The Order took steps to require gateway providers to play a more active role in the fight against illegal robocalls originating from offshore. Among other requirements, under the new Order, gateway providers must:

· apply STIR/SHAKEN caller-ID to all Session Initiation Protocol (SIP) calls carrying a U.S. number;

· submit certifications and mitigation plans to the Robocall Mitigation Database (RMD);

· respond to traceback requests from the traceback consortium within 24 hours;

· block calls based on a reasonable do-not-originate (DNO) list; and

· incorporate “know your upstream provider” requirements into their mitigation plans.

Additionally, the Order expanded the “chain of trust” requirements for all voice service providers and intermediate providers, as they relate to gateway providers.?
Gateway Providers are required to submit a certification and mitigation plan to the RMD, and intermediate providers and voice service providers will be prohibited from accepting traffic from gateway providers not listed in the RMD beginning next year.?
The KEY dates are as follows, and are fully detailed on the Wiley-Law web site:-?
https://www.wiley.law/alert-New-Robocall-Mitigation-Obligations-and-Filing-Deadlines-for-Voice-Service-Providers-and-Gateway-Providers?
DNO List Blocking. By December 19, 2022, gateway providers must block calls based on any reasonable do-not-originate (DNO) list.?
Gateway Provider RMD Certification and Mitigation Plans. By January 11, 2023, gateway providers must submit a certification and mitigation plan to the RMD.?
Know Your Upstream Provider Requirements. Also beginning in January 2023, gateway providers are required to follow new “know your upstream provider” rules, which require them to “take reasonable and effective steps” to ensure that their upstream foreign provider is not using the gateway provider to process a high volume of illegal traffic.?
Blocking of Gateway Providers Not Listed in RMD. ?
Beginning April 11, 2023, all providers—including intermediate providers and voice service providers—will be prohibited from accepting traffic from gateway providers not listed in the RMD.?
Also beginning April 11, 2023, all providers—including voice service providers and intermediate providers—may only accept calls from a foreign provider if the foreign voice service providers and foreign intermediate providers are registered in the RMD.?
Implementing STIR/SHAKEN for Gateway Providers. By June 30, 2023, gateway providers must also implement the STIR/SHAKEN framework within their networks and authenticate SIP calls carrying a U.S. number in the caller ID field.?
In summary, there are rapidly approaching compliance deadlines associated with the FCC’s new obligations under the Gateway Provider Order, which will impact a broad range of foreign and domestic entities, including voice service providers, intermediate providers, and gateway providers. Many of these deadlines are fast approaching, and all providers must be prepared to comply with the FCC’s new requirements.?
Again you can read the full posting from Wiley web site?
https://www.wiley.law/alert-New-Robocall-Mitigation-Obligations-and-Filing-Deadlines-for-Voice-Service-Providers-and-Gateway-Providers