Free template

Robocall Mitigation Plan Template

A section-by-section outline for voice providers preparing or updating their Robocall Mitigation Database filing. The FCC has removed more than 1,400 providers from the RMD since January 2025, often for vague plans that list no concrete steps. Use this checklist to make every section specific.

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This template is general guidance, not legal advice. Check the current FCC rules and talk to your regulatory counsel before filing.

1. Provider identification

Who you are, as the FCC and other providers will see you in the Robocall Mitigation Database (RMD).

Legal business name, all trade names (DBAs) and FCC Registration Number (FRN)
Provider role(s): originating, intermediate, gateway, terminating, non-gateway intermediate
Principals, affiliates and any parent company; foreign ownership, if any
Robocall mitigation point of contact (name, title, phone, email) reachable for tracebacks

2. STIR/SHAKEN implementation status

State exactly where you sign and where you rely on others.

Full, partial or no STIR/SHAKEN implementation, with the reason for any gap
Own SPC token, or third-party signing (name the vendor — you remain responsible)
How you assign A, B and C attestation, with examples for each
Non-IP segments of your network and the caller-ID authentication used there

3. Know Your Customer (KYC)

The specific checks done before a customer can originate traffic.

Identity and business verification collected at onboarding (documents, FRN, RMD lookup)
How you confirm a customer's right to use each number they present
Higher-risk signals that trigger extra review (new entity, prepaid, high volume, short calls)
How often existing customers are re-verified

4. Know Your Upstream Provider

How you vet the carriers that hand you traffic.

Confirm every upstream provider is listed in the RMD before accepting traffic
Weekly check of upstream providers against FCC removal and blocking orders
Contract terms requiring cooperation with tracebacks and lawful robocall practices
Steps taken when an upstream provider is removed (block within the FCC deadline)

5. Detecting and stopping illegal traffic

Concrete, reasonable steps — not general promises.

Traffic analytics used: short-duration calls, answer-seizure ratio, call bursts, spoofed ANI
Do Not Originate (DNO) list and invalid / unallocated number blocking
Real-time content or behavior analysis for fraud and impersonation calls
Who reviews alerts, within what time, and what action follows

6. Traceback cooperation

How fast and how completely you respond.

Commitment to answer Industry Traceback Group (ITG) requests within 24 hours
Who receives and answers traceback requests, with a backup person
Records kept (CDRs, customer details) and how long they are retained
Actions taken against a customer identified in a traceback

7. Review and recertification

Keep the filing accurate — out-of-date filings are a common removal reason.

Date of last plan update and who approved it
Commitment to update the RMD within 10 business days of any change
Annual recertification date and owner
Disclosure of any investigation, enforcement action or traceback history

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