What does the FCC’s “know your customer” rule require of a small VoIP provider?

The rule in force

Section 64.1200(n)(4) requires a voice service provider to “take affirmative, effective measures to prevent new and renewing customers from using its network to originate illegal calls, including knowing its customers and exercising due diligence in ensuring that its services are not used to originate illegal traffic.” It names no document to collect: how you meet it is yours to choose, and to show.

Your robocall mitigation plan must describe how you comply with that obligation (§ 64.6305(d)(2)(ii)). In March 2026 the Enforcement Bureau ordered 35 providers to cure certifications and plans lacking required information, and listed that description among the required elements (DA 26-282); 14 of them were later removed from the Database (DA 26-872).

What the FCC proposed in 2026

In FCC 26-27, adopted April 30, 2026, the FCC sought comment on requiring originating providers to (comments closed June 25, replies July 27, 2026):

• obtain, before granting service to new and renewing customers, at least a name, physical address, government-issued identification number and alternate telephone number; for high-volume customers, including business and foreign customers, also the intended use and the IP address calls will be placed from;
• verify that information with supporting records, such as copies of government-issued identification, and re-verify it when needed;
• keep it for four years after the customer relationship ends.

It also proposed a base forfeiture of $2,500 per call for violations of § 64.1200(n)(4), and asked about safe harbors. These are proposals: when we checked on October 19, 2026, no final rule had been published in the Federal Register.

Last reviewed: October 19, 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.