What changed
On September 9 the Federal Register published the FCC's proposal to tighten the Robocall Mitigation Database (RMD), the list of providers that U.S. carriers are allowed to accept calls from. The Commission adopted the proposal on July 22. Publication started the clock: comments are due October 9 and reply comments November 9, 2026.
For companies running automated calls, the biggest change is scope. The FCC says it believes "voice service" under its illegal-call rules covers PBXs, dialing platforms, cloud service providers, over-the-top services, call centers, value-added service providers and telephone number service providers, as long as they deliver voice to end users using North American numbers. The notice adds that an entity which considers itself an information service can still be providing voice service. The classification it gives itself does not settle the question.
The notice also sets out ways to take providers off the list faster. It proposes a two-step removal process and asks whether five days is enough time for a provider to fix its filing, answer the Commission or notify its customers. It also asks about a one-step process for egregious conduct. Removal has direct consequences. Under the rule text in the notice, a voice service provider may not accept calls directly from a domestic or foreign provider whose filing has been removed. Emergency calls must still get through. Providers facing removal would also have to notify their customers, and the FCC asks whether that duty should extend to wholesale providers whose customers include call centers and enterprise users.
The same week, a bipartisan coalition of 49 state and territory attorneys general asked the FCC to strengthen its related "Know Your Upstream Provider" rules. They want carriers to verify and regularly review who sends traffic onto their networks, drop upstream providers that fail those checks, and keep records that investigators can use later.
Who it affects
Any operation where an AI voice agent places or receives calls on U.S. numbers. That includes a carrier calling drivers about pickups, a clinic confirming appointments, a lender making payment reminders, and a field service company dispatching technicians. The agent itself is only one link. Behind it sits a chain of platform, telephony provider and carrier, and each of them may be a "voice service provider" under this reading.
If you run your own dialing stack or call center and the FCC adopts this interpretation, you may have filing obligations of your own: the database filing, its annual recertification and its fee.
If you buy calling as a service, your own obligations may not change. You do depend on every provider in your call path staying listed. If one is removed, carriers must refuse its traffic, and the notice period the FCC is weighing is five days.
None of this is final. This is a further notice of proposed rulemaking, and the scope, the timelines and the customer-notice duty are all open for comment.
What to do now
- Ask your voice agent vendor which telephony providers carry your calls, and whether each one has a current RMD filing.
- Ask whether the vendor thinks it will have to file itself under the FCC's proposed reading, and when it plans to decide.
- Put a notice clause in the contract: the vendor tells you quickly if any provider in your call path gets a removal or suspension notice.
- Confirm there is a second carrier route for your numbers. Test it before you need it, not during a five-day notice window.
- If you run your own dialer or call center, have counsel review whether the proposed definition reaches you, and decide whether to file comments by October 9.
- Expect more questions from your carriers about who you are and what you send. The attorneys general want carriers to verify and regularly review their upstream traffic, so keep your consent and opt-out records ready to show.