Robocall Mitigation Database Removals: Oct 7 Has Passed, Nov 4 Is Next

1. Oct 7 was the cutoff for direct traffic. The order required all intermediate and voice service providers to stop accepting calls directly from Digital Solutions within two business days of release.
2. Nov 4 is the final determination’s blocking deadline. Every provider immediately downstream must block and cease accepting all traffic directly from Digital Solutions no later than 30 calendar days after release.
3. Check your upstream list today. Search your interconnect agreements, trunk configs and route tables for Digital Solutions Inc. Look at every provider that hands you traffic directly, including backup routes that rarely carry volume.

Then put Nov 9 in your calendar. That is the last day for reply comments on the FCC’s proposed RMD rule changes.

The rest of this post covers what each order says, who it affects, and a self audit for your own filing.

What Robocall Mitigation Database removal means

The Robocall Mitigation Database (RMD) is the FCC’s list of providers that have filed a robocall mitigation certification. Voice service providers, gateway providers and non-gateway intermediate providers all have to file.

Once the FCC removes a provider from the RMD, all intermediate and voice service providers must stop accepting calls directly from it, except calls to 911 and other emergency numbers.

A mandatory blocking order is a separate tool. It follows a three step process: a notice of suspected illegal traffic, then an initial determination order, then a final determination order that starts a 30 day block clock for the provider immediately downstream. The Digital Solutions order was a final determination and an RMD removal in one document.

What each order says

Digital Solutions Inc. (DA 26-1073, Oct 5)

DA 26-1073 is a single Final Determination Order and Removal Order. According to the order:

• The Bureau identified 51 prerecorded calls to wireless numbers, sent between May 6 and July 8, 2025. Some claimed the recipient’s loan “application” had been “preapproved”. Others pitched “updated IRS relief programs”. The Industry Traceback Group traced them to Digital Solutions as the originating provider.
• Its RMD certification said it had fully implemented STIR/SHAKEN, while its own mitigation plan said part of its network had not. It later fixed that statement, but never supplied the authentication information the Bureau asked for on ten traced calls.
• Its July 2026 recertification did not mention the open FCC proceeding against it.
• It cannot refile in the RMD without the approval of both the Enforcement Bureau and the Wireline Competition Bureau.

The order adds two practical details. Downstream providers may start blocking before Nov 4 if they first give the FCC notice and a brief summary of why. And the rules still bar blocking emergency calls placed to 911.

Aspireistic Inc. (DA 26-1084) and Callsto, LLC (DA 26-1085), Oct 8

These are Initial Determination Orders and Orders to Show Cause. They are not blocking orders, and neither company has been removed from the RMD by them.

Each order gave the company 14 days to respond. If the Bureau later issues a final determination, that order starts its own 30 day block clock for the provider immediately downstream. According to the Callsto order, the traced traffic included robocalls to two 911 call centers and Medicare themed robocalls to wireless numbers. The Aspireistic order says its response to the earlier notice was incomplete and arrived 12 days late.

Mexico IP Phone LLC (DA 26-1116, Oct 16)

The FCC removed Mexico IP Phone from the RMD in DA 26-1116. According to the FCC’s news release, the company filed a forged Commission document with the numbering administrator to seek direct access to numbers, and did not disclose a State Attorneys General Task Force anti-robocall investigation in its RMD certification. Providers had two business days to stop accepting its traffic, which was Tue Oct 20. The release also says the FCC has removed more than 1,400 companies from the RMD since January 2025. Like Digital Solutions, Mexico IP Phone cannot refile without the approval of both bureaus.

Who this affects

Carriers, wholesale and intermediate providers. A removal binds all intermediate and voice service providers: none of you may accept calls directly from a removed provider. A blocking order adds a second duty for the provider immediately downstream. “We didn’t originate it” doesn’t help if the traffic came to you directly after the deadline.

VoIP, CPaaS, CCaaS and UCaaS providers. You probably file your own RMD certification. The Callsto deficiency list below reads like a description of a thin filing. If yours hasn’t changed in a year, reread it this week.

Dialers and voice AI platforms. You may not touch the RMD directly, but your termination vendor does. If a vendor sends traffic through a removed provider, routes can fail without warning. Ask your vendors in writing whether any of these providers sit in their path.

