Last January, the Federal Communications Commission (FCC) adopted new rules mandating Disaster Information Reporting System (DIRS) compliance for telecommunications and interconnected VoIP providers. These rules, outlined in the FCC’s Report and Order and Further Notice of Proposed Rulemaking (RO/FNPRM), officially went into effect on January 21, 2025. Affected providers must achieve full compliance by February 20, 2025.
Summary of the New DIRS Reporting Rules
The FCC’s updated Disaster Information Reporting System (DIRS) rules impose new requirements on telecommunications and interconnected VoIP providers to ensure timely and accurate reporting during emergencies. These rules aim to enhance the FCC’s ability to monitor service outages and coordinate recovery efforts effectively.
Key Requirements for Affected Providers
- Mandatory Reporting During Emergencies: Providers must submit detailed reports through the DIRS platform when activated by the FCC. These reports are crucial for assessing service disruptions and guiding recovery efforts in disaster-impacted areas.
- Preparedness for Compliance: Providers are required to establish robust internal systems and processes to gather and report information, including details on outages, restoration progress, and service availability.
- Confidentiality Protections: The rules include safeguards to protect submitted data from public disclosure, ensuring that sensitive information remains secure.
- Mandatory Participation: Participation in DIRS reporting is no longer optional. Telecommunications and interconnected VoIP providers operating in areas affected by disasters are legally required to comply with these reporting obligations.
Specific Impacts on Interconnected VoIP Providers
Interconnected VoIP providers are significantly affected by these rules and must take particular note of the following:
- Compulsory Reporting: Compliance is mandatory during FCC-declared emergencies. This marks a shift from the previous voluntary framework.
- Enhanced Preparedness: VoIP providers must ensure their systems can support the collection and submission of DIRS data quickly and accurately.
- Regulatory Risks: Noncompliance can result in enforcement actions, including monetary penalties, making it critical for VoIP providers to prioritize adherence to the rules.
Triggers for Compliance
Interconnected VoIP providers must submit DIRS reports when the following conditions are met:
- DIRS Activation by the FCC: Reporting is required when the FCC activates DIRS in response to a declared emergency, such as hurricanes, wildfires, or other disasters.
- Service Disruptions: Providers must report significant service outages, including degraded quality or interruptions affecting end users.
- Geographic Scope: Reporting obligations apply to providers operating in regions specified by the FCC during the DIRS activation.
- Restoration Efforts: Providers must update the FCC on their progress in restoring services and network functionality during the disaster recovery phase.
Compliance Deadlines
- Effective Date: January 21, 2025
- Compliance Date: February 20, 2025
Preparing for Compliance
Providers should take the following steps to ensure readiness:
- Review the FCC’s Report and Order to understand the specific requirements.
- Develop or update internal protocols to streamline DIRS reporting during emergencies.
- Train staff on DIRS processes and reporting obligations.
- Verify that technical systems are equipped to gather and submit the required data.
Noncompliance can lead to enforcement actions, including fines and penalties. Providers are encouraged to act promptly to meet the upcoming deadlines.
If you have questions about these new rules or need assistance preparing for compliance, please contact the attorney assigned to your account for guidance or, in the alternative, you may contact Michael Donahue at mpd@commlawgroup.com.
