FCC Requires Voice Service Providers to File Robocall Mitigation Plan and Certification

All Voice Service Providers (VSPs) will be required to submit filings through the FCC’s Robocall Mitigation Database that launched on April 20, 2021. There are two types of filings required depending upon the VSP’s status.

One filing is a Robocall Mitigation Plan (RMP), which documents a VSP’s policies and procedures to prevent illegal robocalls from being originated on their platform. The RMP is required for VSPs that qualified for an extension to the TRACED Act’s June 30, 2021 mandate that all VSPs implement STIR/SHAKEN caller authentication technology.

The second filing, which applies to all VSPs (not only those granted an extension), is a “Certification” documenting their efforts to reduce the origination of illegal robocalls on their networks. The Certification must be signed by an officer of the VSP, and certify that their traffic is either fully, partially, or not yet signed with STIR/SHAKEN. The Certification also requires certain disclosures:

• If granted the extension described above, the type of extension;
• The business name(s) and primary address of the VSP;
• Other business names in use by the voice service provider;
• All business names previously used by the voice service provider;
• Whether the voice service provider is a foreign voice service provider; and
• The name, title, department, business address, telephone number, and email address of one person within the company responsible for addressing robocall mitigation-related issues.

RMPs and Certification must be submitted by June 30, 2021 to the RMD via a portal on the FCC’s website. VSPs can request RMP filings be withheld from public inspection by submitting a confidentiality request.

Starting September 28, 2021, intermediate and terminating VSPs will be required to block originating VSPs that are not listed on the RMD.