REMINDER: June 30, 2022 STIR/SHAKEN Implementation Deadline for Non-Facilities-Based Small Providers Approaching

The Federal Communications Commission (“FCC”) has issued a Public Notice reminding non-facilities-based small voice service providers that they must implement the STIR/SHAKEN caller ID authentication framework in their Internet Protocol (“IP”) networks no later than June 30, 2022, and that they must update their certifications and associated filings in the Robocall Mitigation Database within 10 business days of completion of the implementation. This deadline applies to providers that offer voice to end users solely using connections that are not sold by the provider or its affiliates, such as over-the-top (“OTT”) Voice over Internet Protocol (“VoIP”) providers. Providers that fail to implement the authentication framework by the deadline may be subject to enforcement action.

As a reminder, the Commission adopted the STIR/SHAKEN rules in March 2020 pursuant to the Telephone Robocall Abuse Criminal Enforcement and Deterrence Act, which requires voice service providers to implement caller ID authentication technology in the IP portions of their network. The FCC granted small service providers a two-year extension of the original deadline of June 30, 2021, but then shorted the extension to June 30, 2022 for a subset of those providers, specifically non-facilities-based small providers, based on evidence showing that these providers are originating a large and disproportionate amount of robocalls.

Please contact Robin Tuttle at [email protected] or Dee Herman at [email protected] if you have any questions regarding this deadline.