Foreign Robocall Elimination Act: Compliance Guide

Written by: Matt Beucler, CEO, Plura AI

Key Takeaways

• The Foreign Robocall Elimination Act requires foreign carriers to post a $100,000 bond and register in the FCC Robocall Mitigation Database before transmitting U.S.-bound calls.²

• High-volume operators must keep RMD registration current, apply correct STIR/SHAKEN attestations, and maintain documented KYUP and traceback procedures.

• Real-time DNC scrubbing, four-year KYC record retention, and 100% U.S. infrastructure now function as baseline expectations under the 2026 FCC rulemakings.²

• Non-compliance carries steep penalties, including $10,000 forfeitures for false filings and $1,000 daily fines for late RMD updates.

• Plura AI supplies the carrier-level controls high-volume operators use to meet these obligations, and you can book a live demo with Plura to see how its FCC-licensed platform maps to your compliance requirements.

7-Step Foreign Robocall Elimination Act Compliance Checklist

1. File or update your RMD registration. Confirm your entry in the FCC Robocall Mitigation Database, pay the $100 application fee, and schedule annual recertification.

2. Implement STIR/SHAKEN at the correct attestation level. Obtain a valid Operating Company Number (OCN), register with the STI Policy Administrator (STI-PA), and apply A-, B-, or C-level attestations only when the defined criteria are met.

3. Establish Know-Your-Upstream-Provider (KYUP) procedures. Collect, review, verify, monitor, and take responsive action on every upstream provider relationship before activation and at each renewal.

4. Build a traceback response workflow. Document a 24-hour response procedure for Industry Traceback Group (ITG) requests and assign a named internal owner.

5. Retain KYC records for four years. Store customer name, physical address, government-issued identification, and alternate telephone number from service activation through four years after the relationship ends.

6. Enforce real-time DNC scrubbing. Check every outbound contact against federal and state Do Not Call (DNC) registries before dial, and block non-compliant numbers at the platform level.

7. Remediate spam labels and authenticate branded caller ID. Issue branded caller ID through an FCC-licensed carrier and authenticate every outbound call through STIR/SHAKEN to reduce “Spam Likely” presentation at the destination handset.

This checklist describes the regulatory landscape as of May 2026. Consult qualified telecommunications counsel before making compliance determinations for your organization.

Run your numbers through Plura’s calculator to check your ROI in real time.³

Filing in the FCC Robocall Mitigation Database

The FCC’s Report and Order in WC Docket No. 24-213 (FCC 24-135) governs RMD filing requirements, fee schedules, and forfeiture exposure for voice service providers and intermediate providers.

RMD filing starts with registration in the FCC’s CORES (Commission Registration System) and submission of a robocall mitigation plan or STIR/SHAKEN compliance certification. Both initial submissions and annual re-certifications carry a $100 application fee per FCC 24-135.

The 10-business-day update rule functions as a hard operational deadline. Filers that fail to update required information within 10 business days of any change face a base forfeiture assessed on a continuing daily basis until cured. Changes that trigger the update obligation include shifts in STIR/SHAKEN implementation status, ownership changes, and contact-information updates.

False or inaccurate information in an RMD filing carries a steeper penalty tier. FCC 24-135 establishes a base forfeiture for each violation when filers submit false or inaccurate information.

The RMD also functions as a gatekeeping mechanism across the call chain. Voice service providers and intermediate providers must refuse traffic sent directly from any provider that does not appear in the RMD. Removal from the database effectively disconnects a provider from the U.S. market, as demonstrated by the FCC Enforcement Bureau’s December 2025 orders to China Unicom, China Mobile Hong Kong, and China Telecom Global, which marked the first time national security was cited as grounds for RMD removal proceedings.

Annual re-certification remains mandatory for every filer. All RMD filers must re-certify annually to the accuracy of their submissions. Operators should calendar this obligation alongside their STIR/SHAKEN certificate renewal cycle, because RMD registration ties directly to attestation status.

STIR/SHAKEN A-Level Attestation Checklist

STIR/SHAKEN is the FCC-mandated caller ID authentication framework that implements the TRACED Act. The framework assigns one of three attestation levels to each signed call, and the FCC’s 2026 draft Further Notice of Proposed Rulemaking (FNPRM) in WC Docket No. 17-97 and CG Docket No. 17-59 proposes to codify the criteria for each level and prohibit improper attestations.

A-level attestation applies when the provider can support both the identity of the customer and the customer’s right to use the calling number. The draft FNPRM requires providers applying A-level attestations to satisfy both conditions before signing. Applying A-level attestation without verified number association represents the type of improper attestation the FCC proposes to prohibit explicitly.

