Prefer to listen while you’re on the go? We’ve created an audio version of this Client Advisory that you can play anytime, anywhere.
Canadian Radio-Television and Telecommunications Commission (“CRTC” or “Commission”) Staff has suspended the requirement to file semi-annual STIR/SHAKEN implementation status reports pending a review of the reporting process. As a result of this suspension, no November 2025 report is required. This pause does not alter underlying STIR/SHAKEN implementation obligations for IP-based voice. Providers should continue operating and improving call authentication and prepare for possible reinstated or modified reporting following the review.
What Happened
Commission Staff informed industry via email that, as part of efforts to balance oversight with reduced administrative burden, it is reviewing the STIR/SHAKEN reporting process to ensure it remains effective and efficient. Accordingly, providers are not required to submit the semi-annual status report that would normally be due in November. Future reporting requirements will be communicated when determined.
What Has Not Changed
- STIR/SHAKEN remains mandatory for IP-based voice pursuant to Compliance and Enforcement and Telecom Decision CRTC 2021-123(effective November 30, 2021).
- Previously recognized carve-outs (e.g., for certain 9-1-1 call paths) and implementation contours remain governed by subsequent decisions and working-group outputs (e.g., CRTC 2021-426; CST-GA guidance).
Why It Matters
The suspension relieves near-term filing burden but does not relax technical obligations. Providers should anticipate the CRTC could reinstate reporting (potentially with new metrics, cadence, or scope) after the review. Maintaining robust internal tracking now will minimize scramble and risk when external reporting resumes.
Recommended Actions
- Do not file the November 2025 semi-annual STIR/SHAKEN status report (unless the CRTC issues new instructions).
- Sustain technical compliance: continue end-to-end signing/verification, attestation policies, error handling, certificate lifecycle management, and partner interop.
- Keep your evidence ready: maintain internal dashboards/metrics (e.g., % signed/verified, non-IP handoffs, failures, traceback responsiveness) so you can rapidly reactivate external reporting in whatever form the CRTC specifies.
- Watch for updates: assign a point person to monitor Commission releases and Staff letters; we will also circulate alerts on any reinstated or revised reporting obligations.
Additional Background
- Core mandate: CRTC directed TSPs to implement STIR/SHAKEN for IP-based voice as a condition of service effective November 30, 2021.
- Framework guidance: Canadian Secure Token Governance Authority (CST-GA) guidelines detail token/certificate governance and operational best practices supporting the Canadian STIR/SHAKEN ecosystem.
Looking Ahead
We expect the Staff review to consider utility vs. burden of semi-annual filings and whether alternative measures (e.g., targeted metrics, risk-based attestations, exception reporting, or integration with other reliability/consumer-protection reporting) could better achieve policy goals. Providers should remain prepared for:
- Reinstated semi-annual reports with modified content; or
- A new reporting cadence (e.g., annual or event-triggered) with standardized metrics.
We will update clients immediately when the Commission announces the outcome of its review and any revised obligations.
How We Can Help
- Compliance tune-up: Rapid review of your STIR/SHAKEN posture, attestations, and certificate hygiene.
- Reporting restart kit: Templates and data pipelines to meet any reinstated or modified metrics without disruption.
- Cross-border alignment: Harmonize FCC/CRTC obligations for providers operating in both markets.
Contact Michal J. Nowicki mjn@commlawgroup.com