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 1, 2026. 

• Annual Recertification – RMD filers are now required to recertify their RMD filings by March 1, 2026, and the recertification window recently opened on February 1, 2026. The relevant FCC rule requires filers to certify annually, on or before March 1, that any information they submitted to the RMD is accurate, true and correct. 
   
  • While the FCC concluded that RMD filings and recertifications are considered “applications” which require a processing fee of $100, this $100 fee is not yet required by the FCC and is not necessary for this year’s recertification. The FCC stated it will announce an effective date for this fee, so it may be required for next year’s annual recertification. 
     
  • At this time, we recommend that clients review their previously filed RMD filings and robocall mitigation plans which are publicly available in the RMD and which can be found by searching by company name. Clients should review the information that is currently provided in their respective filings and confirm whether the information is still true and correct or whether it needs to be updated. Once you are satisfied with the contents of the filing, you must recertify to the accuracy of the filing by following the brief recertification process discussed on pgs. 26 - 28 of the RMD filing instructions.
     
  • If you have any questions when confirming the accuracy of your company’s filing, or if you need assistance with editing the filing or completing the annual recertification process, we are available to help.

• Updating Information in CORES – As of February 5, 2026, the FCC requires that all entities and individuals that register with the FCC to obtain an FCC Registration Number (“FRN”) in the Commission Registration System (“CORES”), which is required in order to submit filings to the RMD, update any information submitted to CORES within 10 business days of any change to that information.

  • We recommend that clients regularly review their CORES filings to confirm that the information contained therein remains accurate. If you have any questions when confirming the accuracy of your company’s CORES filing, or if you need assistance with editing the information found in CORES, we are available to help.

• Newly Established RMD Forfeitures – The FCC adopted a base forfeiture of $10,000 per violation for submitting false or inaccurate information to the RMD. The FCC also adopted a $1,000 base forfeiture for the failure to update RMD information within 10 business days. The FCC stated it will enforce these new forfeitures on a continuing violation basis, meaning forfeitures will be assessed on a daily basis until they are cured or until the statutory maximum for continuing violations is reached.

  • Based on these forfeitures, we recommend that clients ensure their respective RMD filings remain updated and accurate even after the annual recertification process has passed.

• Filer Education/Guidance – The FCC released additional RMD guidance in the form of a “Frequently Asked Questions” document to assist RMD filers with any relevant compliance obligations. 

• Reporting Mechanism for Deficient Filings – The FCC established a mechanism which stakeholders can use to report deficient filings in the RMD to the FCC if they so choose. This mechanism is in the form of an email address (RMD-Reporting@fcc.gov), where stakeholders can submit information regarding deficient RMD filings, which will then be reviewed by FCC staff.

• Multi-Factor Authentication – The FCC announced that multi-factor authentication has recently been established to better secure the RMD and RMD access. Filers will need to follow this process when logging in to the RMD to update their respective filings and/or recertify.

As noted above, if you have any questions about these developments, or if you need assistance with complying with any new requirements, we are happy to help.