FCC Know Your Upstream Provider (KYUP) Proposed FNPRM

On May 20,2026, the FCC released a Notice of Proposed Rulemaking proposing enhanced Know Your Upstream Provider (KYUP) requirements as part of its continued effort to combat illegal robocalls at every point in the call path.

The proposal builds on prior KYC initiatives by targeting gaps in provider‑to‑provider accountability, where insufficient vetting of upstream partners allows bad actors to persist in the voice ecosystem. The FCC also proposes enhancements to the STIR/SHAKEN framework to strengthen caller authentication and close implementation loopholes that undermine trust in caller identity.

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KYC Relevance

The KYUP proposal represents a significant expansion of KYC principles beyond the originating provider to the full call path. Under the proposed framework, providers would be required to collect and verify information about upstream partners, monitor their traffic and practices, and take action, including refusing or terminating service, when evidence indicates those partners are facilitating illegal calls. This effectively extends identity, due diligence, and accountability requirements across provider relationships, addressing a key enforcement gap where bad actors exploit fragmented oversight.

Key KYC‑related elements include:

• Mandatory vetting and verification of upstream providers, not just end customers
• Ongoing monitoring of upstream traffic patterns and behavior
• Requirement to take corrective action or terminate access for high‑risk or non‑compliant partners
• Strengthening STIR/SHAKEN attestation standards to improve trust in caller identity
• Expanded due diligence expectations tied to participation in the voice ecosystem

Together, these measures signal that responsibility for preventing illegal calls is no longer confined to origination but must extend across all entities that enable call transmission.

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Numeracle’s Stance

Numeracle strongly supports the FCC’s move to extend KYC principles upstream through KYUP requirements. Expanding accountability across provider relationships is a necessary step to close systemic gaps that allow illegal traffic to persist despite originating‑level controls.

It is encouraging to see this continued progress following recent engagement between Numeracle and Chairman Carr, and it closely aligns with principles Numeracle has consistently advocated for: verified identity, accountability at every layer of the call path, and suitability as a condition of network access.

Numeracle supports adoption of KYUP as a critical complement to originating provider KYC, reinforcing that trust in communications depends on knowing not only the customer, but also the providers that enable traffic to flow.