What is the FCC proposing to change in the Robocall Mitigation Database (FCC 26-49)?
Proposals, not rules. FCC 26-49 proposes requiring a U.S. registered agent and details on your human principals, publishing filings only once the FCC accepts them, and fifteen codified causes for removal, most with five days to cure. Comments closed October 9; replies are due November 9, 2026. Until a final rule takes effect, current duties, including March 1 recertification, apply.
What your filing would have to add
- A U.S. registered agent for service, with a U.S. mailing address, phone and email (91 FR 57461, 57487).
- For each human principal: title, phone, email, physical address, country of residence and citizenship, kept non-public; for related companies, an RMD number or a bona fide business address (91 FR 57461, 57466).
- A description of your services and customers, and staff-only details of third parties used for analytics, call signing, customer or upstream checks, or filing (91 FR 57460–57461, 57463, 57466).
- New certifications: no false, misleading or inaccurate information to the FCC, its agents or the STIR/SHAKEN Governance Authority; compliance with all illegal-call rules (91 FR 57458).
- Exemption claims citing the rule and your network’s facts; a temporary exemption, with your OCN, while obtaining an SPC token (91 FR 57459).
- A detailed plan of “affirmative, effective measures” against all illegal calls, analytics measure by measure, in machine-readable PDF (91 FR 57464–57465).
- Separately, for U.S. providers only: a Foreign Adversary Control attestation on whether a foreign adversary owns or controls you, filed under those rules rather than in the RMD form (91 FR 57469).
Getting listed and staying listed
- A new or updated filing would “appear” only once the FCC accepts and publishes it; one that looks non-compliant could be rejected, withheld or held pending (91 FR 57467).
- Fifteen codified causes for removal, including a missed or late recertification or an unpaid recertification fee (91 FR 57469–57470).
- For all causes but an ordinary deficient filing, by default: an Enforcement Bureau order finding the filing removable, then five days to cure or explain (ten in today’s two-step process) before a removal order (91 FR 57471, 57488).
- Notice to your customers if your filing is removed (91 FR 57473).
Only asked, not proposed: copies of principals’ IDs, a letter of credit to file, automatic suspension after a missed March 1 or a grace period, and re-entry bars for removed providers and the people behind them (91 FR 57461, 57467–57468, 57471–57472, 57474–57475).
What applies until a final rule
Nothing changes until a final order takes effect; the FCC proposes applying new filing content from the next annual recertification after a Federal Register notice (91 FR 57479–57480). By November 5, 2026, no final rule had appeared. Recertify on or before Monday, March 1, 2027 (47 CFR § 64.6305(h); the window is expected to open February 1, as in 2026, per the filing instructions), and update within 10 business days of any change (§ 64.6305(d)(5), (e)(5), (f)(5)). The draft rule keeps both (91 FR 57487) but asks whether quarterly or six-month updates should replace the second (91 FR 57466). The $100 fee is not yet in effect (91 FR 57473).
Last reviewed:
General information drawn from the rule text and the FCC documents listed below — not legal advice. You review, sign and submit your own filings.
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