The Federal Communications Commission (FCC) has released a draft Further Notice of Proposed Rulemaking (FNPRM), outlining a series of reforms aimed at modernizing its robocall regulations, reducing compliance burdens, and strengthening consumer protections. For businesses that rely on call and text communications, these proposed changes could significantly reshape compliance obligations under the Telephone Consumer Protection Act (TCPA) and Do Not Call (DNC) rules.
Part of Chairman Brendan Carr’s “Delete, Delete, Delete” initiative, the Call Branding FNPRM targets two major goals:
- Stopping illegal calls, particularly those that originate outside the U.S., before they reach consumers
- Empowering consumers with verified caller information to make informed decisions on whether to answer a call or not
While the STIR/SHAKEN framework has helped reduce spoofed calls by authenticating caller numbers, it does not verify the caller’s identity. The new rules aim to close that gap and address the growing threat of illegal calls originating from outside the United States.
At forty-four pages, the document covers a lot of ground. Here’s a look at some of the key proposed changes—and what they could mean for businesses.
1. Eliminating Outdated Call Abandonment Rules
The FCC proposes removing rules that:
- Prohibit disconnecting unanswered calls before 15 seconds or four rings
- Limit abandoned calls to 3% of total telemarketing calls
Impact: This could reduce compliance costs for businesses using predictive dialers, though it may create inconsistencies with the FTC’s Telephone Sales Rule’s requirements.
2. Eliminating or Streamlining Company-Specific DNC Lists (UPDATE 11/3/25: this proposed change was removed from the adopted FNPRM; internal DNC list rules will remain in effect)
Currently, businesses must maintain their own internal DNC lists in addition to checking the National DNC Registry. The FCC is proposing eliminating this duplicative requirement, arguing that the national list and consent rules may already offer sufficient consumer protection.
Impact: Reduced administrative burden, but potential loss of consumer control over unwanted calls from specific businesses.
3. Modernizing Caller Identification Rules
The FCC proposes replacing outdated callback number requirements for artificial and pre-recorded voice calls with a mandate for a working, verifiable number that:
- Identifies the caller
- Accepts opt-out requests
Impact: This aligns with modern caller ID expectations and supports Rich Call Data (RCD), which allows businesses to transmit verified identity information like name, logo, and call purpose.
4. Strengthening Caller Identity Verification
The FCC proposes that:
- Terminating providers must transmit verified caller identity (e.g., name) to consumers when displaying A-level STIR/SHAKEN attestation
- Originating providers must take reasonable steps to verify the accuracy of caller identity information
Impact:
- A-level attestation alone is confusing without identity context
- Verified caller ID builds trust, improves answer rates, and reduces fraud
- The FCC seeks input on how to define “reasonable” verification, whether standards should vary by caller type (e.g., business vs. individual), and how to handle sensitive or privacy-protected calls
5. Ensuring Secure Transmission of Caller Identity
The FCC is exploring whether to:
- Mandate secure transmission of caller identity using RCD standards
- Prevent tampering or alteration of identity data in transit
Impact: This would ensure end-to-end integrity of caller information, benefiting both consumers and legitimate businesses.
6. Addressing Foreign-Originated Calls
The FCC proposes:
- Requiring gateway providers to label foreign-originated calls
- Mandating intermediate and terminating providers to pass this information to consumers
- Considering prohibitions on spoofing U.S. numbers for foreign-originated calls
Impact:
- Helps consumers identify potentially fraudulent international calls
- Could reduce scam calls and encourage domestic call center use
- Raises questions about how to handle roaming U.S. users abroad and calls from trusted foreign partners
7. Narrowing Consent Revocation Rules
Two major changes are under review:
- All-or-nothing opt-outs may be eliminated or narrowed in favor of a more nuanced approach, allowing revocation by call type, business unit, or location
- Businesses may be allowed to designate specific revocation method such as a web form or phone numbers, replacing the current “reasonable means” standard
Impact: These changes could reduce legal risk and operational complexity, especially for businesses with multiple service lines. Clear disclosures and user-friendly processes could mitigate potential consumer frustration.
8. Eliminating Redundant Call Blocking Rules
The FCC proposes removing permissive call blocking rules that have been overtaken by mandatory requirements, such as blocking:
- Numbers on the Do-Not-Originate (DNO) list
- Invalid or unused numbers
Impact:
Permissive blocking is now mandatory; therefore, removing the permissive blocking will have no impact on entities with a blocking requirement.
9. Reducing Small Business Burdens
To reduce burdens on small businesses, the FCC suggests:
- Making caller ID requirements apply only when a provider chooses to display A-level attestation
- Allowing flexibility in implementing RCD and identity verification standards
Impact: This approach balances modernization with the operational realities of smaller providers on whom the increased cost of RCD transmission could be prohibitive.
What’s Next?
The FCC will vote on this FNPRM at its October 28, 2025 Open Meeting. If adopted, a 30-day public comment period will follow its publication in the Federal Register.
Much more to come as we will be watching this one closely.
