FCC Proposes Major Changes to Robocall Rules

On Oct. 29, the Federal Communications Commission (FCC) unanimously adopted the Improving Verification and Presentation of Caller Identification Information Further Notice of Proposed Rulemaking (“FNPRM”). The FNPRM addresses three main areas: (1) the adoption of a framework to present the caller’s name on consumers’ phones; (2) new regulations of calls originating from other countries; and (3) changes to the Telephone Consumer Protection Act (TCPA) rules, including revocation of consent. If the proposed changes are adopted, the FNPRM marks one of the biggest changes to caller identification and robocall rules in decades. This alert outlines the key proposals under consideration.

Mandating Caller Identity Information to Help Consumers

The first part of the FNPRM discusses the adoption of a framework that would enable businesses to have their name and other information displayed on the called party’s phone. For example, if a consumer’s bank was calling, the name of the bank would appear as well as a reason for the call, such as alerting the consumer to fraud. The FCC is exploring Rich Call Data (RCD), a technical standard for the secure transmission of caller identity information. RCD builds on the STIR/SHAKEN framework and uses encryption to transmit vetted caller identity information like name, photo, logo, email, location, title and call purpose from the originating provider to the terminating provider over IP networks. STIR/SHAKEN is a framework designed to help ensure that a company making a call is authorized to use the telephone number that shows up on the caller ID, but it does not provide information about who is actually calling.

Including caller identity information has been shown to dramatically improve call answer rates and can help restore trust in the network. A handful of companies provide a form of branded calling, but there are no uniform rules and the proprietary solutions can be expensive.

For this proposal to meaningfully help consumers, caller identity information must be accurate and trustworthy. The FNPRM would require the telephone companies serving the calling party, such as a business calling its customers, to take steps to ensure that the caller identity information is accurate. For example, telephone companies should exercise know-your-customer due diligence. Alternatively, the FNPRM asks if third parties should vet the calling party’s information. The FCC also asks if there are circumstances where, out of privacy concerns, a caller would not want this information displayed.

Additionally, the FCC is examining the impact of this proposal on people with disabilities who use assistive technologies, such as braille readers, TTYs or built-in accessibility features.

Securely Transmitting Caller ID Information

The FNPRM requests comment on how to ensure caller identity information is securely transmitted from the originating provider to the terminating provider, including whether to mandate the use of RCD standards. The agency emphasizes that if caller identity data is altered or tampered with during transmission, the originating provider’s verification efforts will be ineffective, potentially exposing consumers to fraud. Key questions include whether secure transmission is essential to prevent manipulation by bad actors and whether alternative methods exist to safeguard the integrity of caller identity data. The FCC also asks whether additional legal requirements or consumer benefits support securing this information throughout the call path.

The FNPRM is also seeking input on how voice service providers can verify caller identity when they do not have a direct relationship with the caller, like when the caller is a customer of a reseller. It seeks comment on removing the exemption from implementing STIR/SHAKEN for providers lacking control of the network control infrastructure needed to implement that framework. The commission also asks how these changes would work in practice and whether alternative methods could maintain the integrity of the framework in such indirect scenarios, including cases involving toll-free numbers or layered provider relationships.

Finally, the FCC is asking whether alternatives to RCD should be utilized. As noted, there are several proprietary call branding solutions being offered, which may rely in part on RCD.

Calls Originating Outside the United States

The second part of the FNPRM seeks comment on new rules that would require voice service providers to identify and mark calls originating from outside the United States, and if the FCC should adopt a definition of “foreign-originated” for purposes of identifying these types of calls. Under this framework, gateway providers would be responsible for labeling foreign-originated calls, intermediate providers would be required to pass that information downstream and terminating providers would need to transmit an indicator to consumers’ handsets when they know or reasonably suspect a call is foreign-originated. The FCC is seeking public comment on the technical feasibility of these requirements, including whether gateway providers can reliably determine a call’s country of origin.

The FCC also proposes that foreign-origin status be incorporated into call-blocking analytics and requests input on which countries generate high volumes of fraudulent or unlawful calls. To help consumers recognize foreign-originated calls, the agency is considering whether a dedicated area code should be established and whether gateway providers should block foreign-originated calls using U.S. NANP numbers that fall outside any designated foreign-use area code.

