In the February 18, 2025 edition of the ICORE Blog we discussed the FCC’s December 30, 2024 Report and Order (Order) establishing new rules related to Robocall Mitigation Database (RMD) filing requirements. The Order created specific requirements for the filing of updates to RMD information and also addressed the filing of false or inaccurate information. Financial penalties will apply to late submissions of RMD updates and to the submission of false or inaccurate RMD information. In addition, the Order required providers to recertify their information in the RMD annually by March 1 of each year and established an annual filing fee of $100 that will apply to the recertification filings. The Order also required the Wireline Competition Bureau (WCB) to update the FCC’s information technology systems and internal procedures to ensure efficient and effective implementation.
The Order was published in the Federal Register on January 6, 2026 and as such certain of the new rules are effective as of February 5, 2026 while certain other provisions of the Order require OMB or Congressional approval and will become effective at a later date. Please note the following:
- Providers are required to update their information in the RMD within 10 business days of any change to relevant information. This requirement is subject to OMB approval and will become effective at a later date. The Order establishes a penalty for failure to update information on a timely basis. Failure to update information will result in a $1000 penalty assessed on a daily basis until the violation is cured (up to the statutory maximum for continuing violations). The Commission will publish notice in the Federal Register announcing the effective date for the 10-business day filing requirement after OMB approval.
- Effective 2/5/26, the submission of false or inaccurate information to the RMD will result in a $10,000 penalty assessed on a daily basis until the violation is cured (up to the statutory maximum for continuing violations).
- The requirement to recertify information in the RMD requires OMB approval and therefore will become effective at a later date. In addition, the establishment of the $100 filing fee applicable to recertification filings requires notice to Congress and updates to the FCC’s information technology systems. Again, the Commission will publish notice in the Federal Register regarding the effective date for this requirement.
The Order directs the WCB to establish a dedicated reporting mechanism for deficient filings that would provide a channel for state and local regulators and other interested parties to notify the Commission of suspected problems related to the RMD. In addition, the WCB is instructed to assist providers with their RMD compliance through the issuance of additional guidance, educational materials, and “best practices” for filing in the RMD. To improve the security of the RMD, the WCB is directed to develop a two-factor (or more) authentication process for accessing the RMD.
As discussed above, many important provisions of the Order require OMB approval or notice to Congress before becoming effective. We believe that OMB approval will likely occur in the near term and therefore providers would be well advised to review their internal procedures to ensure compliance with the requirements discussed above. We will continue to monitor this issue and will provide updates as more information becomes available.
