On August 6, 2025, the FCC’s Enforcement Bureau issued a sweeping order, removing 185 voice service providers from the Robocall Mitigation Database (RMD), effectively banning them from U.S. networks. This decisive action underscores the Commission’s intensifying efforts to combat illegal robocall traffic and enforce compliance with its updated mitigation rules.
The providers were delisted for allegedly failing to meet critical compliance obligations related to their robocall mitigation plans. Last year, the Commission implemented stringent new rules for VSPs, which required them to revise their existing RMD filings by February 26, 2024. A deadline of December 31, 2024, was given to 2,411 VSPs to cure deficient RMD filings or face penalties that could include removal from the RMD.
What Removal from the RMD Means
Make no mistake: removal from the RMD is not symbolic—it’s operationally devastating. All intermediate and voice service providers were directed to cease accepting traffic from the delisted companies by August 8th, just two business days after the Order’s release. These providers are now effectively cut off from the U.S. telecom ecosystem and cannot refile without approval by the FCC’s Enforcement Bureau and Wireline Competition Bureau.
For businesses relying on these providers, this could mean:
- Sudden disruptions in outbound communications
- Increased risk of call blocking or mislabeling
- Exposure to enforcement scrutiny if traffic is routed through non-compliant entities
Protecting Your Business
For VSPs, this Order serves as a clear reminder of the critical importance of filing and maintaining accurate RMD certifications, including the submission of comprehensive robocall mitigation plans that fully comply with FCC requirements. The Commission continues to update its robocall mitigation rules and enforces them rigorously, so staying informed is essential for continued compliance.
Businesses that rely on VSPs for their consumer outreach can protect themselves by taking the following steps:
- Vet Your Providers Immediately
Ensure your VSPs are listed in the RMD and have up-to-date certifications. Ask for documentation of their robocall mitigation plans and STIR/SHAKEN implementation status. - Understand Your Exposure
Businesses using outbound calls, texts, or SMS must recognize their potential liability—even if robocalls originate from third-party vendors. Under the TCPA, vicarious liability is a very real threat. - Prepare for Enforcement
The FCC is not bluffing. As seen in other recent enforcement actions, the Commission is aggressively pursuing violators. Businesses should be ready to respond to traceback requests and FCC inquiries within 24 hours. - Stay Ahead of Regulatory Changes
The FCC is also exploring new rules around AI-generated robocalls and disclosures. Rules at the state level also are in flux. Proactive monitoring of changes is key to compliance. - Use Compliance Tools and Training
Leverage automated systems to monitor call frequency, consent records, and opt-out mechanisms. Regular compliance audits and training are essential to avoid costly mistakes.
This mass delisting is a wake-up call. The FCC is drawing a hard line—and businesses must respond with diligence, transparency, and proactive compliance. If your outreach relies on VSPs, now is the time to ensure your partners are playing by the rules.
A Partner at M&S, Josh advises clients on a range of proactive and responsive matters, helping them achieve their business goals while complying with federal and state privacy and other consumer protection laws.