FCC Proposes New Numbering Policies to Combat Illegal Robocalls

At its March 2026 Open Meeting, the FCC adopted a Notice of Proposed Rulemaking (NPRM) proposing changes to its telephone numbering policies. The changes are aimed at making it harder for bad actors to obtain and exploit numbering resources to make illegal robocalls. The NPRM builds on the Commission’s Third VoIP Direct Access Report and Order, which extended robocall certification and disclosure requirements to all existing interconnected VoIP direct access authorization holders. (For more on that action, see our blog post.) The new proposals would significantly expand the scope of providers subject to these numbering resource compliance obligations and introduce enhanced reporting and resale restrictions designed to increase transparency and prevent illegal robocallers from obtaining numbers.

As Chairman Carr explained, the Commission is “taking a new approach to combating illegal robocalls by tackling the problem at every point of the call path.” He emphasized that the Commission is taking this novel approach to robocall mitigation because the Enforcement Bureau “has found that the majority of its robocall investigations have involved resold numbers,” underscoring the need to scrutinize how bad actors obtain numbering resources. Commissioner Trusty similarly noted that the NPRM “appropriately seeks comment on actions the FCC can take to better align industry practices with accountability and transparency, and to close gaps that bad actors exploit to avoid oversight.”

Expanding Certification and Disclosure Requirements

The NPRM proposes to extend the robocall-related certification obligations currently applicable to interconnected VoIP providers applying for direct access to numbers to all voice service providers that receive numbering resources directly from the North American Numbering Plan Administrator (NANPA). The NPRM would also extend these obligations to resellers of telephone numbers. Covered providers and resellers would be required to make a one-time filing certifying that they will not knowingly facilitate illegal robocalls, illegal spoofing, or fraud, and that they have complied with all applicable STIR/SHAKEN, robocall mitigation, and foreign ownership reporting requirements — all under penalty of perjury.

“Resellers of telephone numbers” would be defined broadly to include LECs, CMRS providers, and interconnected VoIP providers that resell services, including geographic numbering resources, with exceptions for Video Relay and IP Relay Service.

Enhancing Wholesale Reporting Requirements

The NPRM also proposes substantial modifications to the Numbering Resource Utilization/Forecast (NRUF) reporting framework. To improve transparency, the proposed rules would require wholesale providers to identify each reseller by legal name, contact information, and FCC Form 499 Filer ID. The Commission also seeks comment on whether resellers should file their own NRUF reports.

Limiting Resale to a Single Level

The NPRM seeks comment on whether to prohibit the resale of numbers beyond a single level, recognizing that multilevel resale frequently masks the parties involved in illegal robocall schemes. Under this approach, resellers could only serve their own end users and could not further wholesale numbers. The Commission also asks whether both the originating provider and the reseller should be held jointly and severally liable for violations of its robocalling rules.

Addressing Number Cycling

The NPRM also seeks comment on “number cycling” — the practice of churning through large quantities of telephone numbers, often on a single-use basis, to evade robocall detection. The Commission noted that cycled numbers can receive full STIR/SHAKEN attestation, effectively undermining authentication-based protections, and that some operations have used hundreds of millions of different numbers. The NPRM seeks input on how to define and potentially prohibit or limit the practice.

Other Proposals

In addition to the above, the NPRM seeks comment on several other measures, including:

• Expanding state commission access to provider-specific NRUF data, including out-of-state data, to better identify numbering abuse patterns.
• Delegating greater authority to state commissions to direct the NANPA to withhold numbering resources from noncompliant providers.
• Whether additional triggers, such as repeated tracebacks or suspected illegal traffic notifications, should justify withholding numbering resources.
• Whether other changes to numbering administration policy are warranted, given the “massive” quantities of numbers exploited in recent robocall campaigns.

Next Steps

The proposals, if adopted, could impose several new compliance obligations on a broad range of service providers and resellers. Stakeholders — including wireline carriers, wireless providers, interconnected VoIP providers, and entities that resell voice services with telephone numbers — should carefully evaluate the NPRM’s proposals.

Comments on the NPRM are due 30 days after publication in the Federal Register. Reply comments are due 60 days after publication.

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