Robocall Mitigation Database recertification: due March 1, every year
Since February 5, 2026, every provider with a filing in the Robocall Mitigation Database must certify each year, on or before March 1, that everything in it is true and correct. The next deadline is Monday, March 1, 2027. We prepare the recertification — and your CPNI certification, due the same day — for a fixed $790 a year. You review, sign and submit.
Last updated: September 2026
What 47 CFR § 64.6305(h) requires
“Annual Recertification Requirement. In accordance with this section and 47 CFR 1.16, all providers shall certify annually, on or before March 1, that any information submitted to the Robocall Mitigation Database is true and correct.”
47 CFR § 64.6305(h), eCFR text current as of September 24, 2026.
- Adopted in the FCC’s Report and Order FCC 24-135, published in the Federal Register on January 6, 2026 (91 FR 343). The recertification rule took effect February 5, 2026, and the first deadline was March 1, 2026 (91 FR 5242).
- The FCC’s filing instructions (July 2026) say the recertification window opens each year on February 1, the “Recertify” button appears only during that window, and a filing can be recertified only once per window.
- It is signed like an affidavit: an unsworn declaration under penalty of perjury, in the form set by 47 CFR § 1.16.
- It sits alongside a separate duty: updating your filing within 10 business days of any change (§ 64.6305(d)(5)). The two obligations run side by side all year.
If you miss it, or certify something untrue
The FCC said failure to recertify “will result in referral to the Enforcement Bureau, which may subject the filer to forfeiture or removal from the Database” (91 FR 348).
Since February 5, 2026, submitting false or inaccurate information to the Database carries a $10,000 base forfeiture per violation, and failing to update within 10 business days a $1,000 base forfeiture — both continuing violations until cured (47 CFR § 1.80(b)(11)).
Removal is the harshest outcome: once a filing is removed, every U.S. voice and intermediate provider must stop accepting calls directly from that provider (§ 64.6305(g); DA 26-174). On September 30, 2025 the Enforcement Bureau removed 12 providers for not answering tracebacks.
The twelve things we check against your current filing
We start from the public version of your filing in the Database and your questionnaire answers, and check each item against the current rule text and the FCC’s January 2026 filing guidance (DA 26-72).
- CORES name, address and contact are current — the RMD pulls them from CORES, and CORES must be updated within 10 business days of a change (§ 1.8002(b)(2))
- Business names, DBA names and previous names
- Principals, affiliates, subsidiaries and parent companies — at least one principal, who must be an individual
- Each role you play in the call chain, with one filing per FRN
- Your STIR/SHAKEN option for each role: Option 1 or 2 requires your own SPC token and certificate, even when a third party signs your calls; Option 2 or 3 requires the rule that exempts you and a detailed explanation
- The two-year formal action or investigation question, covering affiliates and principals
- Operating Company Number — only if you have one
- Your robocall mitigation contact: name, title, department, address, phone, email
- Know-your-customer description matches what onboarding really does, for new and renewing customers (§ 64.1200(n)(4))
- Upstream-provider procedures and the contract terms that back them (§ 64.1200(n)(5))
- Analytics: whether you use them, and the names of vendors or underlying providers you rely on
- The 24-hour traceback commitment and the procedure that makes it real (§ 64.1200(n)(1))
The certification options for complete and partial STIR/SHAKEN implementation changed with the FCC’s Eighth Caller ID Authentication Report and Order, effective September 18, 2025; the FCC asks recertifying providers to review their selections for each role against the modified rules (DA 26-72).
Annual Compliance Pack — $790 per year
- A written review of your current RMD filing against the current rules
- An updated robocall mitigation plan, in Word and PDF, ready to upload
- The recertification content, field by field, ready for the February 1 – March 1 window
- Your annual CPNI compliance certificate for your officer, its accompanying statement, and the data-broker and complaint statements (details on the CPNI page)
- A compliance calendar with email reminders
- One mid-year Change Update included (more at $150 each)
- One round of revisions on every deliverable
What we don’t do
- Submit the recertification for you — your company files it, and your officer signs
- Give legal advice or represent you before the FCC
- Implement STIR/SHAKEN, obtain SPC tokens or certificates
- Answer tracebacks or Enforcement Bureau letters on your behalf
- Prepare Form 499 filings or universal service contributions
We turn away providers whose business is high-volume unsolicited calling, and providers currently the subject of an FCC enforcement action or robocall-related investigation.
Recertification questions
Can we recertify early, in January?
No. The FCC’s filing instructions say the “Recertify” button appears only during the annual window that opens February 1, and a filing can be recertified only once per window. The deadline is March 1.
Nothing changed this year. Do we still have to recertify?
Yes. The rule applies to all providers with a filing, every year (§ 64.6305(h)). If nothing changed, the work is confirming that — line by line — before your officer signs.
We revised our filing in the fall. Does that count as the recertification?
No. A revision reports a change, which must be done within 10 business days of it (§ 64.6305(d)(5)). The annual recertification is a separate step, done through the “Recertify” action during the February 1 – March 1 window.
Who has to sign?
An officer of your company, in conformity with 47 CFR § 1.16 — an unsworn declaration under penalty of perjury. We prepare what the officer signs; we never sign it.
We’ve never filed at all. Is this the right page?
No — you need a first filing. See the New Provider RMD Filing ($490, one-time).
March 1 comes every year. Get it off your desk.
A fixed price and a delivery date, in writing. No call, no sales meeting. Send it tonight, read it in the morning.