- within Technology and Compliance topic(s)
As described in our previous client advisory, the Federal Communications Commission (“FCC” or “Commission”) has adopted new robocall mitigation rules that affect each and every voice service provider's (“VSP”) current Robocall Mitigation Database (“RMD”) filings. These rules concern:
- mandatory updating of RMD filings and CORES information;
- new annual RMD recertifications;
- easy reporting of deficient robocall mitigation plans (“RMP”);
- multi-factor authentication, and
- a new $100 filing fee.
- substantial fines for noncompliance
Following publication in the Federal Register on January 6, the FCC Thursday released a Public Notice Thursday, stating that, with the exception of the $100 RMD filing fee, the new rules have cleared the FCC's internal procedures and will become effective on February 5, 2026.
These new rules underscore the importance of consistently maintaining accurate RMD filings. In addition to the Commission's recent enhanced enforcement and content requirements, competitors will now be able to easily report deficiencies, and even minor errors can serve as a basis for an FCC investigation.
Update RMD Filings & CORES Information
The FCC requires all VSPs to maintain complete, accurate, and thorough RMD filings, including RMPs. Any changes by a VSP, including corporate, contact, and service provision information that affects the RMD filing, must be updated within 10 business days of the changes. This includes any changes in a VSP's information listed the FCC's CORES database, which also must be updated within 10 business days of such changes.
Annual RMP Recertification
The Commission has set a deadline of March 1, 2026, for all VSPs to recertify their filings in the RMD. This requires that VSPs thoroughly review their existing RMD filings, make any required changes, including any changes to the RMP, submit the filing, and certify as to the accuracy of same. The recertification window opens on February 1, 2026.
Reporting Mechanism for Deficient Filings
The Commission has established a mechanism that enables any stakeholder to report deficient filings in the RMD. The deficiency filing reports are to be sent to a specific FCC email address, where the reports will be monitored by FCC staff. The Commission has not established specific content for the reports, but it recommends that submissions should include the business name, FRN, and RMD number associated with a filing, and a brief description of the alleged deficiency. Once a deficiency report has been filed and if the FCC concludes that an investigation is warranted, the Commission will send a notice of inquiry to the target VSP, requiring a response within a short period of time. If deficiencies are confirmed, the target VSP will be subject to the new fines and possibly more, depending on the egregiousness of any such deficiency.
Multi-Factor Authentication
The FCC has also implemented multi-factor authentication for RMD access. Multi-factor authentication requires the use of multiple authentication protocols, as opposed to simply providing a username and password, to log into the RMD.
Specifically, the new rules require each filer to authenticate its identity by one of two methods: (1) obtain and enter a temporary code generated from the Google Authenticator app; or (2) utilize the Okta Verify authenticator app to validate its identity. The RMD provides links to set up and activate those apps.
Filing Fee
The new rules further require an applicant to submit a $100 application fee for initial submissions, and the required annual recertifications. The fee will not go into effect until the Commission finishes its ongoing technical upgrade to RMD. We will inform you when the FCC completes its upgrade and imposes the new fee.
Significant Fines for Noncompliance
The FCC has raised the base fines for noncompliant VSPs:
- $10,000 per violation for submitting false or inaccurate information to the RMD.
- $1,000 per violation for failing to update the RMD within 10 business days after information changes.
These violations are considered ongoing until corrected. As a result, fines can accumulate daily, up to the maximum allowed by law, for continuing violations.
Action Required
With the effective date of the new rules and the RMD recertification deadline rapidly approaching, it is critical that all VSPs act quickly to ensure that their RMD filings are accurate, complete, current, and recertified within the February 1 – March 1, 2026 timeframe. The FCC is very strict about enforcing its robocall mitigation rules and will not hesitate to impose maximum fines and other sanctions on noncompliant carriers.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
[View Source]
