FCC Releases R&O Imposing Shortened STIR/SHAKEN Implementation Deadline for Certain Small Voice Service Providers

On December 10, 2021, the FCC released a Fourth Report and Order requiring small service providers that are most likely to be the source of illegal robocalls to implement STIR/SHAKEN on an accelerated timeline.   Two categories of providers are required to implement STIR/SHAKEN on an accelerated timeline: 1) non-facilities based small voice service providers; and 2) providers identified by the Enforcement Bureau as likely to be originating a large number of illegal calls.

First, non-facilities based providers, defined as those voice service providers that offer voice service to their end-users solely using connections that are not sold by the provider or its affiliates, will be required to implement STIR/SHAKEN in the IP portions of their network by June 30, 2022.  These providers are required to update their certifications in the Robocall Mitigation Database within 10 days of the effective date of the Order to reflect the fact that they are no longer subject to an extension until June 2023, and are further required to subsequently update their certifications within 10 days of completion of STIR/SHAKEN implementation.  The Wireline Competition Bureau will be sending written notice to small voice service providers listed in the Robocall Mitigation Database (1) for which the most recent FCC Form 477 filing indicates that it is non-facilities-based and (2) that does not update its Robocall Mitigation Database certifications in a timely manner to indicate that it is no longer subject to an extension until June 2023.

Second, small voice service providers found by the Enforcement Bureau to have, upon notice, failed to mitigate suspected illegal robocall traffic, failed to provide information requested by the Enforcement Bureau, including credible evidence that they are not originating illegal traffic, failed to respond in a timely manner, or violated section 64.1200(n)(2) of the Commission’s rules will be required to implement STIR/SHAKEN within 90 days of the date of the Enforcement Bureau’s determination.  These providers are required to update their certifications in the Robocall Mitigation Database within 10 days of the Enforcement Bureau’s determination to reflect that they are subject to a shortened extension and to update the database again once they have implemented STIR/SHAKEN.

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