Today, many foreign calls coming into the United States use U.S. numbers. For example, a company may use an offshore call center that uses the company’s U.S. number when calling a U.S.-based customer. The FCC asks whether it should ban this practice and whether such a ban could encourage job repatriation.

Revisions to TCPA Rules

The third part of the FNPRM proposes eliminating certain older rules and it seeks public comment on making changes to more recent rules that might be harmful to consumers.

• Consent Revocation Rules

The FNPRM seeks public comment on ways the FCC can modify two key rules under the Telephone Consumer Protection Act (TCPA) related to how consumers revoke consent to receive calls or texts. Starting in April 2026, without further modification, if a consumer opts out of one type of communication from a caller, that revocation applies to all future calls or texts from that caller, even if they concern unrelated matters. The FCC is now asking if the revoke-all rule unduly restricts consumers’ ability to receive wanted calls, such as appointment reminders or account alerts from health care providers, pharmacies, banks or businesses with multiple service lines. The FCC requests public comment on ways that it can modify the rule so that consumers continue to receive the calls they want while also ensuring that callers honor consent revocation from other consumers. The FCC delegated to the bureau the issue of extending the April 2026 deadline.

Additionally, the FCC is considering whether to allow businesses to prescribe a reasonable method of revoking consent. Currently, consumers can revoke consent through any “reasonable means.” Some stakeholders have suggested allowing callers to designate a specific method for revoking consent to reduce ambiguity and streamline compliance. The FCC is seeking input on whether less restrictive alternatives exist, what revocation methods should be required or prohibited, and how to ensure consumers are clearly informed of their options. The agency is also interested in whether complex revocation procedures might discourage consumers from exercising their rights and whether rule changes could improve clarity and efficiency for both consumers and businesses.

• Fraud Alert Call Rules

The FNPRM seeks public comment on eliminating its current rule that restricts financial institutions to contacting only the phone number provided by the consumer when making fraud alert or similar calls under an exception to the TCPA’s consent requirements. The agency believes this limitation may hinder the timely delivery of critical fraud-related messages that help protect consumers’ financial accounts. To evaluate the potential impact, the FCC is seeking public input on whether broadening the rule could lead to misdirected calls or unauthorized disclosure of sensitive financial information. It also asks whether the ability of institutions to obtain prior express consent sufficiently mitigates these risks. Additionally, the FCC is exploring whether this proposal should be aligned with other federal or state laws and industry best practices. Ultimately, the agency wants to understand whether increased flexibility would enhance fraud prevention and consumer protection and how to balance that benefit against the risk of unintended disclosures.

• Call Abandonment Rules

The FNPRM seeks public comment on eliminating the FCC’s call abandonment rules, which currently prohibit telemarketers from disconnecting unanswered calls before 15 seconds or four rings and limit abandoned calls to no more than 3% of telemarketing calls. These rules were originally adopted under the Do-Not-Call Implementation Act (DNC Act) to align FCC regulations with the FTC’s Telemarketing Sales Rule (TSR), which still contains similar provisions.

• Artificial and Prerecorded Voice Caller ID Rules

The FCC is proposing to amend its caller identification rule for artificial and prerecorded voice calls. Currently, callers must provide a callback number that avoids premium-rate charges and, for telemarketing calls to residential numbers, must accept Do-Not-Call (DNC) requests during business hours. Recognizing that traditional distinctions between local and long-distance charges are largely obsolete, the FCC suggests streamlining the rule to simply require that callers identify themselves with a valid telephone number that allows consumers to recognize who is calling.

• Company-Specific Do-Not-Call Rules Unchanged

The draft version of the NPRM released several weeks ago included a proposal eliminating the FCC’s company-specific Do-Not-Call (DNC) rules, which currently require telemarketers to maintain internal lists of consumers who directly request not to be called. However, the proposal was not included in the FNPRM.

Next Steps

Public comments are due 30 days after the FNPRM is published in the Federal Register. Due to the ongoing federal government shutdown, publication might be delayed. Reply comments will be due 60 days after the date of publication in the Federal Register. Please contact the authors of this alert if you are interested in submitting a comment.