B-level attestation applies where the provider has a direct, authenticated relationship with the customer but has not verified the customer’s association with the specific telephone number being used.

C-level attestation applies where the provider lacks origination responsibility or a direct customer relationship, such as when handling transit traffic.

The 2026 FNPRM also proposes repeal of the two remaining undue-hardship extensions to STIR/SHAKEN implementation and seeks to prohibit intentional routing designed to strip authentication information where a technically available route preserves it.

The KYUP (Know Your Upstream Provider) framework reinforces attestation integrity. The FCC’s April 2026 FNPRM notes that STIR/SHAKEN attestation integrity depends in part on the originating provider’s relationship with and knowledge of the customer, citing the 2024 Lingo Telecom consent decree as an example where inadequate KYC contributed to incorrect attestations for spoofed robocalls.

To participate in STIR/SHAKEN, providers must maintain an up-to-date FCC Form 499-A, hold a valid OCN, register in the RMD, register with the STI-PA, select a Certification Authority (STI-CA), obtain a Secure Telephone Identity (SPC) Token, and request a digital certificate from an approved STI-CA.

Traceback Investigation Response Procedures

Traceback cooperation now functions as a baseline obligation for providers registered in the RMD. Carriers must cooperate with the FCC, law enforcement, and the Industry Traceback Group (ITG) when investigating illegal robocalls.

The 24-hour response expectation has become a documented enforcement standard. The 2025 warning notices from the state AG Anti-Robocall Litigation Task Force cited failure to respond to traceback requests within 24 hours as a specific compliance deficiency. Operators should treat 24 hours as the operational ceiling, not a target.

KYC record retention forms the foundation of an effective traceback response. The FCC’s April 2026 FNPRM proposes requiring originating providers to retain KYC information and supporting records for four years after the customer relationship ends, aligning with the statute of limitations the FCC identifies for certain spoofing and intentional TCPA violations.

The minimum KYC data set proposed includes the customer’s name, physical address, government-issued identification number, and an alternate telephone number collected before service activation. For high-volume customers, including business and foreign customers, the April 2026 FNPRM seeks comment on whether originating providers should also collect the intended use of service and, where applicable, the IP address from which calls will be placed.

Red flags trigger re-verification. The April 2026 FNPRM proposes that originating providers re-verify customer information when unusual traffic patterns, inconsistent foreign IP origination, dormant accounts that suddenly generate large call volumes, suspicious addresses or websites, or payment through non-traceable means arise.

Enforcement exposure for KYC failures is material. The April 2026 FNPRM proposes a $2,500 per-call base forfeiture for KYC violations. At high call volumes, that exposure compounds quickly.

Book a live demo with Plura to see how carrier-level controls map to your traceback and KYC obligations.

Gateway-Provider Obligations Under the Foreign Robocall Elimination Act

The table below maps compliant versus non-compliant gateway practices across four dimensions. Every data point is cited inline. This table is descriptive, not legal advice, and readers should consult qualified counsel for specific obligations.

Obligation Area	Compliant Practice	Non-Compliant Practice	Enforcement Reference
RMD Filing	Active RMD registration, $100 fee paid, annual re-certification current, updates filed within 10 business days of any change	No RMD filing, lapsed certification, or failure to update changed information	Forfeitures described in FCC 24-135
STIR/SHAKEN Attestation	A-level applied per criteria defined in FNPRM, with B- and C-level applied per codified criteria	Improper A-level attestation without verified number association, or routing designed to strip authentication information	Lingo Telecom consent decree (2024); proposed codified prohibition in 2026 FNPRM
Traceback Response	Response within the 24-hour standard, with KYC records retained for four years post-relationship	Failure to respond within 24 hours, or no documented KYC records available for production	State AG Task Force warning notices (Dec. 2025); 3,060 traceback notices to Bandwidth, 9,712 to Inteliquent since 2019
Upstream Provider Vetting	KYUP review completed before new agreements, renewals, and upon risk awareness; traffic refused from providers not in RMD	Accepting traffic from unregistered providers, with no documented upstream vetting process	State AG Task Force Dec. 2025 notices to Bandwidth, Inteliquent, and Lumen for accepting foreign-originated illegal traffic

Mapping Act Requirements to Plura Platform Controls

The table below maps statutory obligations to Plura controls. Plura provides infrastructure that supports compliance workflows, and customers remain responsible for their own regulatory obligations. Readers should consult qualified counsel for their specific compliance posture.

