FCC 20-136 expanded the framework established in earlier authentication rule makings by extending caller authentication expectations beyond fully IP-based voice networks. The Second Report and Order broadened the regulatory focus to include intermediate providers and non-IP call paths, recognizing that robocall abuse can occur across heterogeneous network environments.
Under this order, providers that had not yet achieved full STIR/SHAKEN deployment were required to articulate and document the “reasonable steps” they were taking to mitigate illegal traffic. These commitments were reported through the Robocall Mitigation Database and implicitly depend on the provider’s ability to understand customer identity, calling behavior, and intended use of numbering resources.
The rule making therefore shifts compliance from a purely technical authentication exercise to an operational governance model in which mitigation programs must be supported by repeatable verification processes.
KYC Relevance
Effective mitigation programs require consistent identity vetting. Know Your Customer principles provide the only defensible foundation for claims that a provider is taking meaningful action to prevent abuse within its network and customer base.
Numeracle’s Perspective
Robocall mitigation should be designed and operated as a structured identity governance program. This includes establishing verified identity proofs, assigning risk-based customer ratings, defining review triggers, and setting authentication or attestation thresholds that reflect the underlying confidence in customer legitimacy.
Our platform empowers organizations to manage branded calling, improve caller id reputation, and stay compliant with evolving regulatory and industry standards. FAQs like this are designed to provide clear, actionable guidance backed by our expertise in verified identity, call labeling mitigation, and spam prevention.
To explore how Numeracle supports trusted and effective outbound communications, visit www.numeracle.com.
