robocall mitigation. The FCC also proposes to require mitigation plans to be submitted as machine-readable PDFs, citing concerns that non-searchable filings hinder compliance review.
More Aggressive Screening and Removal Tools
The NPRM would give the FCC clearer authority to reject, withhold, or place into pending status RMD filings that appear non-compliant, evasive, connected to removed providers, or otherwise likely to present grounds for enforcement. The Commission also seeks comment on whether RMD filers should be required to provide letters of credit or similar financial assurances, potentially to deter shell entities and improve collection of forfeitures.
The proposed removal grounds are broad. They include deficient or materially inconsistent filings, lack of candor, missed recertifications, traceback violations, enabling illegal calls, inadequate mitigation, failure to cooperate with investigations, impersonation, STIR/SHAKEN violations, national-security concerns, and repeat violations after reinstatement.
The FCC also proposes to formalize removal procedures, including an expedited two-step process with a proposed five-day response period for serious violations and a possible one-step removal process for egregious circumstances where pre-removal process would be unnecessary, impracticable, or contrary to the public interest.
Next Steps
The circulated document was released for tentative consideration and remains subject to change before final Commission action. If adopted, comments will be due 30 days after Federal Register publication and reply comments will be due 60 days after Federal Register publication. The proceeding will be permit-but-disclose, and filings may be submitted through ECFS in WC Docket Nos. 24-213 and 17-97 and CG Docket No. 17-59.
Companies already listed in the RMD should begin reviewing whether their filings, mitigation plans, STIR/SHAKEN exemption explanations, ownership disclosures, and vendor information would satisfy the proposed standards. Companies that operate dialing platforms, hosted PBX services, cloud communications tools, call-center infrastructure, number services, or other voice-adjacent offerings should evaluate whether the FCC’s proposed interpretation could bring them within the RMD framework.
