Deadlines Set for New Gateway Provider Obligations
Gateway providers – U.S.-based intermediate providers that
serve as the entry point for foreign calls into the United States
– have until January 11, 2023, to submit certifications,
including their robocall mitigation plans, to the Robocall
Mitigation Database (“RMD”). Beginning April 11, 2023,
gateway providers will be prohibited from accepting traffic from
foreign providers not listed in the RMD. Also, starting on April
11, 2023, downstream intermediate and voice service providers in
the United States will be prohibited from accepting traffic from
gateway providers that fail to submit their certifications to the
RMD.
As we reported in May, the Federal Communications Commission
(“Commission”) adopted rules imposing new obligations on
gateway providers. However, some of these obligations were subject
to approval from the Office of Management and Budget
(“OMB”). After several months of review, on December 12,
an OMB approval notice was published in the
Federal Register, triggering the above compliance
deadlines. With the establishment of these deadlines, all gateway
provider compliance dates have been finalized.
Commission Continues New and Aggressive Enforcement Action Against
Illegal Robocalling
Commission Removes First Non-Compliant Provider from
Robocall Mitigation Database
Following up on a previous Order to Show Cause, the
Commission’s Enforcement Bureau issued a Removal Order and
