On February 20, 2026, the FCC’s Enforcement Bureau released Enforcement Advisory No. 2026-02 (DA 26-174), underscoring that Mobile Virtual Network Operators (MVNOs) are fully subject to the Commission’s Robocall Mitigation Database (RMD) and related robocall compliance obligations.
The Advisory serves as a pointed reminder that MVNOs offering voice services—despite not owning underlying transmission facilities—are considered “voice service providers” under the FCC’s rules and must independently comply with robocall mitigation requirements.
Who Is Affected
The Advisory applies to MVNOs and other resellers providing interconnected voice services. The FCC makes clear that these providers may not rely solely on underlying carriers for compliance. Independent obligations apply.
Key Compliance Requirements
The Enforcement Bureau reiterated that covered providers must:
- File and maintain an accurate certification in the Robocall Mitigation Database.
- Describe their STIR/SHAKEN implementation status and/or robocall mitigation program.
- Maintain and implement a robocall mitigation plan, including meaningful Know-Your-Customer (KYC) procedures.
- Respond to traceback requests from the FCC, law enforcement, and the designated traceback consortium within 24 hours.
- Recertify their RMD filings annually (with the next recertification deadline approaching March 1, 2026).
The Bureau emphasized that inaccurate filings, failure to file, or failure to respond to traceback requests may result in removal from the RMD, blocking by downstream providers, monetary forfeitures, and additional enforcement action.
Practical Considerations
MVNOs should review their compliance posture promptly. In our experience, risk often arises not from the absence of policies on paper, but from weaknesses in KYC diligence, traffic monitoring, vendor oversight, numbering authorization, VoIP waiver compliance, and documentation supporting mitigation decisions.
Given the increasingly aggressive enforcement environment, providers should also anticipate heightened scrutiny from state attorneys general, consumer protection authorities, and private litigants.
Need Help with Robocall Mitigation, Compliance, or Litigation Support?
The CommLaw Group Can Help!
Given the complexity and evolving nature of the FCC’s rules, industry frameworks, and private-sector governance surrounding Robocall Mitigation—including STIR/SHAKEN, the TRACED Act, FCC regulations, ATIS and USTelecom initiatives, NECA guidance, VoIP numbering waivers, Know-Your-Customer obligations, and the broader telecom compliance ecosystem—providers face significant regulatory and business risk.
In addition to FCC enforcement exposure, companies are seeing increased business disputes, state enforcement investigations, and civil litigation tied to robocall and traffic origination practices.
To address these challenges, The CommLaw Group has formed a Robocall Mitigation Response Team to assist clients—both existing and new—in proactively structuring compliance programs, responding to traceback requests, defending enforcement inquiries, and navigating business and legal disputes.
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: 703-714-1318 / 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
If you have questions about your Robocall Mitigation Database filing, traceback response obligations, or broader robocall compliance strategy, please contact us to discuss your specific situation.