FCC Seeks Comment on Consumer-Facing Robocall Mitigation Scorecard

The Federal Communications Commission’s (“FCC,” “Commission”) Consumer and Governmental Affairs Bureau has issued a Public Notice seeking comment on the establishment and publication of a consumer-facing Robocall Mitigation Scorecard (“Scorecard”). The proposed Scorecard would assess how effectively voice service providers protect customers from illegal robocalls and is intended to help consumers compare providers when selecting service. Comments are due September 22, 2026, with reply comments due October 2, 2026.

Proposed scope and purpose

The FCC proposes initially rating domestic voice service providers that serve retail customers, including wireless, wireline, VoIP, and hybrid-network providers. The Commission proposes excluding entities that operate solely as wholesale or intermediate providers, such as certain gateway and non-gateway intermediate providers that do not bill end-user customers directly. Rather than rate every retail provider, the FCC is considering an approach that would cover providers representing most of the retail market, potentially based on subscriber counts or Form 477 data.

The agency emphasizes that the Scorecard would not determine whether a provider is in compliance with FCC robocall rules. Nonetheless, a public rating could materially affect customer perceptions, competitive positioning, and provider decisions concerning call-labeling, blocking, traceback response, complaint-handling, and data-governance practices.

Potential scorecard criteria

The FCC is considering a composite framework that includes both provider conduct and measurable consumer outcomes:

A key issue for commenters is how the FCC should normalize and validate these data sources. The Public Notice recognizes that complaint volumes, blocking levels, and third-party analytics may not be directly comparable across providers and may reflect factors beyond a terminating provider’s control. It also specifically asks how the Scorecard should account for erroneous blocking of legitimate calls.

Key issues for providers

Retail voice providers (and entities whose data or practices may inform retail-provider ratings) should consider whether to comment on the following issues:

• Provider selection and comparability. The FCC seeks input on whether small and regional providers should be excluded or treated differently in light of differences in scale, traffic patterns, resources, and data availability.
• Data integrity and auditability. The Commission asks whether provider data, third-party analytics, complaint records, traceback information, and enforcement actions are sufficiently complete, reliable, unbiased, and comparable to support public ratings.
• Metric design and weighting. The FCC seeks comment on how to balance conduct-based measures against outcome-based measures; whether to use qualitative and quantitative measures; and how to adjust for provider size.
• False positives and redress. Providers should focus on the proposed treatment of erroneous blocking, including the data sources used to measure blocking accuracy and processes for notifying callers, resolving disputed blocks, and handling error complaints.
• Public presentation and procedural safeguards. The FCC is considering a single composite score, individual metric displays, letter grades, numerical scales, or tiered ratings. It also seeks comment on pre-publication review, post-publication correction procedures, and update frequency.
• Accessibility and language access. The agency seeks input on accessibility for individuals with disabilities and whether the Scorecard should be offered in languages other than English.

Recommended next steps

Providers that may be within the eventual rating population should promptly assess the completeness and consistency of their robocall-mitigation records, including RMD filings, traceback-response processes, consumer tool disclosures, blocking and labeling practices, complaint-escalation procedures, and mechanisms for identifying and correcting false positives.

Interested parties should also consider filing comments on:

• objective provider-selection criteria;
• transparent, normalized, and independently verifiable metrics;
• appropriate limitations and contextual disclosures for complaint, enforcement, and third-party data;
• provider notice and correction rights before public dissemination; and
• safeguards against a consumer-facing score being misconstrued as a legal compliance determination. The proceeding is “permit but disclose,” subject to specified limited exemptions for certain pre-release technical discussions initiated by Bureau staff.

The proposed Scorecard is not itself a new regulatory mandate. However, it may establish a consequential public benchmark for robocall-mitigation performance and could influence provider practices well before any future Commission rulemaking.

The CommLaw Group Can Help!

Comments are due September 22, 2026, with reply comments due October 2, 2026.

CommLaw Group’s Robocall Mitigation Response Team is available to assist providers with evaluating the Public Notice, preparing comments, reviewing and updating RMD filings, assessing STIR/SHAKEN implementation and exemption claims, strengthening robocall mitigation plans, and developing compliant KYC, KYUP, traceback, and third-party oversight procedures.

Providers that are uncertain whether their current RMD filings accurately reflect their corporate structure, services, call-path roles, numbering arrangements, authentication practices, or mitigation procedures should consider conducting a privileged compliance review.

Jonathan Marashlian | jsm@commlawgroup.com
Diana James | daj@commlawgroup.com