Client Advisory | General Regulatory & Legal Advisory

FCC Withdraws STIR/SHAKEN Exemptions From Vonage and Bandwidth for Failure to Update Networks

On Thursday, February 17, 2022, the Federal Communications Commission released an Order that withdrew STIR/SHAKEN exemptions from two voice service providers, Vonage and Bandwidth. The FCC found that these providers failed to fully implement STIR/SHAKEN following the period of leniency granted to them by the exemption. The FCC has referred Vonage and Bandwidth to the agency’s Enforcement Bureau for further investigation.

Large voice providers were required by the FCC to implement STIR/SHAKEN by June 30, 2021. STIR/SHAKEN technology is designed to reduce illegal robocalls on the provider’s network by using common information sharing language to verify caller ID information. This allows consumers and the provider’s own robocall blocking software to judge the legitimacy of an incoming call.

STIR/SHAKEN is the result of a congressional mandate found in the TRACED Act. That said, Congress also dictated that certain providers should be granted leniency with respect to full implementation of STIR/SHAKEN by the June 30, 2021 deadline if they could demonstrate early implementation progress of the technology by December 30, 2020. Exempted providers were then required to certify full implementation of STIR/SHAKEN authentication on October 4, 2021.

After reviewing the certifications submitted by Vonage and Bandwidth, the FCC found that they both failed to achieve full implementation. Specifically, the FCC stated in the Order that Bandwidth “has not yet completed all necessary network updates to support [STIR/SHAKEN] throughout its entire [IP] network” because it “still operate[s] some legacy IP equipment that supports a de minimis amount of traffic that cannot support the STIR/SHAKEN standards at this time.” Similarly, Vonage “is not verifying caller ID information for all authenticated calls” because only “50% of outbound SIP calls [are] being validated.” As a result of this incomplete compliance, the FCC has referred Bandwidth and Vonage to the Enforcement Bureau for further monitoring.

In a press release published by the FCC, Chairwoman Jessica Rosenworcel stated that the Commission “will not turn a blind eye to providers who have not done enough to protect consumers from spoofed robocalls.” “The FCC is keeping a close watch as phone companies implement STIR/SHAKEN – a critical tool to help robocall blocking and consumer information,” she said. “We will hold companies accountable if they fail to meet their commitments.”

This action demonstrates that the FCC is not holding its punches when it comes to robocall mitigation compliance, especially considering the ongoing public outrage with the pervasive nature of spam calls. Partial compliance will not cut it.

Given the complexity and evolving nature of the FCC’s rules, regulations and industry policies & procedures around Robocall Mitigation and Compliance issues (e.g., Stir/Shaken, TRACED Act, FCC Rules & Regulations, US Telecom Industry group, ATIS, NECA, VoIP Numbering Waivers, Know Your Customer and the private sector ecosystem), as well as the increased risk of business disputes, consumer protection enforcement by state attorneys general, and even civil litigation, and anticipating the potential torrent of client questions and concerns, The CommLaw Group formed a “Robocall Mitigation Response Team” to help clients (old and new) tackle their unique responsibilities. If you would like one of our expert attorneys to review your robocall mitigation procedures for full compliance with FCC rules, please contact us.

Michael Donahue — Tel: 703-714-1319 / E-mail:

Rob Jackson – Tel: 703-714-1316 / E-mail:

Ron Quirk – Tel: 703-714-1305 / E-mail:


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