Insights

FCC Raises the Bar on Robocall Mitigation: What the March 1 Deadline Means for Service Providers

Feb 05, 2026

The Federal Communications Commission (FCC) has formally raised expectations for Robocall Mitigation Database (RMD) compliance, and the message to service providers is clear. Robocall mitigation is no longer a static filing requirement. It is now an ongoing operational obligation.

This shift builds on the FCC’s broader robocall enforcement framework, including the December 15, 2025 mandate requiring all U.S.-based providers in the call path to block calls using a reasonable Do Not Originate (DNO) list. Under that rule, providers are expected not only to block DNO traffic, but to rely on a DNO list that is reasonable, current and practical to maintain.

On January 22, 2026, the FCC’s Wireline Competition Bureau reinforced this expectation with the release of Public Notice DA 26-72, announcing Office of Management and Budget approval and effective dates for revised Robocall Mitigation Database rules. The Public Notice confirms that providers must complete their annual RMD recertification by March 1, 2026, with the filing window opening February 1.

The FCC has also made clear that it will place greater scrutiny on the accuracy and timeliness of RMD filings, signaling that providers must be able to demonstrate that their robocall mitigation practices, including DNO blocking, are actively working in their networks.

Why This Matters: Compliance Now Requires Proof

The FCC’s updated rules reflect a fundamental shift in enforcement posture. Accuracy is now a priority, not a formality. Providers are expected to ensure that their RMD disclosures remain continuously accurate and are updated within required timeframes when circumstances change.

To reinforce this shift, the FCC has increased base forfeiture amounts for submitting false or inaccurate RMD information and for failing to update filings in a timely manner. The Bureau has also established a formal reporting mechanism that allows stakeholders to flag deficient RMD filings directly to the FCC, further increasing enforcement risk.

At the center of this change is the FCC’s expectation that providers take reasonable, demonstrable steps to prevent illegal robocall traffic from originating on their networks. One of the clearest indicators of robocall risk is traffic originating from known DNO numbers. If that traffic is present, RMD claims may be questioned, regardless of how well-written a mitigation plan may be.

Under the updated framework, intent is no longer enough. Providers must be able to show outcomes.

How RealNumber® DNO Helps Meet the FCC’s Higher Standard

 As the FCC raises expectations, service providers need robocall mitigation solutions grounded in authoritative data and proven numbering intelligence, not static lists or ad hoc blocking rules.

RealNumber® DNO is built on Somos’ trusted numbering data and governance expertise, providing a comprehensive view of numbers that should never originate traffic. The dataset is continuously maintained and informed by authoritative industry sources, helping providers identify high-risk and prohibited calling sources with greater confidence.

RealNumber DNO enables service providers to operationalize their robocall mitigation commitments by preventing traffic associated with known DNO numbers before it originates. This directly supports the FCC’s expectation that providers take reasonable, demonstrable steps to avoid originating illegal robocall traffic and to maintain accurate RMD disclosures.

What sets RealNumber DNO apart is the quality and reliability of the underlying data. Providers benefit from:

• A centralized DNO dataset informed by authoritative numbering and industry sources

• Ongoing updates that reflect changes in numbering status and risk signals

• Alignment with Somos’ long-standing role in numbering administration and data stewardship

• Actionable intelligence that supports defensible, auditable robocall mitigation practices

By using RealNumber DNO, providers can move beyond generic blocking approaches and rely on a trusted dataset that supports real-time decision making and regulatory accountability.

As March 1 approaches, providers should evaluate not just whether they have a DNO solution in place, but whether that solution is built on data strong enough to withstand FCC scrutiny.

Take Action Before March 1

The FCC has raised expectations with its robocall mitigation requirements, and service providers are expected to comply.

RealNumber DNO helps turn robocall mitigation commitments into measurable action and supports stronger, more defensible RMD compliance ahead of the March 1 deadline.

Learn how RealNumber DNO can help your organization meet the FCC’s updated robocall mitigation requirements. Reach out to a Somos team member at connect@somos.com today!