Quick answer: Almost certainly not. The FCC’s Robocall Mitigation Database is a register of providers, not of callers — 10,872 voice providers had filings in it as at 21 April 2026, against 471 million US retail voice connections as of June 2024. If your AI voice agent dials on numbers a carrier or CPaaS supplies, that carrier files under 47 CFR 64.6305 and you are its customer.
This is general information about a United States regulatory process, current as at 22 September 2026. It is not legal advice. Every rule and figure below was opened at its primary source on 22 September 2026 and is linked in the source table at the foot of the page.
Who has to file in the Robocall Mitigation Database, in the FCC’s own words
Three classes of entity file, and the classes are defined in 47 CFR 64.6300 rather than by what the business calls itself:
- Voice service providers certify under 47 CFR 64.6305(d). A “voice service” under 64.6300(o)(1) “means any service that is interconnected with the public switched telephone network and that furnishes voice communications to an end user using resources from the North American Numbering Plan…”. Both limbs must hold. Limb (o)(2) then extends it in two sub-limbs — facsimile transmissions, and, (o)(2)(ii), “without limitation”, to “any service that enables real-time, two-way voice communications, including any service that requires internet Protocol-compatible customer premises equipment and permits out-bound calling…”.
- Gateway providers certify under 64.6305(e). Under 64.6300(d) a gateway provider is “a U.S.-based intermediate provider that receives a call directly from a foreign originating provider or foreign intermediate provider at its U.S.-based facilities before transmitting the call downstream to another U.S.-based provider”, with “U.S.-based” and “receives a call directly” each further defined in the two sub-paragraphs that follow.
- Non-gateway intermediate providers certify under 64.6305(f). An intermediate provider under 64.6300(g) is “any entity that carries or processes traffic that traverses or will traverse the public switched telephone network at any point insofar as that entity neither originates nor terminates that traffic”.
The enforcement mechanism is downstream, not on you. Under 64.6305(g)(1), “Intermediate providers and voice service providers shall accept calls directly from a domestic voice service provider only if that voice service provider’s filing appears in the Robocall Mitigation Database… and that filing has not been de-listed pursuant to an enforcement action.” That is why a missing or de-listed filing takes a carrier off the US network — and why it is your carrier’s filing, not yours, that decides whether your calls connect.
Am I a voice service provider if I run an AI voice agent?
Running software that decides what to say is not the test. The test is whether you furnish voice communications to an end user using North American Numbering Plan resources. A business that buys numbers and origination from a carrier or a CPaaS platform, points an agent at them and dials its own prospects is consuming voice service, not furnishing it.
The FCC is aware that people get this wrong in the cautious direction. In the Further Notice of Proposed Rulemaking published on 9 September 2026 (FCC 26-49, 91 FR 57454), the Commission wrote that “end users are not required to file in the RMD, and we do not condone voice service providers compelling their end users to submit RMD filings” — adding that staff have seen entities file anyway “out of an abundance of caution or because the provider supplying them with voice service requires them to do so to transmit their calls”. It seeks comment on whether to add a form option so such an entity can say on the record that it believes it is an end user.
The boundary is genuinely moving, though, and in one direction. The same Further Notice states the Commission’s belief that “voice service”, for the purposes of its rules targeting illegal calls, “includes PBXs, dialing platforms, cloud service providers, over-the-top service providers, call centers, value-added-service providers, and telephone number service providers (TNSP)” — but only to the extent those services “furnish[ ] voice communications to an end user using resources from the North American Numbering Plan”, including if they “enable[ ] real-time, two-way voice communications…”. The Commission is explicit that it does “not intend to alter the scope of entities that are voice service providers, but rather to clarify which entities are voice service providers today”. Read that as a warning that the qualifier does the work: on the Commission’s stated reading a dialling platform that furnishes numbering resources to its customers would be inside the definition, while one that dials on the customer’s own carrier account would not — but the Commission is seeking comment on that analysis, so it is not settled.
The Three-Name Test
Here is the screen we use before anyone reads a rule. Write down three company names:
- The company whose numbering resources your calls present as caller ID.
- The company whose SPC token signs your calls under STIR/SHAKEN.
- The company that appears in the Robocall Mitigation Database for the traffic you send.
If all three names belong to someone else, you are that company’s customer and it is the filer. If any one of the three is your own company name, stop and read 47 CFR 64.6300 before you decide anything. And the sharper version, for the reader who only remembers one line: if you cannot name the certificate that signs your caller ID, you do not yet know which one you are — go and find out before you assume you are only the customer.
