The FCC released a Fourth Report and Order on STIR/SHAKEN that shortens the prior extension provided to small voice providers (100,000 or fewer voice service subscriber lines) to implement the STIR/SHAKEN caller ID authentication standards. Specifically, the Order provides that non-facilities-based voice service providers that offer voice services to end-users solely using connections that are not sold by the provider or its affiliates must implement STIR/SHAKEN in the IP portions of their network by June 30, 2022.
Facilities-based providers can still take advantage of the full extension until June 30, 2023, unless they are suspected of originating illegal robocalls.
By a separate Public Notice, the FCC retained three extensions granted in September 2020 for: (1) small voice service providers not affected by the Fourth Report and Order, through June 30, 2023; (2) voice service providers unable to obtain the “token” necessary to participate in STIR/SHAKEN, until they are able to obtain a token; and (3) services scheduled for Section 214 discontinuance, until June 30, 2022.
The two categories of small voice providers that are required to expedite STIR/SHAKEN implementation are:
Non-Facilities Based Providers ‒ Six Months to Implement STIR/SHAKEN
The FCC shortened the timeline from June 30, 2023 to June 30, 2022, based on evidence reflecting that a subset of non-facilities based small voice providers are responsible for generating a high quantity of illegal robocalls compared to facilities-based and larger providers.
“Bad Actors” ‒ 90 Days to Implement STIR/SHAKEN
The FCC directed the Enforcement Bureau to provide written notice to originating small voice providers that are suspected of being a source of illegal robocalls. Upon notice, the small voice provider must take specific steps to mitigate the suspected illegal robocall traffic, provide information requested by the Enforcement Bureau, and include credible evidence that they are not originating such traffic.
If the provider does not promptly investigate the traffic and take steps to mitigate the identified traffic, the provider will have 90 days to implement STIR/SHAKEN. If the 90-day period will extend beyond June 30, 2022, the June 30 deadline will apply.
Update Extension Status
Non-facilities-based providers, and providers identified as a source of illegal robocalls, must update their Robocall Mitigation Database filings to indicate they are subject to a shortened extension within 10 business days of an Enforcement Bureau determination. The database must be updated again once STIR/SHAKEN has been implemented.
If you have questions regarding STIR/SHAKEN implementation and compliance, please contact any attorney in our office.