Are the RMD recertification and the CPNI certification the same March 1 filing?
No. They share the March 1 deadline but are two separate filings. The RMD recertification confirms, in the FCC’s Robocall Mitigation Database portal, that your filing is true and correct. The CPNI certification is filed with the Enforcement Bureau in ECFS under EB Docket No. 06-36, or through the FCC’s CPNI web application, and covers the previous calendar year.
Side by side
| RMD recertification | CPNI certification | |
|---|---|---|
| Rule | 47 CFR § 64.6305(h) | 47 CFR § 64.2009(e) |
| What is certified | That any information submitted to the Database is true and correct | Personal knowledge that operating procedures are adequate to ensure compliance with the CPNI rules |
| Period | Your filing as it stands | The previous calendar year |
| Where | The RMD portal, with an FCC Username tied to your business-type FRN and multi-factor authentication | ECFS, EB Docket No. 06-36 in the “proceeding” field, or the FCC’s CPNI web application |
| When | Only inside the window that opens February 1; deadline March 1 | On or before March 1 |
| Who signs | An officer, under 47 CFR § 1.16 | An officer, as agent of the company |
| How many | Each filing, once per window | One per affiliate with its own Form 499 Filer ID |
| Attached | A revised plan PDF if your practices changed | A statement on how your procedures ensure compliance, data-broker actions, a complaint summary |
Who owes which
The RMD recertification is owed by every provider with a filing in the Database (§ 64.6305(h)). The CPNI certification is owed by telecommunications carriers and interconnected VoIP providers, with no exemption for small companies (DA 26-139). An interconnected VoIP provider with a filing in the Database owes both.
Different rules, different penalties
- False or inaccurate information in the RMD: a $10,000 base forfeiture, continuing until cured (§ 1.80(b)(11)).
- CPNI rules, including the annual certification: forfeitures of up to $251,322 per violation or per day of a continuing violation, up to $2,513,215 (DA 26-139).
- The CPNI certification is not your Form 499 or universal service filing; those are separate (DA 26-139).
When March 1 falls on a weekend, the CPNI deadline moves to the next business day: it was March 2 in 2026 (DA 26-139; 47 CFR § 1.4(j)). For the 2027 season, the RMD window opens Monday, February 1, 2027 and both filings are due Monday, March 1, 2027.
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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