Robocall Mitigation Database: The FCC Plan and Who Files

November 12, 2026. Reply comments on the FCC's plan to overhaul the Robocall Mitigation Database were due on November 9, and 49 state and territorial attorneys general sent comments dated that day asking the agency to verify filings before they go live and to make it harder for removed providers to return. A listing in the database is a precondition for your provider's calls to be accepted: under 47 CFR 64.6305(g)(1), U.S. voice service providers and intermediate providers may accept calls directly from a domestic voice service provider only if its filing appears in the database and has not been de-listed in an enforcement action. If you run outbound or AI calling, or sell calling to clients under your own brand, the provider behind your numbers could face stricter vetting if the FCC adopts these proposals, and its listing is something you can check yourself today.

What happened between July and November

1. The FCC proposed the overhaul on July 22, 2026. The Further Notice of Proposed Rulemaking in WC Docket No. 24-213 was published in the Federal Register on September 9, with comments due October 9 and reply comments due November 9, 2026.
2. 49 attorneys general sent reply comments. The filing is dated November 9 and the National Association of Attorneys General announced it on November 10. It was co-sponsored by the attorneys general of Colorado, Illinois, Indiana, North Carolina, Ohio and Pennsylvania and joined by 43 more, including the District of Columbia, American Samoa and the U.S. Virgin Islands.
3. They asked for vetting before listing. NAAG's release says the group wants the FCC to "Verify provider information before allowing filings to appear in the RMD" and to "Make it more difficult for bad actors to reenter the database after being suspended or removed."
4. They backed a money test. The 34-page reply comments support "mandating verifiable evidence of solvency before providers' filings are published in the RMD", noting that the FCC floated a letter of credit and mentioned surety bonds as an alternative.
5. Local press picked it up. The Whig reported on November 11 that the attorneys general say bad actors can currently get into the database "and stay there with minimal effort."

What the Robocall Mitigation Database is

The Robocall Mitigation Database, or RMD, is the FCC's public list of phone providers that have filed a description of how they keep illegal robocalls off their networks. NAAG's release puts it plainly: "Voice service providers must submit information about their businesses and robocall mitigation practices to the RMD before routing calls through the U.S. communications network." Each filing's mitigation program must include "a commitment to respond within 24 hours to all traceback requests from the Commission, law enforcement, and the industry traceback consortium," according to the FCC's notice.

A listing is a precondition for other providers to accept a provider's calls directly. The FCC's notice says that "removed providers are effectively prevented from transmitting voice calls on the U.S. voice network," because downstream providers may only accept calls directly from a provider whose filing is listed. The FCC has already set a $10,000 base forfeiture for submitting false or inaccurate information and a $1,000 base forfeiture for failing to update a filing within 10 business days, and it treats both as continuing until cured.

What the FCC proposed in WC Docket 24-213

The notice's summary says the FCC wants to "clarify which entities are required to file in the RMD," make filings more accurate and complete, decide which parts are public, and add "strengthened screening procedures for new filers, improved mechanisms for identifying noncompliant providers, expedited removal processes, and safeguards to prevent unauthorized re-entry into the Database." In our view, these are the pieces most likely to touch a small calling operation:

1. Who counts as a provider. The notice uses a definition that covers initiating, originating, intermediate and terminating providers, "including facilities-based providers and non-facilities-based providers (inclusive of interconnected Voice over internet Protocol (VoIP) resellers and Mobile Virtual Network Operators (MVNOs))", and says the rules would apply to new and existing filings.
2. Named people behind each filing. Providers would report each human principal's title, phone number, email, physical address, country of residence and citizenship. The FCC proposes keeping those contact details private.
3. A letter of credit. The FCC asks whether filers should submit "a standby letter of credit from a bank meeting our capital requirements, along with a bankruptcy opinion of counsel." The notice does not set an amount in the passages we read.
4. Harder to return under a new name. The notice proposes safeguards against unauthorized re-entry and points to filings that list the same address, telephone number, email address, principal, affiliate, subsidiary, parent company, OCN or third-party filing consultant as a provider whose filing was previously removed.

These are proposals. They do not change anyone's obligations unless the FCC adopts final rules and they take effect, and the FCC has not published a date for that vote.

Who files, and where a calling business fits

NAAG's release says voice service providers must file before routing calls, and the database also lists gateway and non-gateway intermediate providers. The FCC is proposing to "clarify which entities are required to file," so who counts is still open. Reselling is where it gets least clear: if your agency sells phone numbers and calling to clients under its own brand, the proposed definition's mention of "interconnected Voice over internet Protocol (VoIP) resellers" is the line we would take to a telecom lawyer before scaling. Agencies that package calling inside a white-label SaaS offer should ask the same question. Whether a specific setup makes you a provider depends on its facts, and the notice is still a proposal.

What it means for teams running AI or outbound calls

Your campaigns already depend on your provider's RMD standing. If a provider is de-listed, other providers may no longer accept its calls directly under section 64.6305(g)(1), so the outbound calls it carries for you would effectively stop being accepted by other networks. In our view, the proposals would raise the cost of being listed (principal disclosures, possibly a letter of credit), which is more likely to squeeze thin, low-cost resellers than large carriers.

The database is one layer among several. TCPA consent rules are a separate question, covered in our 12-point TCPA compliance checklist. Call authentication is another layer, explained in our guide to STIR/SHAKEN attestation, and the FCC's Reassigned Numbers Database is a separate lookup for numbers that changed hands. If you are pricing a branded display name, see our branded caller ID cost breakdown.

How to check your provider in the RMD

1. Open the public listing. The Robocall Mitigation Database needs no login. Its columns include Business Name, FCC Registration Number (FRN), Implementation (which appears to show the provider's STIR/SHAKEN status) and whether it filed as a voice service provider, gateway provider or non-gateway intermediate provider. There is also a Download Database option.
2. Search by legal name, then read the Business Name column. The keyword search also returns other companies' filings that mention the name. When we searched "Twilio" on November 12, the first rows were other companies' filings, not Twilio's own; we did not page further, so this says nothing about Twilio's own listing. Confirm the name and FRN rather than trusting the top result.
3. Ask your vendor for its FRN. If your AI voice platform resells another carrier's service, ask which provider originates your calls and check that one too.
4. Keep a second route ready. We suggest knowing which other provider you would port to, so a removal is less disruptive.

This is general information, not legal advice.

If you are planning outbound AI calls, our page on the consent and opt-out layer under an AI dialer describes what we build there, and our AI calling for home services page covers answering calls and calling web leads back. For platform choices, compare the all-in costs in best AI voice agents in 2026, and see what an AI answering service for HVAC does on the inbound side. If you use local area codes for outbound, read whether local presence dialing is legal first.