FCC Adopts New Rules to Strengthen Robocall Mitigation Database Requirements

FCC Adopts New Rules to Strengthen Robocall Mitigation Database Requirements

The Federal Communications Commission (FCC) has adopted new rules to improve the overall quality of Robocall Mitigation Database (RMD) submissions and strengthen the procedures providers must follow to submit, update, and maintain accurate filings. These changes, adopted on December 30, 2024, represent significant enhancements to the RMD’s effectiveness as a compliance and consumer protection tool. The RMD serves as an essential resource for housing information necessary to assist the Commission in evaluating providers’ compliance with robocall mitigation rules and is used by federal and state enforcement bodies for investigations, as well as by service providers who are prohibited from accepting voice traffic from providers not listed in the RMD.

Under the new rules, providers are required to update any information submitted to the Commission Registration System (CORES) within 10 business days of any change. The Commission has also established a new annual recertification requirement, with providers needing to recertify their RMD filings by March 1 each year. Both initial submissions and annual recertifications will require a $100 filing fee and are subject to the FCC’s red-light rule, which means it will not process applications from entities with outstanding debts. Additionally, providers will need to comply with new two-factor authentication requirements for accessing the database.

The Commission has implemented new enforcement measures to ensure compliance with these requirements. These include a $10,000 base forfeiture for submitting false or inaccurate information and a $1,000 base forfeiture for failure to update information within required timeframes. The Commission is also establishing a dedicated reporting mechanism for identifying deficient filings, which will help improve oversight and compliance.
Recognizing the potential impact on smaller providers, the Commission has taken steps to minimize the burden while maintaining the effectiveness of these new requirements. The $100 filing fee will only be assessed at initial filing and annual recertification, not for interim updates. Furthermore, forfeitures may be adjusted based on specific circumstances, including the provider’s size and ability to pay.

Most provisions of the Order will become effective 30 days after publication in the Federal Register. However, certain provisions, including the filing fee requirement, will take effect at a later date following required notifications to Congress and system updates. The Commission will publish notices in the Federal Register announcing the effective dates of these provisions. JSI will send a follow-up e-Lert once these notices have been published to make clients aware of the deadlines.

JSI recommends that clients review their current RMD filings to ensure accuracy and establish processes for timely updates of both CORES and RMD information. We can assist with reviewing your current filings, establishing compliance procedures, and preparing for the new annual recertification requirement. For questions or assistance with RMD compliance, please contact Bridget Alexander White or Brett Hallagan.