We missed the March 1 RMD recertification. What happens now?
Nothing happens automatically, but you are out of compliance: the FCC said failure to recertify “will result in referral to the Enforcement Bureau, which may subject the filer to forfeiture or removal from the Database.” Log in to the RMD: if a Recertify button appears on your filing, recertify now. If not, make the filing accurate and contact FCC staff.
What the FCC said it would do
When it adopted the rule, the FCC wrote that failure to recertify “will result in referral to the Enforcement Bureau, which may subject the filer to forfeiture or removal from the Database,” and that staff would “conduct outreach to providers that fail to recertify” and “refer deficient filers to the Enforcement Bureau” (FCC 24-135, 91 FR 343, 348).
Late recertification: what the instructions say, and what the data shows
The FCC’s filing instructions (July 2026) say annual recertifications “can only be completed during the Annual Recertification filing window, which opens each year on February 1,” and its filer FAQ lists a closed window among the reasons the button does not appear. Neither document describes a late-recertification path. Yet the FCC’s public Robocall Mitigation Database export of November 5, 2026 shows 524 filings recertified between July 30 and November 4, 2026, and no filing whose last recertification date falls between March 3 and July 29, which suggests the FCC has reopened the button for some filings. So log in and look: if the button is there, recertify now; if it is not, the next window opens Monday, February 1, 2027, for the March 1, 2027 deadline. Our free RMD status check shows what the FCC’s export holds for your filing.
What you can still do today
- Make the filing accurate. Revisions are not limited to the window, since the rule requires them within 10 business days of any change. A revision does not count as a recertification (FCC FAQ 16), but it cures inaccurate information, which carries its own $10,000 base forfeiture per violation, continuing until cured (47 CFR § 1.80(b)(11)).
- Check CORES: your business name and address in the RMD come from it, and must be current within 10 business days of a change (§ 1.8002(b)(2)).
- For help with the portal itself, the instructions give FCC staff’s address for special assistance: RobocallMitigationDatabase@FCC.gov.
- Answer any FCC notice by its deadline. In the two removal orders cited here, providers first received notice of the deficiency, then an order giving them 14 days to cure it or explain; removal followed only when they did neither (DA 25-913; DA 26-872).
- Carriers and interconnected VoIP providers: check your CPNI certification too; it was due the same day (March 2 in 2026, as March 1 fell on a Sunday), is filed in EB Docket No. 06-36, and the FCC warns that failing to comply can bring forfeitures of up to $251,322 per violation or per day (DA 26-139).
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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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