FCC Enforcement Advisory on RMD Compliance

Beginning September 28, 2021, carriers were prohibited from accepting direct traffic from voice providers not listed in the Robocall Mitigation Database, as established under enforcement guidance from the Federal Communications Commission and implementation requirements associated with FCC 21-122. This operational rule effectively transformed RMD participation into a functional interconnection prerequisite rather than a voluntary compliance disclosure.

The enforcement advisory issued by the agency emphasized that certification alone is insufficient. Providers must maintain verifiable mitigation practices supported by accurate, operationally grounded documentation of customer traffic behavior and network oversight. Failure to properly certify or sustain compliant mitigation programs could result in enforcement action, including removal from interconnection pathways.

The directory-based nature of the RMD further reinforced ecosystem transparency. Filings are publicly searchable and downloadable, enabling peer visibility into provider commitments and creating a form of market-enforced accountability across the voice supply chain.

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KYC Relevance

Because interconnection eligibility is contingent on RMD certification status, identity governance becomes a prerequisite for network participation rather than a discretionary risk control measure. Mitigation programs must therefore be supported by customer verification practices that are sufficiently robust to sustain regulatory and partner scrutiny.

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Numeracle’s Perspective

Organizations should explicitly map RMD commitments to named KYC control mechanisms, including onboarding verification, number right-to-use validation, and risk-based customer review workflows. Mitigation plans should reflect actual on-net behavior and be operationally traceable so that interconnection partners can have confidence in the integrity of the certification.