The test is a screen, not the rule. It works because all three names track the same underlying question the rule asks — who furnishes the voice service — and because most businesses can answer all three in ten minutes from an invoice and a carrier portal. If you want the attestation half of that picture in detail, our walkthrough of how STIR/SHAKEN attestation works in the US compared with Australia’s code-based blocking covers what A, B and C attestation actually assert.
Where each business shape sits: the call-path filing table
| Your business shape | Do you file in the RMD? | Which definition decides it | What you must do | What your provider must do |
|---|---|---|---|---|
| You dial on numbers supplied by a CPaaS or carrier account in your name | No. You are an end user | 47 CFR 64.6300(o) — you do not furnish voice service to an end user | Give your provider truthful onboarding information; keep your own consent and calling records | File under 64.6305(d); run a robocall mitigation program; know its customers under 64.1200(n)(4) |
| Bring-your-own-carrier: you hold the carrier contract and SIP trunk, the platform just dials it | No, while you only place your own calls | Same test. Holding a trunk does not make you a furnisher of voice service to anyone else. Note that in FCC 26-49 the Commission says it believes — and is seeking comment on the view — that PBXs are among the services that are voice service, to the extent they furnish voice communications to end users using NANP resources | Confirm which entity the carrier treats as the originating provider for your traffic | File under 64.6305(d) and make an attestation-level decision on your numbers |
| You resell numbers or voice service to your own customers | Yes, very likely | 64.6300(o). FCC 26-49 reads the proposed “voice service provider” definition as covering “VoIP resellers and MVNOs” | File under 64.6305(d); certify STIR/SHAKEN status; recertify by 1 March each year; update within 10 business days | Its own filing still has to be current for it to accept your traffic |
| You run your own SBC and carry or process calls you neither originate nor terminate | Yes — as a non-gateway intermediate provider | 64.6300(g) and (i) | File under 64.6305(f); run a mitigation program; respond to traceback within 24 hours | Downstream providers may accept your traffic only if your filing appears and is not de-listed: 64.6305(g)(4) |
| You receive calls directly from a foreign provider at US facilities and pass them downstream | Yes — as a gateway provider | 64.6300(d) | File under 64.6305(e); mitigation program covering US NANP caller ID; traceback within 24 hours | 64.6305(g)(3) gates acceptance of your traffic on your filing |
| You are outside the US and send calls with US NANP caller ID into the US | Yes, to be carried — as a foreign voice service provider | 64.6300(c) | File under 64.6305(d). You are not required to implement STIR/SHAKEN — 91 FR 57454 states that foreign voice service providers “are not required to implement STIR/SHAKEN” | 64.6305(g)(2): US providers may accept your calls only if your filing appears and is not de-listed |
Two things the table is deliberately not doing. It is not telling an Australian or UK operator that any of this reaches them directly: the RMD is a United States instrument, and it touches a non-US business only through the US provider that carries its US-bound traffic. And it does not settle borderline cases — a platform that supplies numbering resources to its customers sits on the line the Further Notice is arguing about right now. If your shape is one of the bottom four rows, this page is a starting point and a US communications lawyer is the next step.
What happens if my RMD filing is wrong
If you are a filer, the accuracy rules bite hard, and most of them have been in force since 5 February 2026 under the Report and Order at 91 FR 343 (FCC 24-135) — with one exception noted below:
- A base forfeiture of $10,000 for each violation for filers that submit false or inaccurate information to the database.
- A base forfeiture of $1,000 for failure to update information that has changed within 10 business days.
- Both are base figures. The Commission notes that section 503’s adjustment factors “permit the Commission to assess penalties upward to the statutory maximum (in cases of egregious or deliberate malfeasance, for example) or reduce the penalty below the base”.
- These are continuing violations: “forfeitures shall be assessed on a daily basis up to the statutory maximum for continuing violations.”
- A $100 application fee for initial filings and annual recertifications has been adopted but is not yet in effect: 47 CFR 1.1105 takes effect only after notice to Congress and FCC systems updates, and on 9 September 2026 the Commission stated that “the requirement to submit an application fee as required by the amendment to 47 CFR 1.1105 adopted in the RMD Order, is not yet effective”. The Commission’s red-light rule does apply to RMD filings.
- Recertification is annual, “on or before March 1”, under 64.6305(h).
One precision point worth carrying, because it is the sort of thing that gets copied wrong: the Federal Register summary of that Report and Order says the update deadline is “within 10 days”, while the Commission’s own discussion and the codified rule at 64.6305(d)(5) both say 10 business days. Work to the rule text.
