The Loophole That No Longer Exists

For years, the FCC‘s STIR/SHAKEN requirements focused primarily on terminating carriers—the providers that deliver calls to consumers. Intermediate providers—the carriers that help route calls from one network to another—were largely overlooked.

That loophole has now been closed.

The FCC has expanded STIR/SHAKEN requirements to require intermediate providers that are the first to pick up a call from an originating carrier to use STIR/SHAKEN. In other words, if you are an intermediate provider and you receive a call from an originating carrier, you must authenticate that call using STIR/SHAKEN.

Who Are Intermediate Providers and Gateway Carriers?

Intermediate Providers: Carriers that sit between originating carriers (which start calls) and terminating carriers (which deliver calls to consumers). They route traffic across networks.

Gateway Carriers: Carriers that accept traffic from foreign originating providers and bring it into the U.S. telecommunications network. They are the “point of entry” for international calls.

Both types of carriers now have significant compliance obligations under FCC rules.

Intermediate Provider Obligations

Intermediate providers must now:

Implement STIR/SHAKEN: If you are the first intermediate provider to receive a call from an originating carrier, you must authenticate that call using STIR/SHAKEN.

Maintain RMD Certification: Like all voice service providers, intermediate providers must be listed in the RMD.

Respond to Traceback Requests: All carriers, regardless of position in the call path, must respond to traceback requests within 24 hours.

Block Based on DNO Lists: The FCC‘s call blocking requirements apply to all providers in the call path, not just terminating carriers.

Gateway Carrier Obligations

Gateway carriers have additional, specialized obligations:

Vet Foreign Partners: Gateway providers must take reasonable and effective steps to ensure that foreign originating providers and foreign intermediate providers are not using the gateway to carry high volumes of illegal traffic onto the U.S. network.

Block Illegal Traffic: If a foreign partner is generating illegal traffic, the gateway provider must block that traffic.

Mark Foreign-Originated Calls: The FCC is proposing to require gateway providers to mark foreign-originated calls, intermediate providers to pass the indicator, and terminating providers to display a foreign-origin indicator to consumers.

Include Foreign Origin in Analytics: The FCC is proposing to require voice service providers to include whether a call originated from outside the United States as a factor in their call blocking analytics.

The Traceback Obligation

All carriers—intermediate providers, gateway carriers, and terminating carriers alike—have a critical traceback obligation.

The purpose of a traceback is to identify the provider that originated the call (or, for overseas calls, the gateway U.S. provider that first accepted the call).

The 24-Hour Rule: All domestic voice service providers must respond to traceback requests from the FCC, civil and criminal law enforcement, and the industry traceback consortium within 24 hours of receiving the request.

The Blocking Consequence: If an originating carrier fails to mitigate illegal traffic after being notified by the FCC, the FCC may require all providers immediately downstream to block all of that provider’s traffic.

Why This Matters for Your Business

If you are an intermediate provider or gateway carrier, the FCC‘s expanded rules mean you can no longer operate in the background. You are now on the front lines of the fight against illegal robocalls.

The Consequences of Non-Compliance:

– RMD Removal: Failure to comply with STIR/SHAKEN or other obligations can result in removal from the RMD.

– Traffic Blocking: Other carriers may be required to block your traffic.

– Fines: The FCC can impose significant penalties for non-compliance.

– Reputation Damage: Public enforcement actions can harm your business relationships.

The Bottom Line

Intermediate providers and gateway carriers are no longer exempt from FCC compliance obligations. The loophole has been closed, and the rules now apply to the entire call path.

At Microtalk, we help all types of carriers—intermediate, gateway, and terminating—navigate FCC compliance requirements. In today’s regulatory environment, every carrier in the call path is accountable.

Are you an intermediate provider or gateway carrier? Is your compliance up to date?