TL;DR – Robocall Mitigation Requirements
All voice service providers must implement an appropriate robocall mitigation program, including reasonable steps to avoid originating illegal robocalls and a commitment to respond within 24 hours to traceback requests.
RMD filing is required (including certifications and mitigation plans), and FCC guidance has emphasized that providers must refuse traffic from providers not listed in the Robocall Mitigation Database, with compliance tied to set dates.
STIR/SHAKEN duties apply based on your role: voice service providers, intermediate providers, and gateway providers have defined authentication obligations and timelines.
Third-party authentication rules became effective September 18, 2025, and include explicit requirements such as obtaining an SPC token and signing with the provider’s own certificate (plus recordkeeping).
Noncompliance can lead to removal from the RMD, and downstream providers may be required to stop accepting traffic directly from removed entities within a short window.
Viirtue’s guidance for PSTN resellers: Viirtue signs calls on its network for its reseller model, and partners still file in the RMD but may file as a provider without a STIR/SHAKEN implementation obligation, depending on their situation and infrastructure control.
Robocalling Mitigation: What Service Providers Must Do and How Viirtue Helps MSP Partners
“Robocalling mitigation” is not just a best practice. For many providers, it is a set of FCC rule-based obligations that combine:
caller ID authentication (STIR/SHAKEN)
a documented robocall mitigation program
filing and maintaining a certification in the FCC Robocall Mitigation Database (RMD)
responding fast to traceback requests
and refusing traffic from non-compliant providers
If you are a service provider or you are an MSP reselling PSTN and voice, the operational question is simple:
How do you stay compliant without turning compliance into your business model?
This guide breaks down the requirements and provides a practical checklist.
1) Who is responsible for robocalling mitigation?
FCC rules and guidance discuss different roles in the call path, including:
Voice service providers (originate calls to end users)
Intermediate providers (carry or process traffic between providers)
Gateway providers (handle certain traffic entering the U.S. network path, including caller ID concerns tied to NANP resources)
The requirements vary slightly by role, but the theme is consistent: every provider has obligations, and the RMD is used as a gating mechanism for who can exchange traffic.
2) The core robocalling mitigation requirement: you must run a real program
Under 47 CFR § 64.6305, providers must implement an appropriate robocall mitigation program. In plain terms, that includes:
reasonable steps to avoid illegal robocalls (originating, carrying, or processing, depending on role)
a commitment to respond within 24 hours to traceback requests from the Commission, law enforcement, and the industry traceback consortium
cooperation to investigate and stop illegal robocallers
The rule also gets specific about what must be included in certifications, including descriptions of KYC, upstream provider procedures, analytics systems, and disclosures of certain enforcement actions or investigations within the prior two years.
3) Robocall Mitigation Database: filing is mandatory, and traffic gating is real
The FCC’s RMD framework is not a “nice to have.” It is designed to ensure providers:
certify their mitigation posture
keep filings current
and enable downstream providers to decide whether to accept traffic
FCC Bureau guidance has spelled out compliance dates and instructions, and emphasized that providers must refuse to carry traffic from providers not listed in the RMD as of specified compliance dates.
Also important for operations: the rules require providers to update filings within 10 business days of changes to required information.
4) STIR/SHAKEN: authentication duties based on provider role
Voice service providers: authenticate what you originate
Under 47 CFR § 64.6301, a voice service provider generally must implement STIR/SHAKEN in its IP networks and:
authenticate and verify the caller ID for SIP calls that exclusively transit its network
authenticate caller ID for SIP calls it originates and transmits downstream (to the extent technically feasible)
verify caller ID for authenticated SIP calls it receives and terminates (Legal Information Institute)
Intermediate and gateway providers: authenticate certain unauthenticated traffic
Under 47 CFR § 64.6302, intermediate and gateway providers have obligations to implement STIR/SHAKEN, and the rule includes specific requirements for gateway providers and non-gateway intermediate providers to authenticate certain unauthenticated calls by particular deadlines (subject to extensions).