The penalty regime also explains a number most readers will find surprising. In the July 2026 Know-Your-Upstream-Provider Further Notice the Commission records that the Wireline Competition Bureau identified 338 filings — 3.2% of all the filings in the database at the time of review — that affirmatively assert the SPC-token implementation exemption but that the Bureau does not believe explained in detail why the exemption applies, as a filer claiming less than full implementation is required to do. Separately, FCC 26-49 notes that 6,689 RMD filings indicate full or partial STIR/SHAKEN implementation while only 2,143 providers appear on the Governance Authority’s list of authorised providers. Filings and reality diverge, which is the whole reason the September proceeding exists.
What is in force today and what is only proposed
| Measure | Status as at 22 September 2026 | Instrument | Date that matters |
|---|---|---|---|
| Voice service, gateway and non-gateway intermediate providers must file in the RMD | In force | 47 CFR 64.6305(d), (e), (f) | Current |
| Downstream providers may accept traffic only from listed, non-de-listed filers | In force | 47 CFR 64.6305(g) | Current |
| $10,000 / $1,000 base forfeitures, assessed daily for continuing violations; annual recertification by 1 March | In force | 91 FR 343 (FCC 24-135); 47 CFR 64.6305(h) | Effective 5 February 2026, confirmed at 91 FR 5242 |
| $100 application fee for initial RMD filings and annual recertifications | Adopted, not yet in effect | 91 FR 343 amending 47 CFR 1.1105; status confirmed at 91 FR 57454 | Effective date still to be announced in the Federal Register |
| Carrier duty to know its customers and its upstream providers | In force | 47 CFR 64.1200(n)(4) and (n)(5) | Current |
| Clarifying which entities are voice service providers; codifying that each parent, affiliate and subsidiary meeting the definition files separately; an “end user” option on the form; numbering-resource disclosure; which parts of a filing are public; faster removal and re-entry safeguards | Proposed only | FCC 26-49, 91 FR 57454, WC Dockets 24-213 and 17-97, CG Docket 17-59 | Comments due 9 October 2026; reply comments 9 November 2026 |
| Five baseline KYUP duties (information collection, compliance review, information verification, monitoring, responsive action); codifying ATIS attestation levels; requiring providers serving end users directly to assign attestations; prohibiting routing that strips authentication; requiring blocking of unauthenticated SIP calls | Proposed only | FCC 26-32, 91 FR 42602, WC Docket 17-97, CG Docket 17-59 | Comments closed 10 August 2026; replies closed 8 September 2026 |
| Repeal of the SPC-token undue hardship extension | Proposed — one of the two remaining extensions, with comment sought on the second (small providers originating via satellite) | FCC 26-32, 91 FR 42602 | Record closed 8 September 2026 |
| An FCC rule specific to AI-generated voice calls | None adopted. The separate AI-call disclosure NPRM remains pending | CG Docket 23-362 (NPRM 24-84) | See the trace below |
The FCC’s own fact sheet overstated one of these proposals
This one is worth recording, because it is a live example of how a correct-looking citation goes wrong. The FCC fact sheet dated 29 April 2026, circulated before the Commission’s 20 May 2026 open meeting, says the Further Notice would “repeal the two remaining undue hardship extensions to STIR/SHAKEN implementation”, and paragraph 105 of the draft item repeats it: “We propose to repeal the two remaining undue hardship extensions…”.
The version the Commission actually adopted, published at 91 FR 42602 on 9 July 2026, says something narrower: “We propose to repeal one of the two remaining undue hardship extensions to STIR/SHAKEN implementation… and seek comment on whether to repeal the second remaining extension”. The one proposed for repeal is the SPC-token extension. The satellite extension for small providers is only a question.
The draft carries its own warning — it states that the issues “remain under consideration and subject to change” and that it “does not constitute any official action by the Commission” — but the draft is a readable PDF on docs.fcc.gov while www.fcc.gov returns HTTP 403 to many automated clients, so the draft is disproportionately what gets quoted. We opened both documents on 22 September 2026 and diffed paragraph 105. If you are citing a proposal, cite the Federal Register text, not the fact sheet.
Is there an FCC rule specific to AI voice calls yet? Here is the trace
No, and here is the method rather than the assertion. On 22 September 2026 we queried the Federal Register full-text API for documents by the Federal Communications Commission published since 1 January 2026 whose text matches "artificial intelligence" robocall. It returned 2 documents: the RMD Further Notice above, in which the phrase appears once and refers to guidance on agency use of AI in data-validation tooling, and the 2026 Unified Agenda notice. A second query for "AI-generated" also returned 2, neither an AI-call rulemaking.
