As per our last advisory issued on September 23, 2025, the FCC’s new rule requiring all voice service providers (“VSPs”) to block suspicious calls based on a reasonable do-not-originate (“DNO”) list will become effective on December 15, 2025.
We write to remind you that the compliance deadline is now less than five weeks away. The rule, codified in 47 C.F.R. 64.1200(o), extends the existing obligation requiring gateway and messaging providers to block calls likely to be illegal based on a “reasonable DNO” to all VSPs.
The new rule requires each VSP to prepare its own “provider-selected” DNO list. The FCC declined to define the precise scope of a reasonable DNO but indicated that such a list could include “only invalid, unallocated, and unused numbers, as well as numbers for which the subscriber has requested blocking.” Critically, the FCC cautioned that it may “deem unreasonable a list so limited in scope that it leaves out obvious numbers that could be included with little effort.”
Additionally, the FCC will require VSPs to “constantly update DNO lists, especially if they include unused numbers that could go into use at any time.” The Commission has acknowledged that smaller VSPs may utilize a less extensive DNO list than larger carriers, particularly in situations where other VSPs in the call chain provide blocking functionality.
With the December 15, 2025 compliance date now imminent, VSPs should take immediate steps to ensure their DNO procedures are finalized, tested, and operational.
The CommLaw Group Can Help!
The CommLaw Group remains available to advise on best practices for robocall mitigation and STIR/SHAKEN compliance. Given the pressing compliance deadline and the complexity of the FCC’s evolving robocall mitigation rules, it is critical that VSPs move expeditiously to ensure full compliance. Accordingly, if you have not yet engaged counsel on your DNO implementation strategy or would like additional guidance tailored to the specific needs of your company, please contact one of our attorneys below without delay.
CONTACT US NOW, WE ARE STANDING BY TO GUIDE YOUR COMPANY’S COMPLIANCE EFFORTS
Michael Donahue — Tel: 703-714-1319 / E-mail: mpd@CommLawGroup.com
Susan Duarte – Tel: 703-714-1300 / E-mail: sfd@CommLawGroup.com
Rob Jackson – Tel: 703-714-1316 / E-mail: rhj@CommLawGroup.com
Ron Quirk – Tel: 703-714-1305 / E-mail: req@CommLawGroup.com
Diana James – Tel: 703-663-6757 / E-mail: daj@CommLawGroup.com