Dear Clients and Friends, 

On February 20, 2026, the FCC released an Enforcement Advisory reminding Mobile Virtual Network Operators (MVNOs) of their obligation to file in the FCC’s Robocall Mitigation Database (RMD). This requirement includes filing a certification and accompanying robocall mitigation plan in the RMD. 

The Advisory also highlighted that all RMD filers, including MVNOs, are required to recertify their existing RMD filings annually by March 1, and that the first annual recertification deadline is March 1, 2026. Failure to file, update, and recertify RMD filings can carry consequences, such as fines and removal from the RMD, which can lead to blocking of a provider’s traffic. For more information on recent RMD obligations and consequences, please see our February 9, 2026 Client Advisory. 

Finally, in the Enforcement Advisory the FCC reminded MVNOs and all other voice service providers that they must respond to traceback requests from the FCC, law enforcement, and the industry traceback consortium. The traceback process and providers’ involvement in this process help these entities to identify the source of unlawful robocalls. 

If you have any questions about the Enforcement Advisory or these obligations, or if you need assistance with complying with these requirements, we are happy to help.