RMD & STIR/SHAKEN: What Every Voice Platform Buyer Needs to Know in 2026
A quick guide for AI voice-agent platforms, CPaaS resellers, and anyone buying US call termination — not for telecom lawyers.
You don't need to become a compliance expert to buy termination safely. But three concepts now directly affect whether your calls get answered, flagged, or blocked — and most buyers have never had them explained outside a legal memo. Here's the plain-English version.
1. The Robocall Mitigation Database (RMD) — the on/off switch for the phone network
Every provider that touches a call — not just the carrier you pay — has to be listed in the FCC's RMD. If a provider isn't listed, or gets removed, everyone downstream is required to block their traffic.
Why you should care
In August 2025 the FCC removed over 1,300 providers from the RMD in a single order. If your termination provider — or their upstream — gets removed, your calls can stop connecting overnight, with no warning and no fault of your own.
What to ask your provider
“Are you currently RMD-listed, and can you show me the filing?” A provider that can answer this in one sentence, with evidence, is a safer bet than one that says “yes, of course” and stops there.
2. STIR/SHAKEN attestation — why your caller ID either builds trust or gets you flagged
STIR/SHAKEN is how carriers cryptographically sign calls to prove who's really calling. Every call gets one of three attestation levels:
The carrier knows you and verifies you have the right to use that calling number. This is what you want for your outbound traffic.
The carrier knows you, but hasn't verified the number itself.
No real relationship with the originator (typically inbound international traffic funneled through a US gateway).
Why you should care
As of September 18, 2025, providers must sign with their own certificate and make their own attestation decisions — they can no longer just borrow an upstream's trust. A provider that over-attests gets penalized by downstream carrier analytics over time — and so does your traffic, if it's riding on their network.
What to ask your provider
“Do you sign with your own SPC token and certificate, or an upstream's?” If it's the latter, that's now a compliance violation on their end — and a stability risk on yours.
3. Gateway providers, traceback, and why a slow response becomes your problem
If illegal or suspicious traffic gets traced back to a network, the Industry Traceback Group (ITG) sends a request. Providers have to respond — 24 hours for gateway providers, “reasonable time” for others. Ignore it, and the cascade is: traceback → RMD deficiency → removal from the RMD → mandatory blocking by everyone downstream → effective disconnection from the US phone network.
Why you should care
This isn't hypothetical anymore. A provider was hit with a $4.5M proposed FCC forfeiture in 2026 for exactly this failure mode — passing unvetted traffic that spoofed major bank caller IDs. If your termination provider is slow to respond to traceback, or doesn't vet who they buy from, that risk sits one layer upstream of you — but it still lands on your calls.
What to ask your provider
“What's your traceback response SLA, and is it contractual?” 24 hours, in writing, is the standard to look for.
What this means for you, concretely
If you're an AI voice platform, CPaaS reseller, or BPO buying US termination:
- Ask for evidence, not assurances — current RMD listing, own STIR/SHAKEN certificate, contractual traceback SLA.
- Ask for real route data — ASR, ACD, PDD, MOS per destination, not just a rate card.
- Consider a second, independently compliant route — if your primary upstream has a bad day, a redundant path keeps your calls flowing.
- Run a short pilot before committing volume — 48–72 hours on a defined route set is enough to see real ASR/ACD/PDD and clean CDRs before you scale up.
The short version
A termination provider's compliance posture isn't a legal footnote — it's a leading indicator of whether your calls keep getting answered. The providers worth trusting can answer these questions in one sentence, with evidence, not a sales pitch.
Ready to verify a route before you commit volume?
This guide is for buyer education and general understanding — not legal advice. Regulatory status changes; verify current FCC requirements before relying on any compliance representation in a contract.