Two positive controls on the identical query form, because a failed search is not evidence of absence: the same query with no search term returns 318 FCC documents for the period, and the term robocall alone returns 25. The query works; there is simply nothing there. The FCC’s AI-call disclosure proposal is a separate and still-pending proceeding in CG Docket 23-362, which we cover in detail in our breakdown of FCC NPRM 24-84 and the proposed AI-call disclosure rules. What binds AI callers today is the TCPA, not the RMD.
If I am not the filer, what do I ask the carrier that is?
This is the work the page exists to hand you. It costs nothing, it takes one email, and the rule each question rests on is named so your carrier cannot wave it away:
- “Does your RMD filing appear, and has it ever been de-listed?” Under 64.6305(g)(1) a downstream provider may accept calls directly from your carrier only if your carrier’s filing appears in the database and has not been de-listed pursuant to an enforcement action. This is the question that decides whether your traffic connects at all.
- “Which certification did you make under 64.6305(d)(1) — full, partial, or no STIR/SHAKEN implementation?” Partial implementation is legitimate and common; it is also the reason two number ranges from the same carrier can attest differently.
- “If you claim an implementation extension, which rule, and what is your detailed explanation?” A filer certifying less than full implementation must state the exempting rule and explain in detail why it applies. The Bureau found 338 filings that did not, in its view, do so.
- “What attestation level will my numbers receive, and on what basis?” If the answer is B or C, ask what would move it to A.
- “You have a duty under 47 CFR 64.1200(n)(4) to know your customers. What do you need from me to satisfy it?” That rule requires the provider to “take affirmative, effective measures to prevent new and renewing customers from using its network to originate illegal calls, including knowing its customers and exercising due diligence in ensuring that its services are not used to originate illegal traffic”. You are the customer it has to know. Volunteering the information early is the cheapest insurance available.
- “Did you recertify by 1 March this year?” 64.6305(h) makes it annual, so the answer expires.
- “If you are asking me to file in the RMD, on what basis do you consider me a voice service provider?” Put the question in writing. The Commission has said on the record that it does not condone providers compelling their end users to file.
The honest economics: this is a recurring job, not a one-off. Every answer above expires on the next 1 March recertification, and it expires per carrier and per number range — so a team on three carriers is asking all seven questions three times over, and asking them again after every 1 March recertification — and the answers only matter if someone reads them against the numbers your agents are actually dialling. Teams that skip it usually discover the gap through answer rates rather than through a letter, which is the expensive way to find out; the remediation path if that has already happened is in our guide to fixing a business number that shows as Scam Likely. And if you are weighing whether to hold the carrier relationship yourself at all, that trade-off is set out in our answer on whether an AI voice agent needs its own SIP trunk — taking the trunk in-house changes row two of the table above, not row one.
Zian AI runs autonomous phone, SMS, email and WhatsApp sales agents in 30+ languages, and the diligence above is what our own deployment conversations start with, because the regulatory question and the deliverability question turn out to be the same question asked twice.
Frequently asked questions
Do I have to be in the Robocall Mitigation Database if I run an AI voice agent?
Almost certainly not. The database lists voice service providers, gateway providers and non-gateway intermediate providers that file under 47 CFR 64.6305. If your agent dials on numbers supplied by a carrier or a CPaaS platform, that provider is the filer and you are its customer. You cross the line only when you begin furnishing voice service to other people.
Am I a voice service provider if my software places the calls?
The test is the definition at 47 CFR 64.6300(o), not whether software dials. Voice service means any service that is interconnected with the public switched telephone network and that furnishes voice communications to an end user using resources from the North American Numbering Plan. Both limbs must hold. Placing your own calls through a provider that furnishes that service does not make you the furnisher.
My carrier is telling me I have to file in the RMD. Is that right?
Ask on what basis, in writing. In the Further Notice published on 9 September 2026 the FCC stated that end users are not required to file in the RMD and that it does not condone voice service providers compelling their end users to submit RMD filings. It seeks comment on whether to add an option to the submission form so an entity can record that it believes it is an end user rather than a voice service provider. Source: 91 FR 57454.
What happens if my RMD filing is wrong?
Since 5 February 2026 the base forfeiture is $10,000 for each violation for filers that submit false or inaccurate information to the database, and $1,000 for failure to update information that has changed within 10 business days. Both are base figures that the section 503 adjustment factors can move upward to the statutory maximum or downward, and the FCC assesses them on a daily basis for continuing violations. Source: 91 FR 343.
