Good morning. Your phone is your lead flow. There is a federal database that decides whether anyone on the network is allowed to accept calls from the company that supplies it — and one order in 2025 struck more than a thousand filings off it.

Top story — The database your carrier is in, and what happens when it isn't

The FCC runs the Robocall Mitigation Database. Voice service providers file in it, and the filings carry certifications about how the provider stops illegal calls. The FCC says the Database "currently contains over 11,000 filings."

The part that matters to you is the rule attached to it. Under 47 CFR 64.6305(g), a provider may accept calls sent directly from another provider only if that provider's filing appears in the Database and has not been removed. The FCC states the consequence plainly: "Because downstream providers may only accept voice calls directly from another provider if that provider's filing appears in the Database and has not been removed pursuant to an enforcement action, removed providers are effectively prevented from transmitting voice calls on the U.S. voice network."

This is not theoretical. The Commission says it "has removed over 1,400 deficient filings since January 2025," and it names the scale: "two orders in August 2025 that removed 1,203 and 185 filings, respectively."

Then there is the speed, and this is the part most people get wrong. There is no deadline in the rule itself. What exists today is a Bureau practice, which the FCC describes this way: in an earlier caller-ID authentication order the Commission "concluded that the existing Enforcement Bureau process, whereby providers are given two business days to block calls following Commission notice of removal from the Database, is sufficient." The FCC now proposes to write a timeline into the rules, and it is asking in both directions at once — it seeks comment "on whether the current two-day compliance timeline is reasonable, and on the burdens and costs to providers in complying, and on the impact on customers of the deficient filer," and asks whether "a default minimum timeline" should "require downstream providers to cease accepting calls immediately upon release of the removal order, within the current two business days, or some other length of time." It also floats letting the Enforcement Bureau set a longer one.

So the question for an owner is not whether the FCC is right. It is whether you know the name of the entity whose filing your phone number depends on.

Quick hits

  • A number the agency published about its own record. The FCC writes: "We note that 6,689 RMD filings indicate full or partial implementation of STIR/SHAKEN, but that only 2,143 providers appear on the Governance Authority's list of authorized providers." The Commission offers no explanation for the gap beyond a question — "Are providers filing independently in the RMD but sharing SPC tokens?" It is a discrepancy in the agency's own records, published by the agency.

  • You do not have to file, and nobody should be telling you otherwise. In the FCC's words: "Although end users are not required to file in the RMD, and we do not condone voice service providers compelling their end users to submit RMD filings, Commission staff have observed that some entities that do not consider themselves 'voice service providers' nevertheless submit RMD filings out of an abundance of caution or because the provider supplying them with voice service requires them to do so to transmit their calls." The Commission goes on to ask whether there are "potential downsides or unintended consequences, and if so, should we prohibit voice service providers from requiring end users to file in the RMD?" ⚠ One caution, in the agency's own framing: it says that "for the purposes of our rules targeting illegal calls," voice service "includes PBXs, dialing platforms, cloud service providers … call centers" and several other categories, where they furnish voice communications using North American Numbering Plan resources — and it is still seeking comment on where "end user" ends. If your shop resells or re-provides phone service to anyone, that is a question for your lawyer, not for a newsletter.

  • A warning to customers is being proposed, not promised. The proposed rule text adds a customer-notice requirement at § 64.6305(l), covering providers "subject to a removal order, suspension (if adopted), or mandatory blocking order." The FCC asks which providers should have to give it — "only retail providers, or also wholesale providers whose customers may include resellers, call centers, enterprise users, or other service providers?" Its own reasoning: notice "may reduce consumer disruption by informing lawful customers that their service may be affected and by allowing them to migrate to another provider." Comments are due 9 October 2026; reply comments 9 November 2026.

The Tip — Two questions, in writing, to whoever bills you for phone service

Ask them this week and keep the answers. One: "Which legal entity actually hands our calls to the network, and is that entity's filing currently published in the Robocall Mitigation Database — under what name, and what OCN if it has one?" Two: "If that filing were removed, what is your plan for our service, and how quickly would you tell us?" A provider that can answer both in a sentence is fine. A provider that cannot tell you which entity is filed has told you something. Then check it yourself: the core filings are public — the Wireline Competition Bureau, when it issued the Database's protective order, "made clear that 'certifications, contact information, and other data submitted to the Robocall Mitigation Database are public and cannot be marked as confidential'" — so the Database is searchable on the FCC's own site. Note that this proposal would narrow that: the FCC proposes that contact details for human principals, some business addresses, and "information about providers' use of third parties should not be made public."

Tool watch — [Not sponsored]

The Federal Register version is free at federalregister.gov, runs 36 pages, and is a summary — the FCC's own full text sits behind a link inside it. Most of the 36 pages is about other people's compliance problems. The part worth your two minutes is the proposed rule text at the very end, under "PART 64". Proposed § 64.6305(o) is the one to read. It has two prohibitions, not one — the same bar on accepting calls applies to domestic and to foreign providers: "A voice service provider shall not accept calls directly from a domestic voice service provider unless that domestic voice service provider's filing appears in the Robocall Mitigation Database … and has not been removed pursuant to Commission action." Then come the carve-outs that survive regardless — 911 calls may not be blocked "under any circumstances," and providers "must make all reasonable efforts" not to block calls from public safety answering points. Two prohibitions, two exceptions, and your service line is none of the four.

That's the callout. See you next time.

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