The Robocall Mitigation Database: What It Means for Your SIP Trunk

What the Robocall Mitigation Database Is

The FCC established the Robocall Mitigation Database (RMD) as part of its TRACED Act implementation. The RMD is a public registry where all US voice service providers must certify their approach to preventing illegal robocalls. Providers fall into one of three categories:

Full STIR/SHAKEN implementation. The provider can cryptographically sign all IP calls and has completed STIR/SHAKEN deployment across its network. This is the standard certification for any modern SIP-based carrier.

Partial implementation with a mitigation program. The provider has implemented STIR/SHAKEN for some of its traffic but has documented a program covering the portions it cannot yet sign — typically legacy TDM interconnects, rural carriers, or international gateways.

Mitigation program only. The provider cannot implement STIR/SHAKEN (usually because it operates exclusively on TDM infrastructure) and instead files a robocall mitigation program describing its policies, processes, and technical controls for preventing illegal traffic.

The FCC requires gateway providers — carriers that receive traffic from foreign networks and route it onto the US PSTN — to actively block calls from providers not listed in the RMD. This is the mechanism that makes the database consequential: if your originating carrier's upstream provider cannot find them in the RMD with an acceptable filing, your calls get blocked at the gateway.

How to Look Up Your Provider's Filing Status

The RMD is publicly accessible at fcc.gov/rmd. You search by provider name or RBN (Robocall Registry Business Name). The database shows the provider's certification type, filing date, and last update. For any SIP trunking provider you are evaluating or currently using for US outbound traffic, a five-minute check tells you whether they have a full STIR/SHAKEN certification or a mitigation-only filing.

A mitigation-only filing is not automatically disqualifying, but it warrants a direct question to the provider: which portions of their network are covered by STIR/SHAKEN, and what is the traffic path for your outbound calls? If your calls are originating on a signed SIP path, a mitigation filing for legacy portions of their network does not affect you. If your calls are transiting the unsigned portion, you have a problem.

The Gateway Blocking Rule and Why It Matters

US gateway providers are required to block calls from providers not in the database. "Block" in this context means the gateway drops the call before it reaches the US PSTN — there is no ring, no voicemail, no busy signal. The call simply does not complete.

This rule was designed for international robocall traffic: overseas operations that originate massive call volumes, transit through gateway providers, and appear on US handsets. In practice, any provider with incomplete RMD registration is exposed, including domestic providers that missed a filing deadline or let their certification lapse.

For outbound call centers routing US traffic through a wholesale SIP provider, the question is not just whether your direct provider is in the database — it is whether every carrier in your call path is registered. If your provider re-routes traffic through an intermediary, that intermediary's registration status matters too.

UnlimCall's network routes US and Canadian traffic directly. There is no intermediary reseller chain with opaque registration status between your calls and the PSTN.

What Happens When a Provider Falls Out of Compliance

The FCC has enforcement authority to require gateway providers to block traffic from non-compliant originators. There have been published enforcement actions against specific providers, and the FCC has signaled that it will continue to use the gateway blocking mechanism as its primary enforcement tool.

For your outbound operation, provider non-compliance means call delivery interruption. You may not notice immediately — some gateway providers issue a grace period or a warning before blocking. Others block without notice. If your answer rates drop sharply over 24–48 hours with no change to your lists, dialing window, or campaign parameters, your provider's RMD status is worth checking.

The practical exposure is highest for operations running high call volumes to US and Canadian mobile numbers — the traffic that gets scrutinized most aggressively by the major carriers' analytics systems.

STIR/SHAKEN Filing vs. STIR/SHAKEN on Your Specific Calls

A provider can have a full STIR/SHAKEN certification in the RMD and still sign your specific calls at B-level. The RMD filing certifies the provider's infrastructure and program. The attestation level on individual calls depends on whether the provider controls the specific numbers you are presenting.

This is why the two questions are separate: "Is my provider in the RMD with a full certification?" and "What attestation level will they assign to my calls?" A yes to the first question does not guarantee A-level on the second. Both questions matter. The attestation level breakdown at UnlimCall's STIR/SHAKEN comparison guide covers this distinction in detail.