What must a robocall mitigation plan include to avoid being found deficient?
The specific steps you actually take against illegal robocalls, for each role you play: how you know new and renewing customers, how you vet upstream providers, which analytics you use and whose, the contract terms you rely on, and a 24-hour traceback commitment. A plan that only explains how STIR/SHAKEN works is facially deficient.
The standard
A program is sufficient if it “includes detailed practices that can reasonably be expected to significantly reduce” illegal robocalls, and the provider must follow the practices it describes. The FCC adds that “a sufficient robocall mitigation plan is not necessarily a lengthy one,” but it must answer each requirement in detail (DA 24-73).
What goes in, by role
| Element | Who includes it | Rule |
|---|---|---|
| How you keep new and renewing customers from originating illegal calls | Voice service providers | § 64.1200(n)(4); § 64.6305(d)(2)(ii) |
| Procedures to know your upstream providers | All filers; gateway and intermediate providers describe how they meet § 64.1200(n)(5) | § 64.6305(d)–(f)(2)(ii); FCC FAQ 13 |
| Whether you use analytics, which systems, vendor names, or the underlying provider you rely on | All filers | § 64.6305(d)–(f)(2)(ii); FCC FAQ 12 |
| Contract terms with end users or upstream providers aimed at illegal robocalls (general terms are enough) | All filers | DA 24-73 |
| Commitment to answer traceback requests within 24 hours and cooperate | All filers | § 64.6305(d)–(f)(2)(iii) |
| The rule and a detailed explanation for any STIR/SHAKEN exemption | Filers certifying partial or no implementation | § 64.6305(d)–(f)(2)(i) |
Write it in English, or attach a certified English translation (§ 64.6305(d)(2)), and upload it as a PDF (FCC filing instructions). If you play more than one role, one plan is enough, but it should explain any steps that differ by role (DA 24-73). A form field that is too short can point to a section of the plan (FCC FAQ 8).
What the FCC treats as deficient
- a confidentiality request with no underlying filing;
- only non-responsive documents, such as a screenshot of your FRN record;
- text that merely explains how STIR/SHAKEN works, with nothing about your own efforts;
- a certification not in English and without a certified translation (DA 24-73).
Such filings may be removed through the FCC’s expedited procedure (DA 24-73). On September 2, 2026 the Enforcement Bureau removed 14 providers whose certifications, “inclusive of their robocall mitigation plan,” lacked required information (DA 26-872). Since January 2026 anyone can report a deficient filing to RMD-Reporting@fcc.gov (DA 26-72), and redacted plans are public (FCC FAQ 7).
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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