When do comments close on the 2026 RMD proceeding?
Comments in WC Docket Nos. 24-213 and 17-97 and CG Docket No. 17-59 are due on or before 9 October 2026, and reply comments on or before 9 November 2026. The item is FCC 26-49, adopted 22 July 2026 and published at 91 FR 57454 on 9 September 2026. Note that the 9 November date is the reply deadline, not the opening comment deadline.
Is there an FCC rule yet that is specific to AI-generated voice calls?
None published in the Federal Register during 2026 as at 22 September 2026. A query of the Federal Register full-text API for FCC documents since 1 January 2026 matching artificial intelligence and robocall returned 2 results, neither an AI-call rulemaking. Two positive controls on the same query form returned 318 FCC documents with no search term and 25 for robocall alone, which shows the query itself works. The separate AI-call disclosure proposal, NPRM 24-84 in CG Docket 23-362, remains pending.
Does any of this apply to me if I am calling from Australia?
The Robocall Mitigation Database is a United States instrument and the filing duties in 47 CFR 64.6305 apply to providers in the United States call path. It touches an Australian business through the US provider that carries its US-bound traffic, and through rule 64.6305(g)(2), under which US providers may accept calls carrying US numbering plan caller ID from a foreign provider only if that foreign provider appears in the database and has not been de-listed.
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Where every figure on this page comes from
| Figure | Who published it | Link | Date read |
|---|---|---|---|
| 10,872 voice providers with RMD filings as at 21 April 2026 | FCC, KYUP Further Notice, 91 FR 42602 | federalregister.gov 2026-13874 | 22 Sep 2026 |
| 471 million US retail voice connections (as of June 2024) | FCC Office of Economics and Analytics, quoted in 91 FR 42602 | federalregister.gov 2026-13874 | 22 Sep 2026 |
| 338 filings, 3.2% of filings at time of review, asserting the SPC-token exemption without detailed explanation | FCC Wireline Competition Bureau, in 91 FR 42602 | federalregister.gov 2026-13874 | 22 Sep 2026 |
| Proposal to repeal one of the two remaining undue hardship extensions; comments closed 10 August 2026, replies 8 September 2026 | FCC, 91 FR 42602 (FCC 26-32) | federalregister.gov 2026-13874 | 22 Sep 2026 |
| Draft fact sheet wording “repeal the two remaining undue hardship extensions”, dated 29 April 2026 | FCC draft item circulated for the 20 May 2026 open meeting | docs.fcc.gov DOC-421205A1 | 22 Sep 2026 |
| 6,689 RMD filings indicating full or partial STIR/SHAKEN; 2,143 providers on the Governance Authority list | FCC, RMD Further Notice, 91 FR 57454 (FCC 26-49) | federalregister.gov 2026-18366 | 22 Sep 2026 |
| Comments due 9 October 2026, reply comments 9 November 2026; published 9 September 2026 | FCC, 91 FR 57454 | federalregister.gov 2026-18366 | 22 Sep 2026 |
| “End users are not required to file in the RMD” and the “abundance of caution” observation | FCC, 91 FR 57454 | federalregister.gov 2026-18366 | 22 Sep 2026 |
| $10,000 and $1,000 base forfeitures and daily continuing-violation assessment, effective 5 February 2026; $100 application fee adopted but not yet effective (91 FR 5242; 91 FR 57454) | FCC Report and Order, 91 FR 343 (FCC 24-135) | federalregister.gov 2026-00010 | 22 Sep 2026 |
| Definitions of voice service, gateway provider, intermediate provider, foreign voice service provider | Office of the Federal Register / GPO, eCFR | 47 CFR 64.6300 | 22 Sep 2026 |
| Filing duties, 10 business day updates, 1 March recertification, acceptance gating in paragraph (g) | Office of the Federal Register / GPO, eCFR | 47 CFR 64.6305 | 22 Sep 2026 |
| Carrier duty to know its customers and upstream providers | Office of the Federal Register / GPO, eCFR | 47 CFR 64.1200(n)(4) and (n)(5) | 22 Sep 2026 |
| 2 of 318 FCC Federal Register documents match “artificial intelligence” + robocall since 1 January 2026; 2 match “AI-generated”; 25 match “robocall” alone | Zian AI, first-party query of the Federal Register full-text API, run 22 September 2026 | Federal Register API documentation | 22 Sep 2026 |