Your first Robocall Mitigation Database filing, written for how your company actually works
Until your filing appears in the Database, U.S. voice and intermediate providers must refuse the calls you send them directly. We write your robocall mitigation plan and every field of the FCC form from one written questionnaire — $490, delivered within 3 U.S. business days. You review, sign and submit.
Last updated: September 2026
Every voice provider — including resellers and MVNOs
- All voice service providers and intermediate providers, including gateway providers, must file (DA 26-72, FAQ 1). “Voice service” means a service interconnected with the public switched telephone network that furnishes voice communications to an end user using North American Numbering Plan resources (47 CFR § 64.6300(o)).
- The FCC names “voice over Internet protocol (VoIP) resellers and mobile virtual network operators (MVNOs)” among those who must file (DA 26-72), and repeated it for MVNOs on February 20, 2026 (DA 26-174).
- Owning no switches doesn’t exempt you from filing. Providers without the facilities to implement STIR/SHAKEN must still take reasonable steps against illegal robocalls, certify, and file a mitigation plan (DA 26-174).
- An affiliate or subsidiary that independently provides voice service files its own filing, under its own FRN (DA 26-72, FAQ 1).
Why a thin filing is a risk
The FCC can remove a filing through an expedited process when it is facially deficient. Its own examples (DA 24-73):
- a request for confidentiality with no underlying substantive filing;
- only non-responsive documents, such as a screenshot of your FRN record;
- text that merely explains how STIR/SHAKEN works, with nothing specific about your own mitigation efforts;
- a certification not in English and without a certified English translation.
Since February 5, 2026, false or inaccurate information in the Database also carries a $10,000 base forfeiture per violation, continuing until cured (47 CFR § 1.80(b)(11)).
What has to be in place on the FCC side
From the FCC’s filing instructions (July 2026) and its January 2026 guidance. Our pre-filing checklist walks you through each item.
- A business-type FRN from the FCC’s registration system (CORES). The form cannot be submitted with an individual-type FRN, and each filing is tied to one FRN.
- A CORES login with multi-factor authentication. The RMD requires it; supported options include authenticator apps and phishing-resistant keys.
- Current CORES data. Your business name and address on the form are pulled from CORES and are read-only. CORES updates are due within 10 business days of any change (47 CFR § 1.8002(b)(2)).
- An officer to sign. The certification is signed by an officer in conformity with 47 CFR § 1.16, under penalty of perjury.
- Your plan as a PDF, in English. Every provider uploads a robocall mitigation program description meeting § 64.6305(d)(2)(ii)–(iii) (or (e)/(f) for intermediate roles).
- An OCN only if you have one. Filers without an Operating Company Number are not required to get one (DA 26-72, FAQ 5).
A filing package you can submit the day you get it
- Your robocall mitigation plan (Word and PDF): company and network facts, role in the call chain, STIR/SHAKEN status and its explanation, know-your-customer steps for new and renewing customers, upstream-provider checks, contract terms, caller ID and do-not-originate controls, monitoring and analytics (with vendor names), the 24-hour traceback commitment and procedure, FCC-notice handling, the two-year history statement, and how you keep the filing current.
- Every RMD form field, filled in: names, principals and affiliates, contact person, role(s), prior-action statement, OCN, certification option and its exemption text.
- A short mapping note showing how your network facts line up with the STIR/SHAKEN certification options, with the rule text. You choose and certify.
- A pre-filing checklist for CORES, multi-factor login and the officer’s e-signature.
- Your compliance calendar: first March 1 recertification, 10-business-day update rule, traceback clock, and your CPNI date if the CPNI rules apply to you.
- One round of revisions, returned within 2 U.S. business days.
What we don’t do
- Submit the filing for you or log in to your FCC accounts
- Obtain FRNs, SPC tokens or certificates, or implement STIR/SHAKEN
- Give legal advice or represent you before the FCC
- Take providers whose earlier filing was removed by the FCC or who were barred from filing, providers facing an FCC enforcement action or robocall investigation, or businesses built on high-volume unsolicited calling
New filer questions
We resell a wholesale platform and own no switch. Do we still need a mitigation plan?
Yes. The FCC requires all providers — including those without the facilities to implement STIR/SHAKEN — to take reasonable steps against illegal robocalls, certify their STIR/SHAKEN status and file a robocall mitigation plan (DA 26-174). As a voice service provider, your plan must describe how you know your customers (§ 64.1200(n)(4); § 64.6305(d)(2)(ii)).
Our wholesale provider signs our calls. Which STIR/SHAKEN option do we pick?
It depends on facts, which is why the questionnaire asks them. Options 1 and 2 require your own SPC token and certificate — a third party may sign for you, but with your certificate, and you make the attestation decisions (47 CFR § 64.6301(b); DA 26-72, FAQ 9–11). A provider that lacks control over the network infrastructure needed to implement STIR/SHAKEN can certify to partial or no implementation, as long as it explains in detail how that applies to it (as the FCC restated in FCC 26-32). We map your facts to the options with the rule text; you choose and certify.
Do we need an Operating Company Number?
No. You enter an OCN only if you have one; the FCC says filers without one are not required to obtain one before filing (DA 26-72, FAQ 5).
Can we keep parts of our plan confidential?
Yes, within limits. You file a request for confidential treatment in ECFS, WC Docket No. 17-97, and upload both a redacted and an unredacted plan; the redacted one is published. Over-redacted plans are not appropriate (DA 26-72, FAQ 7). We prepare both versions if you ask; the request itself is filed by you or your counsel.
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