STIR/SHAKEN and Robocall Mitigation Database filing deadlines

What’s happening?

STIR/SHAKEN is a robocall mitigation framework designed to reduce fraudulent robocalling and illegal phone number spoofing in the U.S. The deadline for STIR/SHAKEN compliance was June 30, 2021. Smaller providers (less than 100K subscribers) have an extension to June 30, 2022. 

The FCC has also launched the Robocall Mitigation Database (RMD) for service providers to formally register and confirm the status of their STIR/SHAKEN implementation. Service providers were required to complete their registration in the RMD by June 30, 2021. 

Important: The FCC has directed carriers and service providers to block calls they may receive, including internationally originated traffic, from voice service providers not registered in the RMD after September 28, 2021. 

Who’s impacted by STIR/SHAKEN and the upcoming deadlines?

Voice service providers routing traffic to or from US phone numbers, including internationally-based providers. 

What do I need to do? 

1. Register in the FCC’s RMD. Companies that have completed full STIR/SHAKEN implementation simply need to confirm this with their registration, while companies that do not have a full STIR/SHAKEN implementation will also need to include a Robocall Mitigation Plan. For more information on registration and how to appropriately confirm your STIR/SHAKEN implementation status, the Robocall Mitigation Database External Filing Instructions from the FCC can help guide you in this process.
2. Be prepared to manage network and traffic exchange arrangements with new carrier blocking behaviors in mind. 

What has Bandwidth done to prepare for STIR/SHAKEN?

Bandwidth deployed STIR/SHAKEN in our network in December 2019. Since then, we’ve completed STIR/SHAKEN interops with Verizon Wireless, Comcast, T-Mobile/Sprint, AT&T, Peerless, and more. 

We currently sign billions of calls each month on behalf of our global customers including Bandwidth International (formerly Voxbone) customers using U.S. numbers. In December, we were granted an exemption by the FCC in recognition of Bandwidth’s significant voluntary efforts to deploy STIR/SHAKEN well in advance of the Commission’s June 30, 2021 deadline. 

How is Bandwidth signing calls on behalf of its customers?

• Outbound calls from Bandwidth customers using Bandwidth U.S. phone numbers are signed with “A” or full attestation. 
• Outbound calls from Bandwidth customers using non-Bandwidth U.S. phone numbers are signed with “B” or partial attestation. 
• Bandwidth does not currently sign any calls with “C” or gateway attestation. 

We strongly recommend that our customers consult with legal counsel to determine if the above, combined with registering in the FCC's Robocall Mitigation Database, satisfies their regulatory requirements for STIR/SHAKEN. 

Want to learn more about STIR/SHAKEN and new features available with Bandwidth? Please see our full support article or contact your Account Manager. 

What if I’m signing my own calls for STIR/SHAKEN? 

Approved STIR/SHAKEN service providers who are authenticating and verifying their own traffic can use Bandwidth as an intermediate service provider at no charge. You can enable our Transit Identity Service directly in the Bandwidth Dashboard. Bandwidth will act as an intermediate service provider and convey the SIP header information for both inbound and outbound traffic.

Bandwidth International (formerly Voxbone) customers who are also approved STIR/SHAKEN service providers should contact their Account Manager or Customer Success Manager to migrate their accounts to the Bandwidth Dashboard in order to enable this service. 

Does Bandwidth provide the verification results on inbound traffic? 

U.S. Origination customers can now enable our Inbound Verification Service in the Bandwidth Dashboard. This feature provides STIR/SHAKEN verification results to service providers in order to make decisions to either block calls or terminate them to the end user.

A similar capability is currently in development for Bandwidth International customers and will be enabled in the Bandwidth International platform at the account level. Please contact your Account Manager or Customer Success Manager for more information. 

Some of my calls will be signed with “B”. Are they going to be blocked? 

Call blocking determinations are made in a number of different ways, including the use of proprietary call analytics services. While Bandwidth is focused on avoiding inappropriate blocking by downstream terminating providers, Bandwidth doesn't anticipate that signing calls with “B” will be the sole factor in such call blocking treatment. 

Nevertheless, in order to better ensure that false-positive blocking is minimized, Bandwidth is a strong proponent of Certificate Delegation. Certificate Delegation would allow our customers to reference a valid certificate from the owner of the phone number so that the call could be signed with “A” attestation. Bandwidth’s product team is currently working within ATIS to push for the adoption of the industry standard this year. 

In general, call delivery or blocking issues with a specific Bandwidth phone number or carrier should be reported to Bandwidth by opening a support ticket. Our Technical Assistance Center (TAC) will investigate and may be able to provide options to help address the problem with the specific terminating carrier. 

What else is Bandwidth planning for STIR/SHAKEN? 

Diversion

Features like call forwarding or the ability to ring multiple devices simultaneously change the destination called number and break the STIR/SHAKEN authentication process. The ATIS standard for “div” PASSporT allows service providers to confirm a call has been legitimately retargeted. Bandwidth is committed to implementing additional STIR/SHAKEN standards as they emerge.

STIR/SHAKEN Canada

Canada’s deadline for STIR/SHAKEN is November 2021. Please note that the certificates required to sign calls originating from Canadian providers are issued from different Certificate Authorities than in the U.S. Bandwidth is currently developing a solution to meet Canada’s deadline. 

Additional resources

• Understanding STIR/SHAKEN
• STIR/SHAKEN Resources