The Risk of Carrier De-Listing — A Compliance Guide to the Robocall Mitigation Database (RMD)


The Database Your Carrier Business Cannot Afford to Be Removed From

Imagine waking up one morning to find that your company’s certification has been removed from the FCC’s Robocall Mitigation Database (RMD). Within hours, every intermediate provider and voice service provider in the United States is prohibited by law from accepting your calls. Your traffic grinds to a halt. Your revenue evaporates.

This is not a hypothetical scenario. In August 2025 alone, the FCC’s Enforcement Bureau removed 185 voice service providers from the RMD, stating that their certifications were deficient because they failed to provide a robocall mitigation plan or required information.

If your carrier business is not RMD-compliant, you are at risk of being next.

What Is the Robocall Mitigation Database?

The RMD is a public database implemented by the FCC to track which voice service providers have implemented STIR/SHAKEN or have an approved robocall mitigation program. All voice service providers—including carriers, intermediate providers, and gateway providers—must file certifications in the RMD to demonstrate their compliance.

Why does the RMD matter?

Because the FCC has made it clear: if you are not in the RMD, you cannot route traffic in the United States. Removal from the RMD requires all intermediate providers and voice service providers to cease accepting calls directly from the removed company.

What Gets a Carrier Removed from the RMD?

The FCC removes carriers from the RMD for several reasons:

1. Failure to File a Certification: If you simply do not submit an RMD certification, you are not in the database. Your traffic is blocked.

2. Deficient Certification: Your certification must include a robocall mitigation plan. If the FCC finds your plan inadequate or missing, you receive a Notification of Deficient Robocall Mitigation Database Certification.

3. Failure to Cure Deficiencies: If you receive a notification, you are allowed to cure the deficiencies. Failure to do so results in removal.

4. False or Inaccurate Information: The FCC has established forfeitures for submitting inaccurate or false certification data to the RMD and for failures to timely update RMD filings.

The Removal Process: What to Expect

The FCC’s enforcement process is swift and unforgiving:

Step 1: Notification. The FCC’s Enforcement Bureau issues a Notification of Deficient Robocall Mitigation Database Certification to the non-compliant carrier.

Step 2: Cure Period. The carrier is afforded a final opportunity to cure the deficiencies.

Step 3: Removal. If the carrier fails to cure, the FCC issues an order for immediate removal from the RMD.

Step 4: Traffic Block. Upon removal, all intermediate providers and voice service providers must cease accepting calls directly from the removed company.

The Stakes Could Not Be Higher

For a carrier business, RMD removal is existential. Consider the consequences:

Revenue Loss: If no other carrier can accept your traffic, you have no business. Your revenue stream stops immediately.

Reputation Damage: Being removed from the RMD is a public black mark. The FCC publishes removal orders, and your competitors and customers will know.

Recovery Is Difficult: To get back into the RMD, you must file a new certification, demonstrate compliance, and convince the FCC that you are trustworthy. This process takes time—time during which you are generating zero revenue.

How to Stay RMD-Compliant

Staying in RMD requires ongoing vigilance:

File Annually: RMD certifications must be filed and updated regularly. The FCC requires timely updates whenever your information changes.

Maintain a Robocall Mitigation Plan: Your certification must include a detailed plan for mitigating illegal robocalls. This plan must be substantive, not a placeholder.

Implement STIR/SHAKEN: If you have a STIR/SHAKEN implementation obligation, you must actually implement it—not just file paperwork saying you will.

Respond to FCC Inquiries: If the FCC contacts you about your certification, respond promptly and completely.

The Bottom Line

RMD compliance is not optional. It is the price of admission for doing business in the U.S. telecommunications network. The FCC has demonstrated that it will remove non-compliant carriers without hesitation.

At Microtalk, we help carriers navigate RMD compliance—from filing certifications to implementing robocall mitigation plans. Because being removed from the RMD isn’t just a compliance failure. It’s a business failure.

Is your carrier business listed in the RMD? And more importantly—is your listing up to date?

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