Nearly a year after adopting stricter Robocall Mitigation Database (RMD) rules, the Federal Communications Commission (FCC) published them in the Federal Register on January 6. Key provisions take effect in 30 days.
Rules Effective February 5, 2026:
The following higher base fines will apply on a continuing violation basis:
- $10,000 for submitting false or inaccurate information in the RMD.
- $1,000 for failing to update RMD information within 10 days of a change.
Rules Pending Future Implementation
1. Annual re-certification of the accuracy of RMD submissions will be required by March 1 each year.
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- This rule will become effective after review by the U.S. Office of Management and Budget (OMB).
2. A $100 initial RMD filing and annual RMD recertification fees will apply once effective.
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- Minor changes to the RMD filing will not require a filing fee.
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- Under the red-light rule, the Commission will not process RMD filings by parties that owe non-tax debt to the Commission.
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- This rule will become effective after the requisite notice is provided to Congress, the FCC’s information technology systems and internal procedures are updated, and the Commission publishes a notice in the Federal Register announcing the effective date of this rule.
3. Entities will be required to update information submitted to CORES (name, entity type, contact name and title, address, email address, and taxpayer identifying number) within 10 days of any change.
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- This rule will become effective after OMB review.
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- Note: providers must already update their RMD filings (including the STIR/SHAKEN certification and robocall mitigation plan) within 10 business days of any change.
Upcoming Reforms
The FCC’s 2025 Report and Order on stricter RMD filing requirements, directed the Wireline Competition Bureau to implement several measures to improve the RMD’s reliability and security. The following reforms are pending adoption:
- Establishing a dedicated mechanism for the public to report deficient RMD filings.
- Issuing additional guidance and “best practices” for filers.
- Implementing two-factor authentication protocols for RMD access.
Current Robocall Mitigation Enforcement Background
Throughout 2025, the FCC’s Enforcement Bureau heightened scrutiny of RMD compliance. The Bureau removed 1,388 non-compliant voice service providers from the RMD for false, misleading, or outdated RMD filings in August alone.
Common violations included failure to disclose use of non-STIR/SHAKEN traffic, inconsistent mitigation descriptions, and submission of outdated contact information. These actions underscore the FCC’s shift toward holding filers accountable and treating inaccurate data as a material compliance failure.
Conclusion
These new rules mark a significant tightening of the FCC’s robocall mitigation compliance regime. Providers should:
- Review and confirm the accuracy of existing RMD and CORES filings.
- Implement internal compliance controls to meet new update and certification timelines when they become effective.
- Monitor FCC releases for effective date announcements and further guidance.
Our firm is available to assist clients in evaluating compliance readiness and preparing for the February 5 effective date and subsequent rule phases.
NEED HELP WITH ROBOCALL MITIGATION, COMPLIANCE AND LITIGATION SUPPORT/DEFENSE AGAINST BUSINESS & LEGAL CHALLENGES?
The CommLaw Group Can Help!
The CommLaw Group remains available to advise on best practices for robocall mitigation and STIR/SHAKEN compliance. Given the heightened fines for inaccurate RMD filings and the FCC’s enforcement vigilance, it is critical that VSPs move expeditiously to ensure full compliance. Accordingly, if you have not yet engaged counsel on your robocall mitigation 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: 703-714-1318 / 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