Statutory Obligation	Regulatory Reference	Plura Control	Infrastructure Layer
STIR/SHAKEN authentication on every outbound call	TRACED Act; FCC STIR/SHAKEN implementation orders	STIR/SHAKEN caller ID verification on every outbound voice call via FCC-licensed carrier, with OCN registration and SPC Token maintained	FCC-licensed audio bridging carrier; carrier identity layer with OCN registration
RMD filing and annual re-certification	FCC 24-135; 47 CFR 64.6305	Plura maintains its own active RMD filing as an FCC-licensed carrier, so operators on Plura’s infrastructure originate calls through a registered provider	FCC-licensed carrier; 100% U.S. infrastructure
Real-time DNC scrubbing before dial	TCPA, 47 U.S.C. § 227; FTC DNC Registry rules	Real-time DNC scrubbing via integration with The Blacklist Alliance’s TCPA Litigation Firewall, with federal and state DNC registries checked before every outbound contact and non-compliant numbers blocked at platform level2	Compliance engine; pre-dial scrubbing layer
Immutable consent records and KYC documentation	FCC April 2026 FNPRM; four-year KYC retention proposal	Timestamped, immutable consent ledger with audit-ready exports available on demand, and a stateful conversation database that retains interaction history per customer token	Stateful Conversation Database; Compliance Engine with SOC 2 and HIPAA-aligned controls1
100% U.S. infrastructure for sensitive data handling	FCC March 2026 NPRM; FCC NPRM CG Docket No. 26-52	Voice origination, model hosting, data storage, and call recording on domestic infrastructure by architecture, with zero offshore infrastructure dependencies	100% U.S. infrastructure; no third-party CPaaS in the call path

Spam-Label Remediation and Branded Caller ID

Spam labels sit at the carrier layer, not the application layer. Most AI voice platforms cannot remediate them because they do not own the carrier stack, they rent from a third-party CPaaS (Communications Platform as a Service) and inherit that provider’s caller ID reputation instead of building their own.

Plura issues branded caller ID directly through its FCC-licensed carrier. Calls present with the company’s name and the reason for the call rather than “Spam Likely” or an unrecognized number. STIR/SHAKEN authentication runs on every outbound call, which the destination carrier uses to verify legitimate origination. The FCC’s December 2025 FNPRM proposes requiring terminating providers to transmit verified caller name or other caller identity information for presentation on a consumer’s handset whenever they transmit an indication that a call has received an A-level attestation, which makes carrier-level branded caller ID increasingly important for pickup rates.

iOS 26 call-screening adds another layer of friction for operators without carrier-level identity. Plura’s AI agents communicate with iOS 26’s call-screening layer so calls that would otherwise be intercepted before ringing through can present a recognizable identity to the recipient. This converts screened calls into pickups rather than voicemails.

The FCC’s March 2026 NPRM also proposes measures to require voice service providers to implement measures to ensure that consumers know which calls originate from outside of the United States and to prohibit spoofing of U.S. telephone numbers for calls that originate from outside of the United States. Operators running on domestic infrastructure with authenticated caller ID are better positioned to demonstrate compliance with these identification requirements than those routing through offshore or third-party infrastructure.

Plura’s compliance framework includes SOC 2 infrastructure controls, TCPA and STIR/SHAKEN enforcement, integration with The Blacklist Alliance for DNC screening, and Number Verifier for caller ID reputation management.¹ These controls operate at the carrier level, not as bolt-on software layers.

Book a live demo with Plura to see branded caller ID and spam-label remediation in action on your call traffic.

Conclusion: Operational Pillars For Foreign Robocall Controls

The Foreign Robocall Elimination Act, the FCC’s 2026 FNPRM in WC Docket No. 17-97, and the companion NPRM in CG Docket No. 26-52 collectively expand the compliance surface for U.S. high-volume operators well beyond legacy TCPA obligations. The regulatory framework is building toward seven operational pillars that work together to verify caller identity and trace illegal traffic.

Active RMD registration establishes a provider’s baseline legitimacy. Correct STIR/SHAKEN attestation authenticates each call’s origin. Documented KYUP procedures ensure providers vet their upstream sources before sending traffic into the network.

The 24-hour traceback response standard and four-year KYC record retention give regulators and law enforcement the data they need when violations occur. Real-time DNC scrubbing prevents illegal contacts before they happen. Domestic infrastructure keeps sensitive data under U.S. jurisdiction and supports proposed limits on offshore handling.

