Voice Provider Know-Your-Customer (KYC) Requirements

Current understanding

The FCC is developing Know-Your-Customer (KYC) obligations for voice service providers as part of its broader robocall mitigation framework. Proposed enhancements would require more rigorous customer identification and verification, add obligations targeting high-volume callers, and set per-call penalty structures for violations. Status: proposed rulemaking — not yet in effect.

Evidence log

• 2026-04-15 — Protecting American Consumers from Robocalls Act: cross-connection with protecting-american-consumers-robocalls-act: Consumer-facing robocall bill complements upstream voice-provider KYC/mitigation duties. (novelty: 2)
• 2010-12-22 — Truth in Caller ID Act of 2009: Truth in Caller ID Act (2009, enacted) establishes the underlying illegality of intentionally deceptive caller ID that voice-provider KYC and KYUP rules seek to prevent originating on U.S. networks in the first place. (novelty: 3)
• 2025-01-13 — To amend the Communications Act of 1934 to establish technical and procedural standards for artificial or prerecorded voice systems created through generative artificial intelligence, and for other purposes.: HR334 (AI prerecorded voice standards) complements KYC-based robocall mitigation by imposing content-level identification and line-release duties on the AI-generated calls that upstream KYC rules try to prevent from originating. (novelty: 2) (novelty: 2)
• 2026-07-09 — Enhancing Know-Your-Upstream-Provider Requirements and Strengthening STIR/SHAKEN (Call Authentication Trust Anchor; Advanced Methods To Target and Eliminate Unlawful Robocalls): 2026-05-26 — FCC proposed rule would add baseline Know-Your-Upstream-Provider (KYUP) requirements alongside customer-side KYC, extending diligence obligations to interconnecting upstream providers in the call path. (novelty: 3) (novelty: 3)
• 2026-05-08 — Combatting Illegal Robocalls Through FCC Numbering Policies; Implementation of TRACED Act-Knowledge of Customers by Entities With Access to Numbering Resources: FCC proposed rule would extend numbering-resource oversight — tightening how providers and resellers utilize, report, and resell numbers — as a complement to KYC obligations aimed at denying illegal robocallers access to origination infrastructure. (novelty: 2)
• 2026-05-26 — Enhancing Know-Your-Customer Requirements: cross-connection with tcpa-fcc-enforcement: KYC obligations on voice providers operate upstream of TCPA enforcement by making it harder for illegal robocallers to obtain origination service in the first place. (novelty: 3)

Open questions

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