Questions small voice providers ask about RMD and CPNI filings
One question per page. Each opens with a short answer, then the detail: dates, figures and the rule text or FCC document behind them. General information, not legal advice.
Last updated: November 5, 2026
RMD recertification, updates and removal
The March 1 recertification, the 10-business-day update rule, and what removal from the Database does.
- How do we recertify our Robocall Mitigation Database filing before March 1?
Inside the window that opens February 1: click Recertify on your filing, correct what changed, and have an officer sign by March 1.
- Does the FCC charge $100 to recertify in the Robocall Mitigation Database?
Not yet: the $100 fee is adopted but had no effective date as of October 29, 2026. The March 1 recertification is due either way.
- We filed in the Robocall Mitigation Database this year. When is our first recertification due?
By March 1 of the year after you first filed: a 2026 filing by March 1, 2027; a January 2027 filing by March 1, 2028.
- We missed the March 1 RMD recertification. What happens now?
Referral to the Enforcement Bureau, which may lead to a forfeiture or removal; recertify now if the button appears, otherwise correct the filing.
- What changes must we update in the Robocall Mitigation Database within 10 business days?
Anything in the filing — names, owners, contact, role, STIR/SHAKEN option, plan practices — within 10 business days, or a $1,000 base forfeiture.
- What happens if our filing is removed from the Robocall Mitigation Database?
Downstream providers must refuse your calls within two business days, and refiling needs the consent of two FCC bureaus.
Who files in the RMD, and what to certify
Resellers, one-way VoIP, new providers, STIR/SHAKEN options, the mitigation plan itself, filing in-house or with help, and the FCC’s September 2026 proposals.
- Does a VoIP reseller with no network of its own have to file in the Robocall Mitigation Database?
Yes: the FCC names VoIP resellers and MVNOs, and without your own filing, providers must refuse the calls you send them directly.
- Which STIR/SHAKEN option should a VoIP reseller certify in the Robocall Mitigation Database?
Options 1–2 need your own SPC token; Option 3 needs a valid exemption, explained — being small or having your carrier sign does not count.
- What must a robocall mitigation plan include to avoid being found deficient?
Your actual customer, upstream, analytics and contract practices plus a 24-hour traceback commitment; generic STIR/SHAKEN text is deficient.
- Do outbound-only (one-way) VoIP providers have to file in the RMD and certify CPNI?
RMD yes: one-way VoIP is named in the definition. CPNI only if you are a carrier or sell interconnected (two-way) VoIP.
- We’re a new VoIP provider. In what order do we get an FRN, a 499 Filer ID and an RMD listing?
CORES FRN, then Form 499 registration (within 30 days of starting service), the RMD before your first call, and the SPC token after the RMD listing.
- Can a consultant file our Robocall Mitigation Database certification for us?
A consultant can prepare it; only your officer can sign it. Whether third parties may submit filings is an open question in FCC 26-49.
- What is the FCC proposing to change in the Robocall Mitigation Database (FCC 26-49)?
Proposals, not rules: a U.S. registered agent, principals’ details, publication only after FCC acceptance and faster removals. Comments closed October 9; replies are due November 9, 2026.
- Can a small VoIP provider do its own RMD and CPNI filings, without a consultant?
Yes — the rules require an officer to sign, not a consultant. It takes a business FRN, MFA logins, a network-specific plan and a real CPNI statement.
- How do we check that a provider sending us calls is listed in the Robocall Mitigation Database?
Look the provider up in the FCC’s RMD listings or CSV file, and watch removal orders: you have two business days to stop taking its calls.
- What does the FCC’s “know your customer” rule require of a small VoIP provider?
Affirmative, effective measures under § 64.1200(n)(4), described in your RMD plan; FCC 26-27 proposes ID collection, verification and per-call fines.
The annual CPNI certification
Where and when to file it, who has to sign it, and how it differs from the RMD recertification.
- How and where do we file the annual CPNI certification in EB Docket 06-36?
By March 1, in ECFS under EB Docket No. 06-36 or through the FCC’s CPNI web form, one filing per Form 499 Filer ID.
- Who must sign the annual CPNI certification, and what must the officer state?
An officer of the company, stating personal knowledge that CPNI procedures are adequate; outsiders may draft it, not sign it.
- Are the RMD recertification and the CPNI certification the same March 1 filing?
No: same March 1 deadline, two filings — the RMD recertification in the FCC portal, the CPNI certificate in ECFS (EB Docket 06-36).
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