On April 28, 2025 the FCC adopted a Notice of Proposed Rulemaking (NPRM) to address continued problems from illegal robocalls specifically related to non-IP networks. The NPRM discusses the Commission’s previous efforts to address illegal robocalls including requiring providers, as directed by Congress in the TRACED Act, to implement the STIR/SHAKEN caller-ID authentication framework. The STIR/SHAKEN framework allows providers to verify that a caller’s number matches the caller-ID information transmitted with a call which enables providers to identify and block illegal robocalls. STIR/SHAKEN, however, is only effective on calls that travel exclusively over IP networks. STIR/SHAKEN is not effective if any part of the call path path passes through non-IP technology.
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, however, Congress directed the Commission to grant a delay of this compliance date if effective solutions for non-IP networks were not readily available. The non-IP network compliance date has been delayed for the past four years and the Commission looks to address the issue via the NPRM. In the NPRM the Commission begins the process of evaluating whether there are effective authentication frameworks available today for non-IP networks that meet the criteria established by the TRACED Act and whether providers must implement such frameworks in their non-IP networks. Specifically, the NPRM proposes the following:
* To establish criteria to evaluate whether non-IP caller-ID authentication frameworks are reasonably available and effective as required by the TRACED Act.
* To conclude that frameworks based on two existing non-IP authentication standards meet the TRACED Act’s requirements and to seek comment on a third framework.
* To repeal the continuing extension from caller-ID authentication requirements for providers that rely on non-IP technology.
* To require that voice service providers, gateway providers, and non-gateway intermediate providers implement non-IP caller-ID authentication frameworks in their non-IP networks and certify as such in their Robocall Mitigation Database filings.
* To give non-IP network providers two years from the effective date of the rules to implement one or more non-IP caller-ID authentication frameworks and to seek comment on how the proposed two year compliance timeline relates to providers’ efforts to transition to IP technology.
In a Statement accompanying the NPRM, FCC Chairman Carr described the Commission’s efforts to crack down on illegal robocalls as like a game of whack-a-mole where as one challenge is addressed another one pops up. He further stated his belief that it is appropriate for the Commission to look at requiring even the non-IP components of networks to meet the standards of the TRACED Act and that there is much more that the FCC can and should be doing to accelerate the transition to IP networks.
Comments on the NPRM are due 30 days after publication in the Federal Register. Reply comments are due 60 days after Federal register publication. We will continue to follow this issue and will provide updates as more information becomes available.
