In its January 2025 Robocall Mitigation Database Report and Order (“R&O”), the Federal Communications Commission revised its rules and requirements regarding RMD plans. On January 22, 2026, the FCC's Wireline Competition Bureau issued a Public Notice announcing that the first annual recertification of a provider's plan in the RMD database must be completed by March 1, 2026.
Pursuant to the 2025 R&O:
- Any change in information contained in an RMD plan must be reported to the FCC within 10 business days of the change.
- The FCC may assess a base forfeiture amount of $10,000.00 for submitting false or inaccurate information to the RMD; and a base forfeiture of $1,000.00 for failure to update information that has changed in the RMD. Forfeitures will be assessed daily up to the statutory maximum for continuing violations.
- The FCC established a dedicated reporting mechanism for state and local regulators and attorneys general, consumers, public interest groups, providers, and others to report to the FCC on a deficient RMD plan.
- An annual RMD plan recertification filing is due no later than March 1st of each year. A filing fee of $100 per recertification applies. The fee requirement, however, is not currently in effect until the FCC provides further guidance.
- The FCC's red-light rules apply to RMD plan filings when a party owes a non-tax debt to the FCC.
The recent Public Notice includes a list of answers to FAQ's regarding the FCC's robocall and RMD plan rules and practices.

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