5) Third-party STIR/SHAKEN signing changed in 2025
A major operational shift for many providers: the FCC published rules (effective September 18, 2025) that authorize third-party authentication arrangements but add guardrails intended to prevent accountability gaps. (Federal Register)
The Federal Register summary states these rules include explicit requirements for providers with a STIR/SHAKEN implementation obligation to obtain an SPC token and digital certificate, and it includes recordkeeping requirements for third-party authentication arrangements.
Separately, FCC Bureau materials around extensions reinforce that if a provider claims it does not have an obligation to implement STIR/SHAKEN due to an extension, it must clearly identify the rule and explain why the exemption applies in its RMD filing.
6) What happens if you ignore this: removal and downstream blocking
Enforcement is not theoretical. FCC orders have removed providers from the Robocall Mitigation Database for deficient certifications, and the orders can require intermediate providers and voice service providers to cease accepting traffic directly from removed companies within two business days of the order’s release.
That is why “we’ll get to compliance later” becomes an availability and revenue risk.
7) Practical robocalling mitigation checklist for service providers
Use this as an internal SOP outline.
A. Identify your role(s)
Are you originating calls as a voice service provider?
Are you acting as an intermediate provider?
Are you functioning as a gateway provider?
Your obligations stack if you play multiple roles.
B. Build your robocall mitigation program
Document reasonable steps to prevent illegal robocalls
Document KYC and upstream provider vetting procedures
Choose analytics and blocking mechanisms
Create a 24-hour traceback response process with named owners
C. File and maintain your RMD certification
Update within 10 business days of changes
D. Implement authentication obligations as applicable
Confirm your STIR/SHAKEN requirements and technical path
E. Operationalize traffic acceptance rules
Ensure you are not accepting direct traffic from entities that are not properly listed in the RMD (and monitor updates)
8) How Viirtue helps partners
For MSPs and resellers, the biggest challenge is that compliance tasks can require heavy infrastructure, specialized telecom operations, and ongoing monitoring.
Viirtue’s positioning for its reseller model is that:
Viirtue signs calls on its network, reducing the infrastructure lift for PSTN resellers, while
partners still maintain their own RMD filing and mitigation plan, and may file as a provider without a STIR/SHAKEN implementation obligation depending on their specific facts (especially whether they control the network infrastructure needed to implement STIR/SHAKEN).
Separately, Viirtue’s partner platform and ViiBE positioning emphasize an integrated operational foundation (quote-to-cash, automated billing, and tax compliance workflows) designed for MSPs and channel partners. (Viirtue)
If you want to build recurring voice revenue, the goal is to make compliance a managed workflow, not an emergency.
Final Thoughts: Robocall Mitigation Is an Operational Reality, Not Optional
Robocall mitigation is no longer a policy exercise or a box to check once and forget. For service providers and MSPs reselling PSTN and voice, it directly impacts whether your traffic is accepted, whether your service stays live, and whether revenue keeps flowing.
The providers that succeed are the ones who treat compliance as an operational workflow with clear ownership, documented processes, and infrastructure support.
Viirtue is built to help MSP partners do exactly that—signing calls on its network, simplifying the compliance burden, and allowing partners to focus on growing a sustainable voice business instead of chasing regulatory fire drills.
FAQ: Robocall Mitigation
What is robocalling mitigation?
Robocalling mitigation is the set of policies, technical controls, and response procedures providers implement to prevent illegal robocalls, including authentication (where required), mitigation programs, traceback responsiveness, and database certifications. (Legal Information Institute)
Do providers have to respond to traceback requests quickly?
Yes. FCC rules require a commitment to respond within 24 hours to traceback requests (for voice service providers and intermediate providers, with parallel requirements depending on role). (Legal Information Institute)
Do I still need an RMD filing if STIR/SHAKEN is implemented?
The rules and FCC guidance framework require RMD certifications and mitigation plans, and filings must remain current.
What changed with third-party STIR/SHAKEN signing?
Rules effective September 18, 2025 allow third-party signing arrangements but impose requirements intended to preserve provider accountability, including SPC token and certificate expectations and recordkeeping. (Federal Register)
What is the risk of being removed from the Robocall Mitigation Database?
Removal can trigger downstream obligations for other providers to stop accepting traffic directly from the removed provider within a short period, which can effectively disrupt traffic exchange.
