Does the FCC charge $100 to recertify in the Robocall Mitigation Database?
Not yet. The FCC adopted a $100 fee for initial Robocall Mitigation Database filings and for each annual recertification (FCC 24-135), but it applies only from a date the FCC must announce in the Federal Register. As of October 29, 2026, no such notice has appeared. The recertification itself remains due by March 1.
Adopted, but not in effect
FCC 24-135 treats RMD filings as applications under section 8 of the Communications Act (47 U.S.C. § 158) and adds two $100 lines to 47 CFR § 1.1105: the initial filing and the annual recertification (91 FR 347–348, 356). The rest of the order is in force, including the March 1 recertification (91 FR 5242). The fee waits for notice to Congress at least 90 days ahead (47 U.S.C. § 159a(b)(2)), updates to the FCC’s systems, and a Federal Register notice setting the date (91 FR 343). By October 29, 2026, no such notice had appeared, and § 1.1105 still listed no RMD fee. In proposals published September 9, 2026, the FCC wrote that “the fee requirement has not yet gone into effect” (FCC 26-49, 91 FR 57473).
Who would pay, and when
- Every filer, at its initial filing and each annual recertification; whether that includes March 1, 2027 depends on the date the notice sets.
- Updates filed within 10 business days of a change carry no fee (DA 26-72; FCC FAQ 17).
- The FCC proposes to require payment when you recertify, and says the Database will not let you finish a recertification until you pay (FCC 26-49).
- Once in effect, an unpaid fee carries a 25 percent late-payment penalty (47 U.S.C. § 159a(c)(1)) and, under the FCC’s red-light rule, can lead to removal of the filing (91 FR 348).
What is due now
The recertification itself: each year by March 1, every filer certifies that its filing is true and correct (47 CFR § 64.6305(h)). The next window opens Monday, February 1, 2027; the deadline is Monday, March 1, 2027. Missing it leads to referral to the Enforcement Bureau (91 FR 348), fee or no fee.
Why you read “$100” everywhere
Because it was adopted and printed: the Federal Register shows the new § 1.1105 table with both $100 lines, in an amendment marked “delayed indefinitely” (91 FR 356), and the FCC’s filer FAQ says that “in the future” providers will pay a $100 annual recertification fee. Summaries drop the condition. Until the notice appears, the FCC charges nothing to file, update or recertify; its July 2026 filing instructions include no payment step.
When it applies, the $100 is an FCC application fee, paid to the FCC and deposited in the U.S. Treasury (91 FR 347), not a filing service’s charge.
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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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