In the May 8, 2025 edition of the ICORE Blog, we discussed the FCC’s April 28, 2025 Notice of Proposed Rulemaking (NPRM) addressing Caller-ID authentication related to non-IP networks. In the 2018 TRACED Act Congress established a June 2021 deadline for carriers to take reasonable measures to implement an authentication framework that could work for non-IP calls. Congress, however, directed the Commission to grant a delay of this compliance date if effective solutions for non-IP networks were not available. The non-IP compliance date has been delayed for the past four years. In this NPRM, the Commission seeks comments on the availability of effective non-IP caller-ID authentication frameworks and the proposal to repeal the continuing extension from caller-ID authentication requirements for providers that rely on non-IP technology. Further, the NPRM seeks comment on requiring non-IP network providers to implement one or more non-IP authentication frameworks within two years of the effective date of the requiring rules and certify as such in their Robocall Mitigation Database filings. Comments and Reply Comments have now been filed in this proceeding.
In its comments, NTCA states that the TRACED Act did not propose or support a permanent or long- term waiver of the Act’s authentication standards and that effective non-IP caller-ID authentication frameworks are currently available. Further, NTCA proposes that the Commission should repeal the continuing extension from call authentication obligations for non-IP network providers and require such providers to upgrade their networks to IP technology or implement one or more non-IP caller-ID authentication solutions within a reasonable period of time (18 or 24 months). NTCA further urges the Commission to consider what measures it can take to clarify or eliminate rules that serve as impediments to the transition to IP technology. In addition, NTCA suggests that the Commission address concerns that the transition to IP networks will result in changes to interconnection arrangements that could significantly increase interconnection costs for small providers and thereby threaten the provision of universal service in RLEC markets.
USTelecom in its comments submits that the non-IP caller-ID frameworks proposed in the NPRM fall short of protecting consumers from unlawful robocalls, fail to meet the TRACED Act requirements, and the Commission should not require non-IP providers to implement these solutions by a date certain. Further, doing so would hinder the technological evolution to modern IP networks. USTelecom opines that the Commission should not adopt an ineffective, impractical, and costly non-IP authentication mandate that forces providers to transition to IP by a date certain. Instead, USTelecom offers that the marketplace is well on the way to delivering solutions that will protect consumers while continuing to encourage the transition to IP networks and avoid unnecessary and wasteful expenditures. The comments specifically mention IP-based voice services (IPVS) that USTelecom describes as an available and cost-effective alternative. USTelecom concludes that providers are making great strides in the IP transition and the Commission should not require the implementation of ineffective solutions on increasingly obsolete technologies.
In Reply Comments, WTA/Advocates for Rural Broadband supports the repeal of the statutory non-IP caller-ID authentication deferral and the proposed two-year period for companies to either transition to IP technologies or adopt one of the non-IP frameworks specified in the NPRM. WTA, however, proposes that the Commission should provide for waivers of the new two-year deadline for small and rural providers upon a demonstration of good cause.
The above is a summary of some of the comments filed in this proceeding and it’s clear that significant differences of opinion exist among the interested parties to this issue. We will continue to follow this issue and will provide updates as more information becomes available.
