State AG Webinar: What We Learned About … Robocall Enforcement

On September 23, 2026, representatives from three state attorneys general offices joined Kelley Drye for a webinar focused on the enforcement activities of the multistate Anti-Robocall Litigation Task Force. The panelists, including Tracy Nayer, Special Deputy Attorney General from the North Carolina Department of Justice, Erin B. Leahy, Senior Assistant Attorney General from the Ohio Attorney General’s Office, and Michel Singer Nelson, Senior Assistant Attorney General from the Colorado Attorney General’s Office, offered a detailed look of their personal views on robocall-related state law enforcement work. Here is what we learned from our guest speakers.

History of the Anti-Robocall Litigation Task Force

Robocalls remain among the most common consumer complaints received by state AG offices nationwide. The Anti-Robocall Litigation Task Force is a 51-member bipartisan collective of 50 states and the District of Columbia, co-led by North Carolina, Indiana, and Ohio. It focuses on investigating and pursuing enforcement actions against entities identified as being responsible for significant volumes of illegal and fraudulent call and messaging traffic.

The Task Force builds on strategic partnerships with federal counterparts, including the FCC, FTC, U.S. DOJ, and the SSA Office of the Inspector General, as well as industry members such as voice service providers and U.S. Telecom’s Industry Traceback Group (ITG), which has been designated by the FCC since 2020 as the registered consortium conducting private-led call traceback efforts. Its public-facing work includes notice letters to industry members, enforcement actions, engagement with industry, and advocacy related to regulatory and legislative reforms.

Enforcement Authority for State AGs

In addition to individual state laws, state AGs can bring enforcement actions under numerous federal laws and regulations which provide for concurrent federal and state jurisdiction. Three such laws and regulations are particularly relevant to the Task Force’s work: the Truth in Caller ID Act, the Telephone Consumer Protection Act (TCPA), and the FTC’s Telemarketing Sales Rule (TSR). Because these federal laws and regulations do not preempt state law, businesses must also consider applicable state consumer protection and telemarketing laws, including the registration requirements imposed by approximately 33 states on telephone solicitors, which may impose additional or more restrictive requirements. 

Recent and Ongoing Task Force Activity

The work of the Anti-Robocall Litigation Task Force is multifaceted. Examples of recent activity include: 

• Multistate Litigation. As one example of collaboration among states on robocall enforcement, 49 state AGs joined together to file a lawsuit in 2023 against Avid Telecom and its principals. The case alleges violations of the TSR’s assisting-and-facilitating provision, the TCPA (including a first-of-its-kind cause of action for failure to exercise due diligence in vetting customers under the FCC’s newer rules), the Truth in Caller ID Act, and the consumer protection laws of 11 states. The case is currently pending. 
• FCC Comments. State AGs have recently filed written comments in several ongoing FCC rulemaking proceedings aimed at addressing robocall traffic issues at all points in the “call path.” In one proceeding on numbering resources, state AGs urged the FCC to expand certification and disclosure obligations to all voice service providers, implement enhanced reporting and tracing of number use (particularly by resellers), prohibit the practice of number cycling, and restrict the use of trial numbers. In another proceeding related to “know your customer” (KYC) rules for voice service providers, state AGs expressed support for more rigorous KYC standards, including for smaller providers, and enhanced scrutiny and monitoring obligations for certain high-risk customers. Most recently, in a proceeding focused on “know your upstream provider” (KYUP) requirements, state AGs called for strengthened KYUP obligations and expanded responsibilities for the STIR/SHAKEN Governance Authority to protect against bad actors improperly obtaining authorization to provide false trust to call traffic. 
• Task Force Notice Letters. In recent years, dozens of notice letters have been sent on behalf of the Task Force to voice service providers that were non-responsive to traceback notices or had deficient or non-existent filings in the FCC’s Robocall Mitigation Database (RMD), with copies also sent to downstream providers that were named in the notices as having accepted traffic directly from the target providers. Following those notice letters, the number of targets identified as non-responsive to traceback notices fell significantly, and several targets no longer appear in the call path of suspicious traffic. In addition, the FCC took action against numerous recipients, including orders addressing deficient RMD filings or removal from the RMD altogether.
• 2026 NAAG Robocall Summit. In August 2026, the National Association of Attorneys General Robocall Summit brought together law enforcement and industry for collaborative discussion. Key topics included KYC standards (and the wide range of practices currently in place across the industry), as well as the use of STIR/SHAKEN call authentication data, not only for its original purpose of verifying caller identity, but also to analyze concerning patterns in network traffic. 

AI in the Calling Context

On the topic of AI in the context of robocalls, panelists discussed the FCC’s 2024 declaratory ruling indicating that AI-generated calls fall within the category of pre-recorded or artificial voice. They commented that the existing legal framework applies and obligations to comply with the rules remain “unchanged” with respect to AI-generated calls. 

Takeaways and Considerations for Businesses

The panelists closed with several key messages for industry participants, including urging providers to appropriately weigh the risks of noncompliance with applicable laws and regulations, take a proactive approach to robocall mitigation, and carefully scrutinize upstream consent claims. 

Until consumer complaints subside, robocalls will remain a significant enforcement priority for AG offices across the country. As state and federal regulators continue to leverage both existing authorities and new industry obligations, businesses should proactively evaluate their practices, vendor relationships, and compliance controls and ensure their compliance programs are keeping pace with evolving enforcement expectations.

The recorded webinar can be viewed here.