On September 2, 2026, the Consumer and Governmental Affairs Bureau (“CGB”) of the FCC released a Public Notice (“PN”) seeking comment on establishing a robocall mitigation scorecard (“Scorecard”) aimed at providing consumers with a simple, easy-to-understand tool to evaluate providers’ effectiveness in combatting illegal robocalls. The PN explains that “this is not a rulemaking that will result in new rules or requirements for voice service providers.” Rather, the Scorecard will be a public-facing document published by the FCC and updated periodically. Specifically, the PN seeks comment on the following aspects of the Scorecard:
Scorecard Structure and Provider Scope:
- The FCC intends for the Scorecard to offer a set of metrics reflecting both operational practices and measurable outcomes, rather than a simple administrative checklist, and clarifies that the Scorecard will not be an indication of whether providers have or have not complied with the FCC’s robocall rules. (¶¶ 4-5)
- The FCC suggests the Scorecard should reflect the following key principles: (1) it must be easy to understand and accessible to consumers; (2) its rating criteria must be relevant, accurate, and derived from sources whose reliability limitations are clearly disclosed, without inherently disadvantaging any particular provider; and (3) there must be an iterative process to improve the Scorecard. (¶ 6)
- The Commission proposes to limit the Scorecard only to domestic voice service providers with retail customers, including wireless, wireline, VoIP, and hybrid network providers. The FCC notes it does not intend to “rate all such providers and instead aim[s] to include those that collectively serve the vast majority of the retail market.” The FCC seeks comment on this approach, including what threshold should be considered. This proposal would exclude providers that operate solely as wholesale or intermediate providers. (¶ 7)
- The FCC seeks comment on whether to include only the largest providers based on the number of subscribers, whether to specifically exclude or treat differently small and regional providers, and whether FCC Form 477 data should be used for the determination of whether a provider is large, small, or regional. (¶ 8)
Data Sources:
- The FCC seeks comment on what sources of data should be used to inform the Scorecard, asking whether providers are a good, or sometimes the only, source of data. The PN also suggests call analytics companies, private companies, or other governmental entities. (¶ 9)
- The FCC proposes utilizing the following sources of data to develop scoring metrics for the Scorecard: (i) Robocall Mitigation Database (“RMD”) filings; (ii) provider-offered consumer tools or services; (iii) provider blocking practices; (iv) FCC Consumer Complaints Center data; (v) FCC enforcement action data; (vi) third-party or industry sources; (vii) Industry Traceback Group data; and (viii) Federal Trade Commission complaint data. The FCC seeks comment on this proposal and which data is most useful from each listed source. (¶ 10)
Metrics:
- The FCC plans to use two general categories of potential metrics:
- Conduct-Based Metrics include: (i) provider-offered consumer tools to label or block calls; (ii) provider network efforts to label or block calls; (iii) provider responses to traceback requests; and (iv) provider attestation of SIP calls (unless exempt). (¶ 13)
- Outcome-Based Metrics include: (i) consumer complaints filed with the FCC, FTC, and other governmental bodies; (ii) aggregated data on the number or percentage of calls blocked, together with the false positive rate as a separate measure of blocking accuracy; (iii) aggregated data on the number or percentage of illegal robocalls consumers receive; and (iv) trend data showing whether the volume or rate of illegal robocalls reaching a provider’s subscribers has changed over time. (¶ 14)
- The Commission seeks comment on whether the above metrics are best indicators of how well a provider is protecting its customers, how each group of metrics should be weighed against the others, whether provider size should be considered when calculating scores from each metric, and whether there are other metrics that should be included. (¶¶ 15-16)
- The Commission seeks comment on incorporating metrics that measure both provider actions and consumer outcomes, including how best to implement such an approach. (¶ 16)
- The FCC additionally asks whether there are limitations to utilizing consumer complaint data, how best to source data on the accuracy of blocking tools, and how to utilize enforcement actions that are still subject to appeal or judicial review in the Scorecard. (¶¶ 17-18)
Methodology:
- The FCC seeks comment on how to display the Scorecard metrics, including whether through a composite score or scores by individual metric, and whether the score should be on a scale of 1-10, a letter grade, or a percentage system (e.g., 95%). The FCC also seeks comment on classifying providers by risk tiers. (¶ 20)
- The Commission asks whether it should place providers in banded tiers based on scores and whether a provider’s scores should be standardized against a fixed score or distributed across providers based on comparative scores. (¶¶ 20-21)
- The FCC asks whether it should use a checkbox system for each category, wherein a provider either receives points for that category or does not, as the standard for each scoring category, or a more qualitative assessment of each provider. (¶ 22)
- The Commission seeks comment on how frequently the Scorecard should be updated, and whether a provider should be given a chance to review and challenge its score either prior to or after publication. (¶ 23)
Accessibility and Language Access:
- The Commission requests comment on how it can design the Scorecard to ensure that individuals with disabilities have access to information comparable to that available to individuals without disabilities. (¶ 24)
- The FCC asks whether the Scorecard should be available in languages other than English. (¶ 24)
Comments are due September 22, 2026; replies are due October 2, 2026.
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