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On February 20, 2026, the FCC's Enforcement Bureau released Enforcement Advisory No. 2026-02 (DA 26-174), underscoring that Mobile Virtual Network Operators (MVNOs) are fully subject to the Commission's Robocall Mitigation Database (RMD) and related robocall compliance obligations.
The Advisory serves as a pointed reminder that MVNOs offering voice services—despite not owning underlying transmission facilities—are considered "voice service providers" under the FCC's rules and must independently comply with robocall mitigation requirements.
Who Is Affected
The Advisory applies to MVNOs and other resellers providing interconnected voice services. The FCC makes clear that these providers may not rely solely on underlying carriers for compliance. Independent obligations apply.
Key Compliance Requirements
The Enforcement Bureau reiterated that covered providers must:
- File and maintain an accurate certification in the Robocall Mitigation Database.
- Describe their STIR/SHAKEN implementation status and/or robocall mitigation program.
- Maintain and implement a robocall mitigation plan, including meaningful Know-Your-Customer (KYC) procedures.
- Respond to traceback requests from the FCC, law enforcement, and the designated traceback consortium within 24 hours.
- Recertify their RMD filings annually (with the next recertification deadline approaching March 1, 2026).
The Bureau emphasized that inaccurate filings, failure to file, or failure to respond to traceback requests may result in removal from the RMD, blocking by downstream providers, monetary forfeitures, and additional enforcement action.
Practical Considerations
MVNOs should review their compliance posture promptly. In our experience, risk often arises not from the absence of policies on paper, but from weaknesses in KYC diligence, traffic monitoring, vendor oversight, numbering authorization, VoIP waiver compliance, and documentation supporting mitigation decisions.
Given the increasingly aggressive enforcement environment, providers should also anticipate heightened scrutiny from state attorneys general, consumer protection authorities, and private litigants.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