Enforcement already operates at scale. In 2022, 51 attorneys general formed the Anti-Robocall Litigation Task Force, which in August 2025 issued warnings to 37 primary voice providers and 99 downstream providers for failing to meet FCC robocall-mitigation rules. The cost of non-compliance, measured in per-call forfeitures, civil penalties, and RMD removal, becomes material very quickly at high call volumes.

Plura’s FCC-licensed, 100% U.S. infrastructure platform supplies the carrier-level controls that support these obligations, including STIR/SHAKEN authentication on every outbound call, real-time DNC scrubbing, an immutable consent ledger, and domestic data handling by architecture. Customers remain responsible for their own compliance determinations and should consult qualified telecommunications counsel when evaluating their obligations under the Act and related FCC rulemakings.

Run your numbers through Plura’s calculator to check your ROI in real time.

Frequently Asked Questions

What is the Foreign Robocall Elimination Act and who does it affect?

The Foreign Robocall Elimination Act (S.2666) is federal legislation targeting illegal robocalls that originate outside the United States and enter the domestic telephone network. The Act would require voice service providers handling U.S.-bound international calls to post bonds of up to $100,000 unless they qualify as established, bona fide providers, and would create an interagency robocall enforcement task force.

The Act works alongside the FCC’s 2026 rulemaking activity, including the FNPRM in WC Docket No. 17-97 and the NPRM in CG Docket No. 26-52, which propose expanded obligations on gateway providers, originating carriers, and the U.S. companies that use offshore call centers. High-volume operators in healthcare, insurance, financial services, legal, and franchise networks are among the categories most directly affected because they generate the call volumes that attract regulatory scrutiny and frequently handle sensitive consumer data that the FCC proposes to restrict to domestic handling.

Readers should consult qualified telecommunications counsel to determine how the Act and related rulemakings apply to their specific operations.

What are the penalties for non-compliance with Robocall Mitigation Database filing requirements?

Under FCC 24-135, effective February 5, 2026, the penalty structure for RMD filing violations has two tiers. Submitting false or inaccurate information in an RMD filing carries a base forfeiture of $10,000 per violation. Failing to update required information within 10 business days of any change carries a base forfeiture of $1,000 per violation, assessed on a continuing daily basis until the deficiency is cured.

Both initial submissions and annual re-certifications require a $100 application fee. Beyond FCC forfeitures, state attorneys general have pursued civil penalties under the TCPA and the Truth in Caller ID Act, with the Truth in Caller ID Act authorizing penalties of up to $10,000 per violation or three times that amount for continuing violations. At high call volumes, per-call and per-day penalty structures compound quickly, so operators should treat the 10-business-day update deadline as a hard operational calendar item, not a soft guideline.

What does STIR/SHAKEN A-level attestation actually require from an originating provider?

A-level attestation under the STIR/SHAKEN framework is the highest level of caller ID authentication and carries the most stringent requirements. To apply an A-level attestation, the originating provider must be able to support both the identity of the customer placing the call and the customer’s right to use the specific telephone number being presented as the calling party.

This requirement means the provider needs a verified, direct relationship with the customer and documented confirmation that the customer is authorized to use that number. The FCC’s 2026 draft FNPRM proposes to codify these criteria and explicitly prohibit improper attestations, including applying A-level signatures where the provider cannot satisfy both conditions.

The 2024 Lingo Telecom consent decree illustrates the enforcement risk, because inadequate KYC practices contributed to incorrect A-level attestations for spoofed robocalls. Providers that apply A-level attestations without the underlying verification to support them face both FCC enforcement exposure and downstream blocking by terminating carriers that rely on attestation levels to make call-handling decisions.

How does Plura support compliance with foreign robocall rules for high-volume operators?

Plura AI is an FCC-licensed carrier, so the compliance controls that matter most under the foreign robocall framework operate at the infrastructure level rather than as software add-ons. STIR/SHAKEN caller ID verification runs on every outbound voice call through Plura’s own carrier, with OCN registration and SPC Token maintenance handled at the platform level.

Real-time DNC scrubbing checks every outbound contact against federal and state registries before dial, with non-compliant numbers blocked before the first attempt. The immutable consent ledger timestamps and stores consent records in an audit-ready format. All voice origination, model hosting, data storage, and call recording run on 100% U.S. infrastructure by architecture, which supports the domestic-handling requirements proposed under CG Docket No. 26-52 and the Foreign Robocall Elimination Act.

Plura also integrates with The Blacklist Alliance’s TCPA Litigation Firewall for litigation-risk screening. These controls support compliance efforts, but customers remain responsible for their own regulatory obligations and certifications.