VoiceFiling
Questions · RMD recertification, updates and removal

What happens if our filing is removed from the Robocall Mitigation Database?

Short answer

Every U.S. voice service and intermediate provider must stop accepting calls directly from you within two business days of the removal order, with an exception for 911 and public-safety calls. You cannot simply refile: the Enforcement Bureau’s removal orders bar refiling until both it and the Wireline Competition Bureau consent (47 CFR § 64.6305(g); DA 25-913).

How a removal happens

The Enforcement Bureau first notifies the provider that its certification is deficient and gives it a chance to cure. If that fails, it releases an order giving the provider 14 days to cure the deficiency or explain why the filing is not deficient. If the provider does neither, a removal order follows (DA 26-872, para. 4; DA 25-913, para. 4).

Removals since 2025

  • August 25, 2025: 1,203 certifications removed, out of 2,411 providers ordered in December 2024 to cure deficient certifications (DA 26-872).
  • September 30, 2025: 12 providers removed for not responding to traceback requests from the industry traceback consortium (DA 25-913).
  • August 27, 2026: nine providers ordered to cure unanswered tracebacks within 14 days or face removal (DA 26-873).
  • September 2, 2026: 14 providers removed because their certifications, including their mitigation plans, lacked required information (DA 26-872).

After removal

After the August 2025 removals, the two bureaus provisionally reinstated some providers that asked and tried to cure, but called it a special circumstance: “RMD filers should have no expectation that provisional reinstatements will be used in the future” (DA 26-872, n.25). Removal also follows you. Every certification states that no prior certification was removed by Commission action, and removal orders must be disclosed for two years in your filing and in those of your principals and affiliates (47 CFR § 64.6305(d)(1), (d)(2)(iv); FCC FAQ 6). Downstream providers have their own reason to comply: failing to block under § 64.6305(g) carries a forfeiture of up to $25,132 per call (47 CFR § 1.80(b)(9)).

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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