Can a small VoIP provider do its own RMD and CPNI filings, without a consultant?
Yes. The rules require an officer of your company to sign, not a consultant or a lawyer, and the FCC publishes filing instructions, a filer FAQ and a CPNI template. What it takes: a business-type FRN, an FCC Username with multi-factor authentication, an officer to sign both certifications, a plan specific to your network, and a real CPNI statement.
What you need before you start
- An FCC Username and a business-type FRN in CORES: the RMD form cannot be submitted with an individual-type FRN (FCC filing instructions, July 2026).
- Multi-factor authentication to log in to the RMD, with options including Google Authenticator, Okta Verify or phishing-resistant MFA (same instructions).
- An officer who signs the RMD certification under 47 CFR § 1.16 (§ 64.6305(d)(3)) and the CPNI compliance certificate, as the company’s agent (§ 64.2009(e)).
- Your Form 499 Filer ID: one CPNI certification per affiliate with its own Filer ID (DA 26-139).
The parts that take real work
The robocall mitigation plan, a PDF in English, must describe your own practices: how you vet new and renewing customers and upstream providers, any analytics vendor by name, and your contractual provisions. The FCC warns that plans without enough detail may be deemed facially deficient, as may filings that only explain how STIR/SHAKEN works in general or that are not in English without a certified translation (DA 24-73).
The CPNI statement must explain how your procedures ensure compliance; stating that procedures were adopted does not satisfy the rule. If you took no action against data brokers and received no complaints about unauthorized release of CPNI, you must say so affirmatively (DA 26-139). Using the FCC’s template is optional.
What stays on your calendar
- The RMD recertification, inside the window that opens Monday, February 1, 2027, by Monday, March 1, 2027 (§ 64.6305(h); FCC filing instructions).
- The CPNI certification for the previous calendar year, by March 1, in ECFS under EB Docket No. 06-36 or through the FCC’s CPNI web application (§ 64.2009(e); DA 26-139).
- RMD updates within 10 business days of any change (§ 64.6305(d)(5)); a late update carries a $1,000 base forfeiture, continuing until cured (§ 1.80(b)(11)).
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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