Non-IP STIR/SHAKEN Extension Requirements
The Federal Communication Commission’s (FCC’s) Call Authentication Trust Anchor Sixth Report and Order, which was adopted on March 16, 2023, granted a continuing extension of the STIR/SHAKEN implementation deadline for portions of voice service providers’ networks that rely on technology unable to initiate, maintain, carry, process, and terminate Session Initiation Protocol (SIP) calls — that is, non-Internet Protocol (non-IP) networks.
However, to remain in compliance with the requirements of the FCC’s continued extension, service providers must:
- Maintain and be ready to provide the Commission on request with documented proof that they are participating, either on their own or through a representative, including third-party representatives, as members of a working group, industry standards group, or consortium that is working to develop a non-IP caller identification authentication solution, or actively testing such a solution; and
- Update their Robocall Mitigation Plans (RMPs) to include certain new information required under the FCC’s March 16, 2023 order.
If the above requirements are not met, then the service providers will be required to upgrade their entire networks to fully implement the STIR/SHAKEN framework throughout those networks.
Universal Robocall Mitigation Database Filing Obligations
Under its March 16, 2023 order, the FCC will require all providers, regardless of whether they are required to implement STIR/SHAKEN, to file an RMP and include additional information, if applicable. Notably, the additional RMP information required under the FCC’s new order includes:
- The STIR/SHAKEN extension rule that applies to the relevant service providers;
- The specific “reasonable steps” taken by those providers to avoid the origination, carrying, or processing of illegal robocall traffic;
- Any call analytics used by the providers to identify and block illegal traffic and, if third-party vendors are used, the name of the relevant vendors;
- Contractual provisions with end-users or upstream providers designed to mitigate illegal robocalls;
- How the relevant providers know their upstream providers;
- The relevant providers’ roles in the call chain;
- The procedures that the providers use to know their new and renewing customers; and
- The providers’ robocall mitigation techniques.
Service providers must also provide their Operating Company Numbers (OCNs), certify that their companies have not been prohibited from filing in the Robocall Mitigation Database (RMD), and explain any recent formal law enforcement or regulatory investigations into suspected unlawful robocalling involving their companies.
The due date for the expanded RMPs, inclusive of the new information discussed above, will be the later of:
- 30 days following publication in the Federal Register of notice of approval by the Office of Management and Budget (OMB) of any associated Paperwork Reduction Act (PRA) obligations; or
- A deadline to be set by the the FCC’s Wireline Competition Bureau through Public Notice.
JSI will notify its clients of the due date once it is announced by the FCC.
For assistance with your RMPs, please contact Bridget Alexander White by telephone at 301-459-7590 or through email by clicking the “Connect with Us” button below.