MVNOs. The Mexico IP Phone order shows the FCC treating access to phone numbers as a front line against illegal robocalls. Know where your numbers come from and who you got them through.

Your RMD self audit: what the FCC called out

The Callsto order lists four deficiencies in its RMD certification, and cites a fifth problem elsewhere in the same order. Use them as a checklist for your own filing.

1. Your STIR/SHAKEN answer matches your plan. Callsto certified “Complete STIR/SHAKEN Implementation”, while its plan said it had not fully implemented it because of non-IP parts of its network. Digital Solutions was cited for the same mismatch. If you have partial implementation, say so in both places.
2. You describe your know your upstream provider steps. The plan has to explain the measures you take to know the providers that send you traffic.
3. You say whether you use a third party analytics vendor, and name it. The certification must describe the analytics you use to identify and block illegal traffic, including whether a third party vendor is involved and who it is.
4. You disclose prior agency action. The certification asks whether the filing entity, or any entity under common ownership or control, has been the subject of a formal Commission, law enforcement or regulatory agency action in the past two years. Digital Solutions was also cited for leaving out an open FCC proceeding.
5. You disclose your affiliates. The order also cites Callsto’s failure to disclose its link to Aspireistic as an affiliate.

If any answer is out of date, update the filing now rather than after a notice arrives. Check with counsel if you’re unsure how to word a disclosure.

The Nov 9 reply comment deadline

The FCC’s further notice of proposed rulemaking on the RMD (FCC 26-49, WC Docket Nos. 24-213 and 17-97, CG Docket No. 17-59) was published in the Federal Register on Sep 9, 2026. Initial comments were due Oct 9. Reply comments are due Nov 9, 2026.

According to the Federal Register notice, the FCC proposes and seeks comment on:

• clarifying which entities have to file in the RMD,
• making filings more accurate and complete,
• deciding which parts of filings can be made public,
• stronger screening of new filers,
• better ways to identify providers that don’t meet the rules,
• faster removal, and
• safeguards against unauthorized re-entry into the database.

If you file in the RMD, these proposals shape how much scrutiny your next filing gets.

Timeline

The date that matters: Wednesday, Nov 4, 2026. Providers immediately downstream must block and cease accepting all traffic directly from Digital Solutions Inc. The duty to stop accepting its calls directly already applied from Oct 7.

What to watch

• Final determinations for Aspireistic or Callsto. If the Bureau issues one, it starts a new 30 day block clock. The FCC posts them on its enforcement orders page.
• More removals. Recheck your upstream list as new orders come out, not once a quarter.
• The final RMD rules. After reply comments close, the FCC can adopt rules that change screening, removal speed and what is public in your filing.

FAQ

What is the FCC Robocall Mitigation Database?

It is the FCC’s public list of voice service, gateway and intermediate providers that have certified how they fight illegal robocalls. Providers that are not listed, or are removed, cannot have their calls accepted directly by other providers.

What happens on Nov 4, 2026?

Providers immediately downstream of Digital Solutions Inc. must block and cease accepting all traffic directly from it. That is 30 calendar days after the FCC released DA 26-1073 on Oct 5. The separate duty for all intermediate and voice service providers to stop accepting its calls directly took effect two business days after release, on Oct 7.

Are Aspireistic and Callsto blocked?

Not by their October orders. DA 26-1084 and DA 26-1085 are initial determinations that gave each company 14 days to respond. A final determination would start its own 30 day block clock for the provider immediately downstream.

Can I block a removed provider before the deadline?

Under DA 26-1073, downstream providers may block Digital Solutions before Nov 4 if they first give the FCC notice and a brief summary of the basis for their decision. In practice this matters little, because the removal already required providers to stop accepting its calls directly from Oct 7.

When are reply comments due on the RMD rule changes?

Nov 9, 2026. The FCC RMD notice was published in the Federal Register on Sep 9, 2026, under WC Docket Nos. 24-213 and 17-97 and CG Docket No. 17-59.

Know who is sending you calls. Falcon checks FCC standing every 6 hours for the carriers that send you calls. A provider that loses its Robocall Mitigation Database listing is flagged, or blocked if you turn on enforce mode. The FCC check runs in monitor mode by default. It’s free and self-hosted. See Falcon, our robocall mitigation software. To see which carrier actually holds a number, use the LRN lookup API, and for per call decisions, the robocall scoring API.