The Robocall Mitigation Database: Who Must File and What a Filing Contains

The Robocall Mitigation Database is the FCC's public list of certifications from companies that originate or carry telephone calls. A provider that is not in it, or that has been removed from it, cannot hand its calls to other U.S. carriers.

Who has to file

Every voice service provider and every intermediate provider, including gateway providers. The FCC's guidance names VoIP resellers and mobile virtual network operators specifically.

• Voice service provider: a company whose service connects to the public telephone network and gives end users voice calling with North American Numbering Plan numbers.
• Gateway provider: a U.S.-based intermediate provider that receives a call directly from a foreign provider at its U.S. facilities before passing it downstream.
• Non-gateway intermediate provider: a company that carries or processes calls it neither originates nor terminates, and that is not acting as a gateway.

A company can be more than one of these, and certifies for each role. An affiliate or subsidiary that meets one of the definitions files its own certification. A foreign provider that sends calls with U.S. numbers directly to U.S. carriers needs a filing for that traffic to be accepted.

What a filing contains

• A STIR/SHAKEN certification: complete implementation, partial implementation, or none. Anything less than complete needs a stated extension or exemption and its basis.
• A robocall mitigation plan describing the specific reasonable steps the company takes to avoid illegal robocall traffic. See what the plan must contain.
• A traceback commitment: to respond within 24 hours to all traceback requests from the Commission, law enforcement and the industry traceback consortium, and to cooperate in stopping illegal robocallers.
• Enforcement history: whether the company, or any entity sharing its ownership, management, directors or control, has been the subject in the prior two years of a formal action or investigation involving illegal robocalls, spoofing, or a deficient filing.
• Company details: business names in use and formerly used, whether it is a foreign voice service provider, its provider type, its principals, affiliates, subsidiaries and parent companies, its OCN if it has one, and one named person responsible for robocall mitigation with title, department, address, phone and email.

The certification is signed by an officer. Everything is filed in English or with a certified English translation.

Why being listed matters

Voice service providers and intermediate providers may accept calls directly from another provider only if that provider's filing appears in the database and has not been removed through an enforcement action. Removal therefore cuts a company off from the U.S. telephone network, with exceptions only for 911 calls and calls from public safety numbers.

Keeping a filing current

• Update it within 10 business days of any change to the information in it. The base forfeiture for failing to do so is $1,000.
• Recertify it every year on or before March 1. An update does not count. See the recertification guide.
• The base forfeiture for submitting false or inaccurate information is $10,000.

How to see what your filing shows

The FCC publishes a listing of every filing with its provider type, STIR/SHAKEN option, last update and last recertification date. You can search that listing here by company name, RMD number or FRN.