Canada’s CST-GA Releases SPC Token Application; CRTC’s Full STIR/SHAKEN Implementation Deadline is Nov 30

SPC Token Application Available with Just Over a Week to Implement STIR/SHAKEN

The Canadian Secure Token – Governance Authority‎ (CST-GA) released its much-anticipated and long-awaited SPC Token Application. Available only via this direct link, the Application generally tracks what was expected and will allow currently ineligible Telecommunications Service Providers (TSPs) to obtain Service Provider Code (SPC) Tokens. (Currently ineligible TSPs are ineligible because they lack access to Canadian Numbering Administrator resources.) SPC Tokens will, in turn, allow these TSPs to access Secure Telephone Identify (STI) Certificates, necessary for higher (Level A or B) attestation.

Recognizing the Canadian Radio-television and Telecommunications Commission’s (CRTC) November 30, 2021 deadline for TSPs to fully implement STIR/SHAKEN as a condition of providing or offering service, the CST-GA has committed to expedited review with provisional approval within three business days of receiving an application.

SPC Token Application Questions Suggest All TSPs Must Implement STIR/SHAKEN and Submit Reports if They Offer IP-Based Voice Calls

The SPC Token Application, now in final form, still asks as the first “Reputation” question, “[w]hen has the applicant last filed a STIR/SHAKEN readiness report per CRTC Decision 2021-123 appendix 1 or 2?”

As previously noted, this suggests (and matches our previous guidance) that all TSPs in Canada—including those relying on underlying providers for technical STIR/SHAKEN implementation—should file the reports mandated by the CRTC.

The CRTC’s STIR/SHAKEN Implementation Order:

  1. Directs TSPs to implement STIR/SHAKEN to authenticate and verify caller identification information and
  2. “[D]irectsTSPs to file STIR/SHAKEN implementation readiness assessment reports by 31 August 2021 and to add certain details to those reports.”

The CRTC’s order makes no exception for TSP size or whether a TSP relies on an underlying provider for implementation, and the CRTC has not indicated such an exception applies.

Take Action Today to Obtain an STI Certificate By Month-End and Comply with STIR/SHAKEN Obligations

Interested currently ineligible TSPs should contact our firm today to discuss the SPC Token Application criteria, obtain help preparing and filing an application, and otherwise ensure full STIR/SHAKEN compliance in Canada. Following expedited SPC Token Application review by the CST-GA, TSPs must still apply for an STI Certificate; acting quickly can secure an STI Certificate prior to the STIR/SHAKEN implementation deadline.

There is no general de minimis exemption for providing service in Canada. Rather, TSPs must comply with relevant, applicable registration, licensing, and other requirements (such as STIR/SHAKEN). Taking a proactive approach is the most prudent way to ensure you remain compliant or fix compliance issues before they become compliance catastrophes.

If you have questions about the applicability of the CRTC’s STIR/SHAKEN requirements, need assistance with preparing an SPC Token application, or have other CRTC compliance questions, please reach out to Ivan Zajicek at 703-714-1310 or isz@commlawgroup.com.

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