Attorneys General Urge FCC to Bolster Rules Against Unlawful Robocalls

Maryland Attorney General Anthony G. Brown has joined a significant bipartisan coalition of 48 state attorneys general in a push to strengthen federal regulations aimed at curtailing illegal robocalls. The group is urging the Federal Communications Commission (FCC) to enhance its “Know Your Upstream Provider” (KYUP) rules, a critical component in preventing scammers from exploiting U.S. phone networks. These rules require voice service providers to implement measures to ensure they are receiving calls from legitimate and responsible entities, thereby preventing the transmission of unlawful robocalls.

The journey of a phone call often involves a series of telecommunications companies before reaching its destination. Current FCC mandates require all voice service providers to exercise due diligence in vetting the companies that originate and route calls. However, the attorneys general argue that some providers are failing to adequately perform these checks, inadvertently allowing illegal robocalls to infiltrate the nation’s communication infrastructure. Last year alone, Americans were inundated with over 29.6 billion scam robocalls and texts, resulting in nearly $2 billion lost to these fraudulent schemes. The coalition is advocating for enhanced scrutiny and diligence from voice service providers regarding their upstream provider customers, including the rigorous vetting processes associated with the STIR/SHAKEN framework designed to combat caller ID spoofing.

The attorneys general have outlined several specific actions they want the FCC to take beyond its current initiatives. They are calling for the mandating of five categories of baseline KYUP measures, which would involve voice service providers collecting more detailed and verified information from their upstream provider customers. Furthermore, they urge the FCC to require more thorough vetting of upstream providers’ adherence to FCC regulations, ongoing monitoring of these providers, and the termination of services for those found to be in violation of the law. The coalition also seeks to institute additional triggers for KYUP monitoring. Presently, providers typically review upstream provider information only when entering into new agreements, renewing existing ones, or upon receiving evidence of a potential violation. The attorneys general contend that more regular monitoring is necessary to proactively identify and address bad actors operating without oversight.

In addition to these KYUP enhancements, the attorneys general are pushing for strengthened STIR/SHAKEN protections. This framework is designed to authenticate callers and ensure they are using legitimate phone numbers, thereby preventing spoofing. The coalition is urging the FCC to ensure that all providers, irrespective of their position in the call routing process, are aware of and comply with caller ID authentication obligations. The attorneys general also stressed the importance of rapid implementation of any new rules, the establishment of clear enforcement penalties for non-compliance, and the mandatory retention of KYUP data. They advocate for prompt adoption of regulations to curb illegal robocalls and support the imposition of penalties for providers who fail to meet upstream provider monitoring requirements or violate STIR/SHAKEN protocols. Moreover, they are requesting that voice service providers be required to collect and maintain data related to KYUP verification and monitoring, making this information accessible to attorneys general and other law enforcement agencies for future investigations.

Attorney General Brown is an active participant in the Anti-Robocall Multistate Litigation Task Force, which initiated “Operation Robocall Roundup” in 2025. The first phase of this operation saw the task force issue warning letters to 37 smaller voice providers for allegedly neglecting their responsibilities in mitigating the origination and transmission of unlawful robocalls by not adhering to FCC mandates. Just two weeks prior to this announcement, the FCC issued an order targeting six of these companies, demanding they rectify their robocall protection deficiencies or face potential revocation of their ability to route calls through the U.S. telephone network. The second phase of the task force’s efforts has broadened its focus to include four of the nation’s largest intermediate voice service providers. This phase also includes advocating for the FCC to strengthen its “Know Your Customer” rules, compelling phone companies to verify the identity of those using their networks and the nature of their business operations.

Article by Mel Anara, based upon information from the Maryland Attorney General’s Office.

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