Which STIR/SHAKEN option should a VoIP reseller certify in the Robocall Mitigation Database?
The one your facts support. Options 1 and 2 require your own SPC token and certificate; a wholesaler may sign for you, but only with your certificate. Options 2 and 3 require a valid exemption, such as no control over the network infrastructure, explained in detail. Being small, or having your carrier sign your calls, does not qualify.
What each option commits you to
- Option 1, complete implementation: only if your entire network is IP-based, with your own SPC token and certificate used on all your calls (FCC FAQ 9).
- Option 2, partial: your own token and certificate on the IP portions of your network, and a stated exemption for the rest (FCC FAQ 10).
- Option 3, none: state the rule that exempts you and explain in detail why it applies (FCC FAQ 10; filing instructions).
A third party can sign for you only under a written agreement: it signs with your certificate, you make every attestation-level decision, and you keep the agreement two years after it ends (47 CFR § 64.6301(b)). Hiring one does not change whether you have an implementation obligation (FCC FAQ 11).
Exemption bases, as the FCC described them in September 2026
| Basis | Status | Source |
|---|---|---|
| Non-IP portions of your network | Valid continuing extension | § 64.6304(d) |
| Cannot obtain an SPC token because of Governance Authority policy | Valid today; the FCC has proposed repealing it | § 64.6304(b); FCC 26-49 |
| No control over the network infrastructure needed to implement STIR/SHAKEN | Valid, though not codified; the FCC proposes to codify it | FCC 26-49 |
| Small provider originating calls via satellite with NANP numbers | Valid continuing extension; the FCC has asked whether to repeal it | § 64.6304(a)(1)(iii); FCC 26-49 |
| “We are a small provider” | Not valid: the small-provider extensions expired June 30, 2022 and June 30, 2023 | § 64.6304(a); FCC FAQ 10 |
| No access to numbers; no SPC token; “our downstream provider signs our calls” | Not valid | FCC 26-49 |
Why it matters now
In September 2026 the FCC noted that 6,689 RMD filings indicate full or partial implementation, while only 2,143 providers appear on the Governance Authority’s list of authorized providers (FCC 26-49, 91 FR 57456–57). An option you cannot support is inaccurate information: a $10,000 base forfeiture per violation, continuing until cured (§ 1.80(b)(11)). Review your selection against the Eighth Report and Order changes effective September 18, 2025 (DA 26-72). A temporary exemption for providers still obtaining a token is only proposed (FCC 26-49).
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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