49 Attorneys General Urge FCC to Strengthen "Know Your Upstream Provider" Rules

The bottom line: state enforcers want carriers to do more vetting of the providers that send them traffic, on a regular schedule, with records to prove it.

Here is what happened

Calls pass through several carriers before they reach a consumer. FCC rules already require voice service providers to take reasonable steps to vet the providers that originate and route traffic to them. According to the attorneys general, some providers fail to do so, and illegal robocalls end up on the U.S. network as a result.

The press release states that Americans received more than 29.6 billion scam robocalls and texts last year and lost nearly $2 billion to these scams.

What the attorneys general asked for

The coalition asked the FCC to:

1. Mandate five categories of baseline KYUP measures, including collecting more detailed and verified information from upstream customers, vetting their compliance, monitoring them, and refusing or ending service to providers that do not follow the law.
2. Require monitoring more often than at contract signing, renewal, or after evidence of wrongdoing.
3. Strengthen STIR/SHAKEN protections. STIR/SHAKEN is the caller ID authentication framework designed to stop spoofing. The coalition wants the rules applied consistently to everyone in the call path.
4. Implement new rules quickly, set base penalties, and require providers to retain KYUP data for law enforcement.

Context

Michigan is part of the Anti-Robocall Multistate Litigation Task Force, which launched Operation Robocall Roundup in 2025. In phase 1, the task force sent warning letters to 37 smaller voice providers. The press release states that the FCC recently ordered six of these companies to fix their robocall mitigation issues or risk losing the ability to route calls across the U.S. network. In phase 2, the task force expanded to four of the country's largest intermediate providers.

These are comments asking for new rules. The FCC has not yet adopted them.

Why it matters

Upstream vetting is becoming an enforcement priority at both the state and federal level. If these proposals are adopted, carriers will need a documented, recurring process, not a one time onboarding check.

What this means for you

1. Collect and verify identifying information for every upstream customer.
2. Monitor traffic and compliance on a schedule, not only at renewal.
3. Keep records of your vetting and monitoring.
4. Have a written process for ending service to providers that send illegal traffic.

Know who sends you traffic. Check them often. Document it.