A voice service provider can lose its place in the U.S. phone network without ever being fined. That is the lesson of the FCC’s latest robocall enforcement action, announced October 5, 2026, in which the Commission prohibited Digital Solutions, Inc. from connecting to U.S. networks for failing to comply with its robocall rules. The company was removed from the Robocall Mitigation Database (RMD), and all providers on U.S. networks have 30 days to begin blocking its traffic.
Digital Solutions is not the only provider the FCC has removed from the RMD this year, and it will not be the last. But the facts of this case are a useful mirror for any business that originates, carries, or buys call traffic, because the path from first notice to shutdown was long, documented, and avoidable at several points.
How the Digital Solutions Matter Unfolded
The matter came to the FCC’s attention through alleged illegal prerecorded calls offering consumers loans and tax relief. Earlier this year, the Industry Traceback Group (ITG) investigated and determined that Digital Solutions had originated suspected illegal robocalls. The ITG gave the company supporting data on each call and explained that the basis for the traceback was evidence of lack of consent for the prerecorded messages. The Enforcement Bureau followed with a formal notice on April 2, 2026, requiring the company to report its mitigation steps within 48 hours and to investigate, block, and report on the identified traffic within 14 days.
To its credit, Digital Solutions did not deny that the calls crossed its network. It confirmed it had originated them and identified three of its customers as the source of all of them. It also corrected one of two deficiencies the FCC had flagged in its RMD certification. Those are the steps regulators hope to see, and they are worth noting before drawing any conclusions about the company.
The problem, as the FCC tells it, is what came next. The company’s response to the notice omitted information the FCC’s rules require about the suspected illegal traffic, and the second certification deficiency remained uncured. The FCC’s April notice had pointed to a mismatch between the company’s certification of STIR/SHAKEN implementation and its actual network. On June 29, the Bureau issued an Initial Determination Order and Order to Show Cause, which gave Digital Solutions a final opportunity to supply the missing information and cure the remaining deficiency. According to the FCC, it did neither. The Commission then took the last step on the escalation ladder: mandatory call blocking and removal from the RMD.
Why Removal From the RMD Is Such a Serious Outcome
The RMD is effectively a ticket to connect. By the FCC’s own description, it is a critical tool for ensuring providers are actively combatting robocalls and implementing STIR/SHAKEN. Providers are required to refuse traffic from any voice service provider that is not registered in the RMD. Removal from the RMD is therefore more than a penalty: it takes away a provider’s ability to deliver calls to the networks that matter, which can end a business in a matter of weeks.
It also reaches beyond the provider itself. Customers and partners lose their route to market, and every other provider has a 30-day clock to begin blocking or risk exposure of its own. A provider’s compliance gaps become everyone’s operational problem.
Lessons for Carriers, Resellers, and Their Customers
Several practical takeaways emerge from the way this matter played out.
- Make your RMD certification match reality. An RMD certification is a statement made to the federal government. Certifying full STIR/SHAKEN implementation while parts of a network remain non-IP, or while some calls go out unauthenticated, creates a separate problem that persists even after the underlying robocall issue is addressed.
- Treat “Know Your Customer” as an ongoing obligation. Vetting at signup is only the beginning. Monitor traffic patterns, respond to traceback requests quickly, and make sure your contracts give you the right to suspend a customer fast. Digital Solutions was able to name the three customers behind the calls once the ITG came asking, but its response was still found incomplete.
- Document consent before you need it. In the FCC’s April notice, only a minority of the identified calls were backed by a claim of consent, and the FCC scrutinized even those. Businesses that rely on third-party lead sources should be able to produce consent records on short notice, not assemble them after a letter arrives.
- Partial cooperation is not enough. Each step in the process carries its own deadline and required content. A response that omits required information, or that cures one deficiency but not another, can turn a manageable compliance matter into a final determination.
Best Practices for Responding to an Enforcement Investigation
Whether the inquiry comes from the FCC, the FTC, a state attorney general, or the Industry Traceback Group, the first hours matter. These steps give a business its best chance of resolving a matter before it escalates.
- Calendar every deadline immediately. In this matter, the April notice set 48-hour and 14-day windows, and those clocks ran whether or not the recipient was ready. Put each deadline on every relevant calendar the day the notice arrives.
- Preserve records right away. Gather and protect call detail records, customer contracts, consent logs, traceback correspondence, and internal communications, and suspend any routine deletion that could touch them.
- Involve counsel early. Statements made in the first response tend to define the record, and a response that is accurate but incomplete can be as damaging as a late one. An attorney can help determine what must be disclosed, how to frame mitigation efforts, and whether privilege applies to internal reviews. Designate a single point of contact so the agency receives consistent, coordinated communications.
- Respond fully, and ask for more time in writing if you need it. If a deadline cannot be met, request an extension before it passes, with a specific explanation and proposed date. Silence is the most costly response available, because it removes the agency’s reason to see the company as a partner in fixing the problem.
- Show corrective action, not just assurances. Where the facts are unfavorable, acknowledge them and focus on what has changed. Agencies give more weight to documented steps, such as terminating a bad customer, adding traffic filters, or correcting a certification, than to general commitments to do better.
- Audit adjacent practices and confirm resolution. Fix the specific issue raised, but also review related conduct, because regulators often look more broadly once they are engaged. Document each remediation step with dates and evidence, and verify that every flagged deficiency is actually cured instead of assuming the matter closed with the original issue.
Staying Ahead of the Next Notice
The FCC’s Enforcement Bureau Chief described the action as part of an intensifying crackdown on illegal robocalls at every point along the call path. The Digital Solutions matter shows how quickly a compliance gap can escalate into a business-ending event, and how much of the outcome depends on what happens after the first notice arrives. Providers, lead generators, and telemarketers can reduce their risk by auditing their RMD certifications, tightening customer vetting, and building a response plan before they need one.
If you have received an FCC, FTC, or traceback inquiry, or would like help reviewing your robocall mitigation program, reach out to our team.
