All voice service providers and intermediate providers, including gateway providers, are required to file recertifications in the Federal Communications Commission’s (FCC) Robocall Mitigation Database (RMD) by March 1, 2026.

To recertify, providers that have previously filed in the RMD must verify that the information contained in their RMD filings is accurate and truthful, including with respect to the certifications required by the Commission’s rules.  To submit the required Annual Recertification during, you must log on here and begin recertification by clicking the “Recertify” button.

On January 22, 2026, the FCC released a Public Notice announcing the effective date of new RMD rules and established the inaugural filing window deadline for annual recertifications of RMD filings.  The Public Notice also announced that the Office of Management and Budget (OMB) approved several of the proposed rule changes in the 2025 Robocall Mitigation Database Report and Order which became effective February 5, 2026.  This includes a new penalty for providers that fail to make updates to their RMD information within 10 days of any change, a higher base forfeiture for providers filing false or inaccurate information, the establishment of multi-factor authentication for the RMD, and a requirement for any entity that has an FCC Registration Number (FRN) to update its registration information in the FCC’s Commission Registration System (CORES) within 10 business days of a change.  The requirement for providers to submit an application fee with the recertification is not yet effective as it is pending further review by OMB.

A “Frequently Asked Questions” document to assist providers in complying with the Commission's RMD requirements is available here and RMD filing instructions are available here.

If you would like assistance with your RMD recertification or have questions about your robocall obligations, please contact one of the authors.