Attorneys General Urge FCC: Strengthen KYUP Rules to Combat Robocalls

• A coalition of 48 Attorneys General, led by West Virginia's AG McCuskey, is urging the FCC to strengthen "Know Your Upstream Provider" (KYUP) rules.
• The AGs seek enhanced vetting obligations for voice service providers, more regular monitoring, and robust STIR/SHAKEN implementation to combat illegal robocalls.
• They also demand the FCC establish penalties for non-compliance and require KYUP data retention for investigations.
• The Anti-Robocall Multistate Litigation Task Force, co-led by AG McCuskey, has already taken action against dozens of non-compliant providers.
• These efforts aim to curb the billions of scam robocalls and texts that cost Americans nearly $2 billion last year.

Failure to adapt to strengthened KYUP requirements and STIR/SHAKEN implementation could expose providers to substantial penalties, making diligent monitoring of upcoming FCC rule changes paramount.

A broad coalition of 48 Attorneys General, spearheaded by West Virginia's Attorney General JB McCuskey, has formally urged the Federal Communications Commission (FCC) to bolster its "Know Your Upstream Provider" (KYUP) regulations. The primary objective of this bipartisan initiative is to curtail the proliferation of illegal robocalls that exploit the U.S. telephone network. These existing KYUP rules mandate that voice service providers (VSPs) verify the legitimacy and responsibility of the providers from which they receive calls, thereby preventing the routine transmission of illicit communications.

Attorney General McCuskey emphasized the critical role of these strengthened rules, stating that they would place the onus on voice service suppliers to confirm the authenticity and legality of providers. This proactive measure aims to intercept scammers before they can defraud diligent citizens. The current system involves phone calls traversing numerous telecommunication companies before reaching their final consumer destination. While the FCC presently requires all VSPs to vet the companies originating and routing these calls, a significant number of providers reportedly fail to adhere to this obligation, inadvertently facilitating the entry of illegal robocalls into the national communications infrastructure.

The Attorneys General are advocating for a substantial reinforcement of voice service providers' obligations in scrutinizing their upstream provider customers. Beyond this, they seek to extend the same rigorous diligence and oversight to entities involved in the implementation of STIR/SHAKEN. This technical standard is specifically designed to combat caller ID spoofing, a common tactic employed by robocallers to falsify the displayed number, often making calls appear to originate from local numbers, government agencies, or known contacts.

The coalition contends that the FCC should mandate more frequent monitoring of upstream providers to prevent malicious actors from operating without accountability. They are also pressing the FCC to ensure that providers are fully cognizant of and compliant with their caller ID authentication duties, insisting that these rules are consistently applied by every entity responsible for guaranteeing the accuracy of caller IDs presented to consumers. Furthermore, the Attorneys General have requested that the FCC promptly establish clear penalties for non-compliance and institute requirements for the retention of KYUP data, making it accessible for future investigations by law enforcement or state attorneys general.

Attorney General McCuskey's involvement extends to his role within the Anti-Robocall Multistate Litigation Task Force. This task force initiated "Operation Robocall Roundup" in 2025, marking a significant escalation in efforts to combat illegal robocalling. The first phase of this operation involved dispatching warning letters to 37 smaller voice providers. These providers were identified as neglecting their obligations to mitigate the origination and transmission of illegal or suspicious robocalls, primarily due to their failure to comply with fundamental FCC mandates.

Building on these initial actions, the FCC, just two weeks prior, issued an order targeting six of these companies. The order directed them to rectify their robocall protection deficiencies or face the severe consequence of losing their authorization to route any calls across the U.S. telephone network. In its second phase, the task force broadened its enforcement scope, extending its crackdown to include four of the nation's largest intermediate voice service providers. Concurrently, the task force has been urging the FCC to strengthen its "Know Your Customer" rules, which would compel phone companies to verify the identities of individuals making calls via their networks and ascertain the nature of their customers' business activities.

The urgency behind these proposed regulatory changes is underscored by the significant impact of illegal robocalls on the American public. Last year alone, consumers were inundated with over 29.6 billion scam robocalls and texts, collectively suffering financial losses approaching nearly $2 billion. This pervasive issue highlights the critical need for robust preventative measures within the telecommunications infrastructure.

The push by this bipartisan coalition of Attorneys General signals a clear intent to hold voice service providers more accountable for the traffic they carry. For telecommunications companies, these developments suggest an impending landscape of heightened compliance burdens and increased scrutiny. Failure to adapt to strengthened KYUP requirements and STIR/SHAKEN implementation could expose providers to substantial penalties, making diligent monitoring of upcoming FCC rule changes paramount.

Voice service providers and telecommunications companies should closely monitor upcoming FCC rule changes regarding Know Your Upstream Provider (KYUP) requirements and STIR/SHAKEN implementation, as a bipartisan coalition of Attorneys General is pushing for stricter enforcement, increased diligence, and data retention, which could lead to new compliance burdens and heightened risk of penalties for non-compliance.

Source: Original reporting via state Attorney General's office