Does a VoIP reseller with no network of its own have to file in the Robocall Mitigation Database?
Yes. The FCC says any provider meeting the definition of a voice service provider, “including voice over Internet protocol (VoIP) resellers and mobile virtual network operators (MVNOs),” must file in the RMD. Owning no switch does not exempt you, and the filing is yours to make: until it appears, U.S. providers must refuse the calls you send them directly.
Why a reseller is a voice service provider
“Voice service” is any service interconnected with the public switched telephone network that furnishes voice communications to an end user using North American Numbering Plan resources (47 CFR § 64.6300(o)). Selling a wholesale platform’s service under your own name fits, and the FCC’s filer FAQ names VoIP resellers and MVNOs. In February 2026 the Enforcement Bureau applied it to MVNOs: one that resells voice services “qualifies as a ‘voice service provider’” and must file, and the duty reaches providers “without the facilities necessary to implement STIR/SHAKEN.” It added that resellers serving end users “are often in the best position to identify customers that are the source of apparently illegal traffic” (DA 26-174).
What your own filing covers
- Your own business-type FRN: the form cannot be submitted with an individual-type FRN, and each filing belongs to one FRN (FCC filing instructions, July 2026).
- A plan describing how you know new and renewing customers (47 CFR § 64.1200(n)(4)), any procedures to know your upstream providers, and your analytics. If you rely on your wholesale provider’s analytics, name that provider (§ 64.6305(d)(2)(ii); FCC FAQ 12–13).
- A commitment to answer traceback requests within 24 hours (§ 64.6305(d)(2)(iii)).
- Your role and STIR/SHAKEN option. That your downstream provider signs your calls is not a valid basis for an exemption (FCC 26-49).
If you are not listed
Voice service and intermediate providers may accept calls directly from a domestic voice service provider only if its filing appears in the Database (47 CFR § 64.6305(g)(1)); for a reseller, that usually means the wholesale platform carrying your calls. All providers have had to file since February 26, 2024, whatever their STIR/SHAKEN status (DA 26-174). The FCC’s September 2026 proposals would further clarify who must file; they are proposals, not rules (FCC 26-49).
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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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