TCPA Regulatory Update — STIR/SHAKEN And Robocall Mitigation Database Implementation Take Effect

America's largest voice service providers are now using STIR/SHAKEN caller ID authentication standards on their Internet Protocol ("IP") networks. Pursuant to the FCC's March 2020 Report and Order (summarized here), as of July 1, all voice service providers and intermediate service providers not subject to an extension were required to implement the STIR/SHAKEN call authentication framework within their IP networks. Those providers whose networks were previously non-IP based were required to either upgrade to implement STIR/SHAKEN or develop some other non-IP based robocall mitigation program. Voice service providers and intermediate providers had to certify that they were STIR/SHAKEN compliant or had a robocall mitigation plan in place, through FCC's Robocall Mitigation Database, also no later than June 30. Those that failed to certify may face FCC enforcement action including a possible monetary forfeiture.