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With just weeks remaining before the FCC’s September 18, 2025 STIR/SHAKEN compliance deadline, voice service providers face a make-or-break moment that will determine their operational future. The technical implementation requirements are more nuanced than many anticipated, and the consequences of non-compliance are severe—as demonstrated by the FCC’s recent removal of over 1,200 companies from the Robocall Mitigation Database.

These companies are now experiencing complete traffic blocking by upstream carriers, causing irreparable harm to their businesses as customers defect due to service disruptions. The September 18 deadline isn’t just another regulatory milestone—it’s a hard cutoff that will separate surviving providers from those facing potential business extinction.

Requirements Depend on Facility Control

The regulatory obligations for voice service providers—including those offering facsimile services and Fax over IP—depend fundamentally on whether they have control of the facilities where STIR/SHAKEN can be implemented.

Providers WITH facility control must:

  • Implement full STIR/SHAKEN authentication on network infrastructure
  • Obtain appropriate certificates from authorized Certificate Authorities
  • Sign outbound calls with proper attestation levels
  • Validate incoming signed calls appropriately
  • Maintain comprehensive implementation documentation

Providers WITHOUT facility control must:

  • File detailed robocall mitigation plans with alternative measures
  • Work with upstream providers that have STIR/SHAKEN implementation
  • Implement reasonable anti-robocall measures within their operational scope
  • Monitor and respond to robocall complaints and illegal traffic

Complimentary Technical Assessment Available

Recognizing the complexity of these requirements and the catastrophic consequences we’ve witnessed, our colleagues at ECG are offering complimentary technical evaluations to help providers assess their compliance before the deadline.

ECG brings unique qualifications to this challenge:

  • Independent consultancy exclusively representing voice service providers
  • STIR/SHAKEN deployments ranging from 5,000 to 3+ million subscribers
  • Technical partnerships with leading providers including TransNexus and Sansay
  • Experience serving as technical experts on compliance matters

The complimentary evaluation includes:

  • Comprehensive review of current STIR/SHAKEN implementation
  • Comparison against FCC requirements
  • Identification of compliance gaps
  • Practical recommendations for remediation
  • No-charge consultation to discuss findings

Given the technical complexity and the severe business disruptions already occurring in the marketplace, no provider should assume their implementation is fully compliant without professional verification. The rules are nuanced, and implementation details can significantly impact compliance status.

Time is running short. The September 18 deadline will arrive regardless of preparation levels, and the FCC has demonstrated its willingness to enforce requirements without regard for business impact.

For ECG’s complimentary STIR/SHAKEN assessment, contact:

Clay Griner
CGriner@ecg.co
+1-229-316-0023

This advisory is provided for informational purposes. Providers should consult with appropriate technical and legal experts regarding STIR/SHAKEN compliance.

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