Will Your Telecom/VoIP Company Have Legitimate and Lawful Calls Blocked by the Big Terminating Carriers (aka, Your Competitors) Courtesy of the STIR/SHAKEN Robocall Mitigation Regime?

Will my Customers’ lawful calls get blocked by the Big Carriers (AT&T, Verizon, CenturyLink, Comcast, T-Mobile, and others) thanks to the STIR/SHAKEN robocall mitigation regime (a regime the Federal Communications Commission is largely putting into the hands of the very same Big Carriers)?


Is there anything my Company can do between NOW and June 30, 2021 to ensure our Customers’ lawful call traffic is NOT BLOCKED?

Have you asked yourself these questions yet?  If not, it’s about time you did!


In March 2020, the FCC adopted rules “requiring voice service providers to implement the STIR/SHAKEN caller ID authentication framework in the IP portions of their networks by June 30, 2021.”[1]  In order to obtain certificates used for the intercarrier exchange of authenticated caller ID information under the STIR/SHAKEN Governance Authority’s current policies, a service provider must satisfy the following “Three-Pronged” qualification requirements:

  • File FCC Form 499A;
  • Receive an Operating Company Number (“OCN”), which is assigned by the National Exchange Carrier Association (“NECA”); and
  • Obtain FCC permission for direct access to telephone numbers from the North American Numbering Plan Administrator (“NANPA”) and the National Pooling Administrator (“NPA”).

A number of service providers desiring to be full participants in STIR/SHAKEN, but which cannot qualify for certificates, have requested the Governance Authority reexamine its participation requirements.  For example, one-way VoIP providers cannot obtain numbers directly from NANPA or the NPA.  Many VoIP providers lease numbers from other carriers and, as such, do not qualify.

In recognition of the Authority’s reevaluation process, the FCC is reconsidering its rules and policies.  Given the short time between now and the June 30, 2021 deadline for STIR/SHAKEN participation, the FCC’s proposed Draft 2nd R&O[2] would conditionally grant a two-year extension for both small voice service providers, serving fewer than 100,000 lines, and voice service providers that cannot obtain a certificate due to the token access policy because, for example, they lease telephone numbers from other carriers.  Any provider receiving an extension of time must develop a robocall mitigation plan that includes participation in the Industry Traceback Group and file such plan with the FCC.

The “Bottom Line” is that VoIP service providers must either:

  1. Satisfy the existing “Three-Pronged” qualifications, most likely by filing for and receiving FCC authority to obtain numbering resources directly from NANPA or the NPA; or
  2. Qualify for the two-year extension. 

Decisions as to which approach to take should come soon!

The CommLaw Group’s attorneys have been in frequent, in-depth contact with key Industry and FCC Staff concerning these options and potential changes in the “Call Certificate Qualifications.” 

We are available to work with your Company and its management team to find the best path for your VoIP operations and to assist with any required filings. 

For those electing to pursue the Three-Prong path, our firm is offering a $5,000 flat fee package that includes the preparation and filing of an Operating Company Number (OCN) application and FCC Waiver Petition, seeking direct access to numbering resources applications (52.15(g)).  NOTE: The flat fee covers the applications, but excludes collateral legal advice and guidance that may be needed prior to filing with the respective agencies.

If you are interested in assistance in making these decisions or with associated filings, please contact Robert H. Jackson at rhj@commlawgroup.com or Jonathan S. Marashlian at jsm@commlawgroup.com or for more information or to take advantage of our firm’s fixed-fee offer.


[1] Call Authentication Trust Anchor, Implementation of TRACED Act Section 6(a)—Knowledge of Customers by Entities with Access to Numbering Resources, Report and Order and Further Notice of Proposed Rulemaking, 35 FCC Rcd 3241, at ¶ 24 (2020).

[2] Call Authentication Trust Anchor, Second Report & Order, WC Docket No. 17-97, FCC-CIR2009-04 (“Draft 2nd R&O”).  

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