GETTING TO KNOW YOU: FCC Publishes New KYC Rules NPRM in Federal Registrar– Proposes Requirements to Validate Customers on Carriers and VSPs and $2,500.00 Fines

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David Casem–the CEO of Telnyx– spoke on stage at the Law Conference of Champions last week and questioned the need for KYC requirements for carriers.

Telnyx famously blasted the FCC for attempting to fine it more than $4MM for allegedly failing to act reasonably in allowing bad actors onto its network. Telnyx argued at the time the Commission had failed to set forth any guidelines in terms of what reasonable KYC procedures looked like.

Fast forward to today and the Commission seems to be heeding Casem’s observation.

Today the commission published its proposes rules requiring carriers to validate customer identity and retain customer records prior to permitting users onto their networks. See 2026 WL 1284762 (F.C.C.)
Federal Communications Commission (F.C.C.)
Further Notice of Proposed Rulemaking
IN THE MATTER OF ADVANCED METHODS TO TARGET AND ELIMINATE
UNLAWFUL ROBOCALLS RULES AND REGULATIONS IMPLEMENTING
THE TELEPHONE CONSUMER PROTECTION ACT OF 1991
CG Docket Nos. 17-59, 02-278
FCC 26-27
Released: May 1, 2026
Adopted: April 30, 2026
Comment Date: (30 days after date of publication in the Federal Register)
Reply Comment Date: (60 days after date of publication in the Federal Register)

Comment due date is June 10, 2026.

You can read the full NPRM here: 1 – IN THE MATTER OF ADVANCED METHODS TO TARGET AND ELIMINATE UNLAWFUL ROBOCALLS (1)

Couple of interesting call outs:

  1. Commission will require all carriers to validate customer identity and retain records;
  2. Commission will require some level of confirmation effort by the carrier of the information provided;
  3. Commission may require “Risk-Based Re-verification” in instances where the user is misbehaving; and
  4. Commission proposes fine of up to $2,500.00 per call when KYC cannot be demonstrated.

Eesh.

Steep penalties. Vague standards. Could be bad.

I commend the FCC for trying to get to the root of the robocall problem– get the fraudsters off the network before they get on. Nice work! But let’s hope people come forward and respond to the Commission’s questions so the Commission gives us clear and workable standards.

Would hate to see Casem proven right. 😉

If you missed Law Conference of Champions this year…. not sure what you were thinking but you definitely missed out. Still you can always request a FREE copy of the Troutman Amin, LLP 2026 TCPA Annual Review, presented by Contact Center Compliance to make yourself feel better!

FIRST DAY OF CZARMAS 2026: THE 2026 TROUTMAN AMIN, LLP TCPA ANNUAL REVIEW, Presented By Contact Center Compliance is now FREE for the Asking!!!!!!!!!!!

Chat soon.

 

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Published by Eric "Czar" Troutman

The Czar of TCPAWorld Eric Troutman is one of the country’s prominent class action defense lawyers and is nationally recognized in Telephone Consumer Protection Act (TCPA) litigation and compliance. He has served as lead defense counsel in more than 70 national TCPA class actions and has litigated nearly a thousand individual TCPA cases in his role as national strategic litigation counsel for major banks and finance companies. He also helps industry participants build TCPA-compliant processes, policies, and systems. Eric has built a national litigation practice based upon deep experience, rigorous analysis and extraordinary responsiveness. Eric and his team feel equally at home litigating multibillion dollar telecommunications class actions in federal court as they do developing and executing national litigation strategies for institutions facing an onslaught of individual TCPA matters. They thrive in each of these roles – delivering consistently excellent results – while never losing sight of the client experience. While many firms now tout TCPA expertise, Eric has been there from the beginning. He built one of the country’s first TCPA-only defense teams and began serving as national TCPA counsel for his clients nearly a decade ago. This perspective allows him to swiftly develop the right litigation strategies for dealing with recurring problems, without wasting time on tactics that are bound to fail. Eric’s rich historical perspective and encyclopedic knowledge of the TCPA landscape also make him an invaluable resource to institutional compliance teams struggling to comply with the shifting regulatory landscape. No task is too small – or too big. Indeed, Eric and his team have helped build TCPA-compliant systems and processes for some of the largest and most complex corporate entities in the country. He commonly works with in-house compliance counsel to build and implement enterprise and business-line specific TCPA solutions, performs TCPA audits and drafts and reviews proposed TCPA policies and procedures. He and his team also have the technical expertise necessary to assist call centers seeking to develop TCPA-resistant call path architecture or to modify existing telephony and software integration to better insulate from potential TCPA exposure. Eric has built a reputation for thought leadership. An avid blogger and speaker, he has been at the forefront of the industry’s effort to push for clarity and a return to sanity for the TCPA for years. He was selected to advocate for the financial services industry on important TCPA issues before the Federal Communications Commission and co-authored the nation’s only comprehensive practice guide on TCPA defense. In his spare time, Eric leads defense teams representing banks and other financial services companies in consumer finance litigation matters. He has experience representing clients in UCC, TILA, RESPA FCRA, CCRA, CLRA, FDCPA, RFDCPA and FCCPA claims, as well as in fraud and bank operations issues.

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