{"id":863,"date":"2026-10-22T14:30:57","date_gmt":"2026-10-22T14:30:57","guid":{"rendered":"https:\/\/microtalk.co.uk\/blog\/?p=863"},"modified":"2026-10-22T14:33:43","modified_gmt":"2026-10-22T14:33:43","slug":"fcc-requirements-for-carriers-protection-of-customer-proprietary-network-information-cpni","status":"publish","type":"post","link":"https:\/\/microtalk.co.uk\/blog\/fcc-requirements-for-carriers-protection-of-customer-proprietary-network-information-cpni\/","title":{"rendered":"FCC Requirements for Carriers’ Protection of Customer Proprietary Network Information (CPNI)"},"content":{"rendered":"
\n

The Compliance<\/span> Obligation You Might Be Overlooking<\/h1>\n

When telecom carriers think about FCC<\/span> compliance<\/span>, they usually focus on call blocking, STIR\/SHAKEN<\/a>, and robocall mitigation<\/a>. But another critical compliance area is often overlooked: Customer Proprietary Network Information (CPNI).<\/p>\n

CPNI is the information telecommunications carriers collect about their customers, including call details, service usage, and billing information. Under federal law, carriers must protect the confidentiality of this information.<\/p>\n

And the FCC<\/span> takes CPNI compliance<\/span> very seriously.<\/p>\n

What Is CPNI?<\/h2>\n

CPNI is defined in 47 U.S.C. \u00a7 222(h)(1) as information that relates to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service subscribed to by any customer.<\/p>\n

Examples of CPNI include:<\/p>\n

– Phone numbers called<\/p>\n

– Call duration and frequency<\/p>\n

– Service plans and features<\/p>\n

– Billing information<\/p>\n

– Customer location data<\/p>\n

What CPNI is NOT:<\/h3>\n

Basic subscriber information such as name, address, and phone number (though this information is also protected under separate privacy rules).<\/p>\n

The Annual CPNI Certification Requirement<\/p>\n

Every year, telecommunications carriers and interconnected VoIP providers subject to the FCC<\/span>‘s CPNI rules must file an annual CPNI certification.<\/p>\n

The Deadline: March 3rd of every year.<\/p>\n

What the Certification Must Include:<\/h4>\n

– A statement that the carrier has implemented policies and procedures to protect CPNI<\/p>\n

– A summary of consumer complaints related to CPNI and actions taken<\/p>\n

– A description of any security breaches and how they were addressed<\/p>\n

– An officer’s signature certifying the accuracy of the filing<\/p>\n

Filing Location: The certification must be filed with the FCC<\/span>.<\/p>\n

The Expanded Breach Notification Rules<\/h5>\n

In 2024, the FCC<\/span> revised its data breach reporting and customer notification rules. These rules were upheld by the Sixth Circuit Court of Appeals in August 2025.<\/p>\n

Key Changes:<\/p>\n

Expanded Scope: Carriers must now disclose breaches of any customer personally identifiable information (PII), not just CPNI.<\/p>\n

Intentional and Inadvertent Breaches: The rules apply to both intentional and inadvertent breaches.<\/p>\n

Notification Requirements: Carriers must notify affected customers and law enforcement of security breaches involving CPNI.<\/p>\n

What This Means for Carriers: You must have systems in place to detect, report, and respond to data breaches\u2014regardless of whether they involve CPNI specifically or other types of customer PII.<\/p>\n

How to Achieve CPNI Compliance<\/span><\/pre>\n
CPNI compliance<\/span> requires a systematic approach:<\/p>\n
Implement Policies and Procedures: Develop and document policies for protecting CPNI. These should cover data access, storage, transmission, and disposal.<\/p>\n
Train Your Team: Ensure that all employees understand CPNI requirements and their responsibilities for protecting customer data.<\/p>\n
File Annual Certifications: Submit your CPNI certification to the FCC<\/span> by March 3 each year.<\/p>\n
Monitor for Breaches: Implement systems to detect unauthorized access to customer data.<\/p>\n
Respond to Breaches: If a breach occurs, notify affected customers and law enforcement as required by FCC<\/span> rules.<\/p>\n
Maintain Records: Keep detailed records of your CPNI compliance<\/span> efforts.<\/p>\n
The Consequences of Non-Compliance<\/span><\/pre>\n
Failing to comply with CPNI rules can have serious consequences:<\/p>\n
Fines: The FCC<\/span> can impose significant penalties for CPNI violations.<\/p>\n
Enforcement Actions: Public enforcement actions damage your reputation and customer trust.<\/p>\n
Legal Liability: Customers affected by CPNI breaches may bring lawsuits.<\/p>\n
Regulatory Scrutiny: CPNI failures can trigger broader FCC<\/span> investigations.<\/p>\n
The Bottom Line<\/pre>\n
CPNI compliance<\/span> is not optional for carriers. The annual March 3 deadline is approaching, and the FCC<\/span> is actively enforcing CPNI rules.<\/p>\n
At Microtalk<\/a>, we help carriers implement CPNI compliance<\/span> programs that protect customer data and meet FCC<\/span> requirements. Because protecting your customers’ privacy isn’t just the law\u2014it’s good business.<\/p>\n
Is your carrier business CPNI-compliant? Have you filed your annual certification?<\/p>\n<\/div>\n"},"excerpt":{"rendered":"
The Compliance Obligation You Might Be Overlooking When telecom carriers think about FCC compliance, they usually focus on call blocking, STIR\/SHAKEN, and robocall mitigation. But another critical compliance area is often overlooked: Customer Proprietary Network Information (CPNI). CPNI is the information telecommunications carriers collect about their customers, including call details, service usage, and billing information. […]<\/p>\n","protected":false},"author":6,"featured_media":864,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[320,319],"tags":[366,374,375,381,377,376,378,322,379,4,380,369,368,367],"class_list":["post-863","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-compliance-regulatory","category-fcc-compliance-for-usa-traffic","tag-carrier-compliance","tag-cpni","tag-customer-privacy","tag-customer-proprietary-network-information","tag-data-breach","tag-data-protection","tag-enforcement-actions","tag-fcc-compliance","tag-legal-liabilities","tag-microtalk","tag-regulatory-scrutiny","tag-telecom-compliance","tag-telecom-regulation","tag-voice-service-provider"],"_links":{"self":[{"href":"https:\/\/microtalk.co.uk\/blog\/wp-json\/wp\/v2\/posts\/863","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/microtalk.co.uk\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/microtalk.co.uk\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/microtalk.co.uk\/blog\/wp-json\/wp\/v2\/users\/6"}],"replies":[{"embeddable":true,"href":"https:\/\/microtalk.co.uk\/blog\/wp-json\/wp\/v2\/comments?post=863"}],"version-history":[{"count":3,"href":"https:\/\/microtalk.co.uk\/blog\/wp-json\/wp\/v2\/posts\/863\/revisions"}],"predecessor-version":[{"id":867,"href":"https:\/\/microtalk.co.uk\/blog\/wp-json\/wp\/v2\/posts\/863\/revisions\/867"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/microtalk.co.uk\/blog\/wp-json\/wp\/v2\/media\/864"}],"wp:attachment":[{"href":"https:\/\/microtalk.co.uk\/blog\/wp-json\/wp\/v2\/media?parent=863"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/microtalk.co.uk\/blog\/wp-json\/wp\/v2\/categories?post=863"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/microtalk.co.uk\/blog\/wp-json\/wp\/v2\/tags?post=863"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}