Robocall Mitigation Database: Questions and Answers

Short answers to the questions providers ask about the Robocall Mitigation Database. Each one ends with the rule section or FCC FAQ item it comes from.

What is the Robocall Mitigation Database?

It is the FCC's public database of certifications from voice service providers, gateway providers and intermediate providers. Each filing states the provider's STIR/SHAKEN status and includes a plan describing how it avoids originating or carrying illegal robocalls. (47 CFR 64.6305(d)-(f))

Who has to file?

All voice service providers and intermediate providers, including gateway providers, VoIP resellers and mobile virtual network operators. An affiliate or subsidiary that independently meets one of those definitions files separately. (FCC FAQ 1)

What must a robocall mitigation plan describe?

The specific reasonable steps the provider has taken to avoid illegal robocall traffic, including how it knows its customers or upstream providers, the analytics systems it uses and the names of any third-party analytics vendors, and its commitment to answer traceback requests within 24 hours and cooperate in stopping illegal robocallers. (47 CFR 64.6305(d)(2), (e)(2), (f)(2))

When is recertification due?

On or before March 1 every year. The FCC opens the recertification window on February 1. A filing first submitted in a given calendar year is first recertified the following year. (47 CFR 64.6305(h); FCC FAQ 17)

Does updating a filing count as recertifying it?

No. The FCC states that updating an existing filing will not fulfill the annual recertification requirement. (FCC FAQ 16)

How fast must a filing be updated when something changes?

Within 10 business days of any change to the information in the filing, including changes in ownership or control. The base forfeiture for failing to update is $1,000. (47 CFR 64.6305(d)(5), (e)(5), (f)(5); FCC FAQ 16)

What is the penalty for a false or inaccurate filing?

The FCC set a base forfeiture of $10,000 for submitting false or inaccurate information to the database. (Public Notice DA 26-72)

What happens when a filing is removed?

Intermediate providers and voice service providers must stop accepting calls directly from the removed company, and the company may not re-file without approval from the Enforcement Bureau and the Wireline Competition Bureau. (47 CFR 64.6305(g); Order DA 26-872)

Are providers required to use call analytics?

No, but a provider that uses analytics must describe the system and name any third-party vendor, and a provider should state whether or not it uses analytics. A provider relying on its underlying carrier's analytics should name that carrier. (FCC FAQ 12)

Can a provider certify complete STIR/SHAKEN implementation if part of its network is not IP?

No. Complete implementation is certified only when the entire network is IP-based. A provider with a non-IP portion selects partial implementation. (FCC FAQ 9)

Can a provider rely on the small voice service provider extension?

No. Those extensions expired on June 30, 2022 for non-facilities-based providers and June 30, 2023 for facilities-based providers. (FCC FAQ 10)

Can a third party sign calls for a provider?

Yes, as long as the provider makes the attestation decisions and all calls are signed using the provider's own certificate, not the third party's. (FCC FAQ 11)

Do foreign providers have to file?

A foreign provider that sends calls using U.S. numbers directly to U.S. providers must have a filing for that traffic to be accepted. It may certify to no STIR/SHAKEN implementation and state that it is a foreign provider. (47 CFR 64.6305(g)(2); FCC FAQ 2)

Can a plan be kept confidential?

A filer may request confidential treatment through ECFS in WC Docket No. 17-97 and upload redacted and unredacted copies. Filers should not redact the entire plan or information the rule specifically requires. (FCC FAQ 7)

Is there a fee?

The FCC has said providers will be required to pay a $100 annual recertification fee and that it will announce when that requirement takes effect. Updates to a filing carry no fee. (FCC FAQ 17)