Robocall Mitigation Database (RMD) Annual Recertification (March 2, 2026)

Dear Clients and Friends,

On January 22, 2026, the FCC released a Public Notice announcing the final approval of and effective dates for certain revised Robocall Mitigation Database ("RMD") filing requirements. The FCC also announced that it has adopted additional guidance and mechanisms related to the RMD. These developments are described in detail below. Most notably, the FCC reminded RMD filers that each will need to review and recertify its current RMD filing by March 2, 2026.

• Annual Recertification – RMD filers are now required to recertify their RMD filings by March 2, 2026, and the recertification window recently opened on February 1, 2026. The relevant FCC rule requires filers to certify annually, on or before March 2, that any information they submitted to the RMD is accurate, true and correct.