HWG LLP Client Advisory (PDF)
By Kristine Devine and Amy C. Robinson
On September 2, 2026, the FCC’s Consumer and Governmental Affairs Bureau (CGB) released a Public Notice seeking comment on a new public-facing “robocall mitigation scorecard” that would rate voice service providers on their efforts to protect consumers from illegal robocalls. The Public Notice seeks comment on the design and implementation of the scorecard. The proposal is the latest in a series of FCC initiatives aimed at strengthening call authentication and robocall mitigation. Comments are due September 22, 2026, and reply comments are due October 2, 2026.
A Consumer-Facing Measure of Robocall Mitigation
The proposed scorecard would provide consumers with an easy-to-understand means of comparing voice service providers’ efforts to protect customers from illegal robocalls. CGB emphasizes that the proceeding would not establish new regulatory requirements or determine whether individual providers comply with the FCC’s robocall rules. Instead, the FCC would use existing information to create a comparative, public-facing assessment of provider performance.
CGB proposes focusing on domestic voice service providers with retail customers, including wireless, wireline, and Voice over Internet Protocol (VoIP) providers, while excluding wholesale-only and intermediate providers. The Bureau seeks comment on whether to rate all retail providers or focus on larger providers that collectively serve most of the retail market.
How Would Providers Be Rated?
Potential data sources include Robocall Mitigation Database (RMD) filings, provider blocking practices and consumer tools, FCC and FTC complaint data, FCC enforcement actions, Industry Traceback Group data, and third-party or industry sources.
CGB is considering including on the scorecard both conduct-based metrics (e.g., blocking and labeling practices, traceback responses, and STIR/SHAKEN attestation practices) and outcome-based metrics (e.g., consumer complaints, blocking and false-positive rates, and trends in illegal robocalls reaching subscribers). The Bureau also seeks comment on whether providers should receive numerical scores, letter grades, or performance tiers and whether providers should be able to review and challenge underlying data.
Part of the FCC’s Broader Robocall Agenda
The scorecard is part of a broader FCC effort to address illegal calls at multiple points in the call path. The Commission is simultaneously pursuing changes to its Know-Your-Upstream-Provider (KYUP) requirements, Know-Your-Customer (KYC) requirements, numbering polices, and call branding framework, among other initiatives intended to strengthen provider accountability and prevent illegal traffic from entering and traversing U.S. networks.
The scorecard would add a new dimension to these efforts. Rather than imposing substantive robocall requirements, it could use information generated through existing authentication, mitigation, complaint, and enforcement regimes to publicly compare providers. Thus, information that previously served principally regulatory or enforcement purposes could also affect how a provider is portrayed to customers and the broader public.
Comments are due September 22, 2026, and reply comments are due October 2, 2026, in CG Docket No. 26-239.