We filed in the Robocall Mitigation Database this year. When is our first recertification due?

Why there is no recertification the first year

The rule requires every filer to recertify on or before March 1 each year (47 CFR § 64.6305(h)). The FCC’s filer FAQ (question 17, July 2026) adds that filers submitting a new filing in the current calendar year are not required to recertify until the following calendar year, and the “Recertify” button does not appear on a filing first submitted in the current calendar year.

What applies before then

• Update the filing within 10 business days of any change (47 CFR § 64.6305(d)(5)); a late update carries a $1,000 base forfeiture, continuing until cured (§ 1.80(b)(11)).
• Keep CORES current within 10 business days as well: your business name and address in the RMD are copied from it (§ 1.8002(b)(2); FCC FAQ 16).
• Answer every traceback request fully within 24 hours, on the business-hours clock of § 64.1200(n)(1).
• Revisions do not count as the recertification. When your window opens, an officer re-certifies the whole filing as true and correct.

If you provided interconnected VoIP or telecommunications service during 2026, your annual CPNI certification for 2026 is due the same day, March 1, 2027 (47 CFR § 64.2009(e)).

Last reviewed: October 29, 2026

General information drawn from the rule text and the FCC documents listed below — not legal advice. You review, sign and submit your own filings.