Can a consultant file our Robocall Mitigation Database certification for us?
A consultant can prepare it, but only an officer of your company can sign it, under penalty of perjury (47 CFR § 64.6305(d)(3)), and the obligation stays with your company. The rules do not say who may enter a filing in the FCC’s portal; the FCC’s September 2026 proposals ask whether to permit or prohibit third-party filers (FCC 26-49).
What the rule requires today
Each RMD certification must be filed in the FCC’s portal and “signed by an officer in conformity with 47 CFR 1.16” (47 CFR § 64.6305(d)(3), (e)(3), (f)(3)): a declaration, under penalty of perjury, that the filing is true and correct. Each annual recertification repeats it (§ 64.6305(h)). The portal ties each filing to one business-type FRN and admits only an FCC Username associated with that FRN in CORES, with multi-factor authentication (FCC filing instructions; filer FAQ 14–15).
The rule does not say who types the filing in, and the FCC’s July 2026 instructions include “Tips for Trusted 3rd Party Users Who Log in to Multiple Client Accounts.” Whoever types it, the filing is your company’s: false or inaccurate information carries a $10,000 base forfeiture per violation, continuing until cured (§ 1.80(b)(11)).
What the FCC asks in FCC 26-49
In proposals published September 9, 2026, the FCC says it is aware that some providers may rely on third parties, “who may not be officers of the provider,” to complete their RMD filings. It asks, without proposing an answer (91 FR 57457):
- whether to explicitly permit or prohibit such third parties;
- whether to let them only input information, with an officer still making the declaration;
- whether the form should show the third party’s name, address, email, phone and, if it is registered with the FCC, its FRN;
- whether third parties should be the provider’s agents, with the declaration made by an officer or an agent;
- whether providers that used third parties should have a safe harbor until any rule takes effect.
It proposes that every filer say whether it uses third parties for call analytics, for signing calls, for know-your-customer and upstream-provider checks and, if the FCC allows it, for submitting its filing, and name each one, with email, phone and, if available, website, seen by FCC staff only; it also asks whether other uses should be disclosed (91 FR 57460–57461, 57466). Among possible screening tools, it cites flagging filings that list the same “third-party filing consultant” as a removed provider (91 FR 57467), and it asks whether a participation bar should reach “regulatory consultants, third-party filing agents” who knowingly submit false or misleading filings for multiple providers (91 FR 57475).
The FCC repeats that “the compliance obligation remains with the provider, and not any third party” (91 FR 57461), and its draft rule text keeps the officer’s signature (proposed § 64.6305(b)(2), 91 FR 57486). Comments closed on October 9, 2026, and replies are due November 9; until a final rule takes effect, today’s rule applies.
Our answer to the FCC
We answered these questions on the record, in comments filed on October 6, 2026: let third parties prepare and enter filings, but keep the officer’s declaration with the provider; have providers name the third parties that submit their filings, seen by FCC staff only; judge similar plans on each provider’s own facts, not on a shared outline; and bar only consultants who knowingly file false information, after notice and a chance to respond.
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.
Send us your company name or RMD number. We read your filing for free.
Within one U.S. business day, in writing: what is current, what a reviewer could flag, and what March 1 will ask. No call. A fixed-price quote only if you want one.
Already know what you need? Request a quote