FCC Fact Sheet & NPRM on Knowledge of Customers and Numbering Abuse

Proceeding: Combatting Illegal Robocalls Through FCC Numbering Policies

‍Dockets: WC 26‑49, WC 20‑67, WC 13‑97, WC 07‑243

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On March 5, 2026, the FCC released a Notice of Proposed Rulemaking (NPRM) proposing changes to its numbering and robocall mitigation framework, with a renewed focus on enforcing “knowledge of customers” obligations under Section 6(a) of the TRACED Act. The Commission proposed extending robocall certification, customer due diligence, and accountability requirements beyond interconnected VoIP providers to all entities with direct access to numbering resources, including resellers and numbering intermediaries.

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The NPRM seeks comment on how the FCC can better identify the true parties in interest behind telephone number use, limit masking created by multi‑layer number resale arrangements, and prevent abusive practices such as number cycling. These proposals reflect the FCC’s finding that insufficient customer knowledge at the numbering level continues to enable large‑scale illegal robocalling.

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KYC Relevance

Key FCC actions in this item include:

• Proposing to extend robocall certification and customer knowledge requirements to all providers with direct access to numbering resources, including resellers.
• Seeking comment on whether current practices adequately identify the true parties in interest behind calling traffic.
• Exploring changes to numbering utilization and customer reporting to improve enforcement visibility and accountability.

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This is the first new FCC numbering NPRM in several years to directly revisit TRACED Act Section 6(a) “knowledge of customers” authority in a comprehensive way.

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Numeracle's Stance

In response to the policy gap identified in this NPRM, Numeracle submitted an ex parte filing following a March 23, 2026 meeting with FCC Chairman Brendan Carr, placed into the same core robocall and call authentication dockets. In that filing, Numeracle argued that existing knowledge‑of‑customer obligations are ineffective without mandatory, standardized verification of the legal entity behind calling activity, not just reporting on number utilization or reseller relationships.

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Numeracle urged the Commission to treat verified caller identity grounded in KYC as a prerequisite to numbering access and continued interconnection, asserting that numbering policy reforms will not succeed unless they require independent verification of who is using numbering resources and for what purpose. The filing positioned verified identity and KYC as the operational mechanism needed to fulfill the FCC’s stated goals in WC 26‑49, rather than relying on disclosures or certifications alone.