On June 30, 2021, all CSPs, both American and foreign, that route calls within or to the United States must comply with the STIR/SHAKEN mandate or risk serious business harm from the FCC, customers, and fellow Service Providers and intermediaries. The introduction of STIR/SHAKEN by the FCC signals a monumental shift for CSPs in the management of both their IP and non-IP networks, routing of calls, and customer experience. Because of the potentially heavy capital and human investment required in new infrastructure, network topology, and other expenses, the FCC is allowing certain CSPs, based on size or case-by-case circumstances to apply for an extension of the STIR/SHAKEN deadline until June 30, 2022 or even 2023.
To Extend or Not
Is an extension a good idea? Probably not. CSPs should seek to comply with STIR/SHAKEN by the deadline if at all possible and forgo an extension. Why? Simply stated, failing to comply with STIR/SHAKEN will put a service provider at serious competitive disadvantage. Absent the compliance-driven verification mark on calls delivered from their network, those calls will be presented as unverified, and the answer rate for them will be seriously hampered. Both enterprise and individual customers may choose to churn out to a competitive network from which their calls will be presented as verified.
As if that was not enough however, there are additional costs to not complying right away. The FCC requires that if a service provider seeks and is granted an extension, that CSP must still implement a robocall mitigation solution that takes “reasonable steps” to ensure that malicious robocalls are not initiated from its network. In most cases, this will mean the addition of a new technology into the network to accomplish those “reasonable steps”. This then imposes on the CSP all of the disadvantages of actually complying with the STIR/SHAKEN mandates (addition capital and human expenses) while conferring none of the advantages that compliance provides (primarily, calls being presented as verified).
And If I Don’t Comply?
The FCC is treating the matter of compliance to either STIR/SHAKEN or robocall mitigation very seriously. In their 2nd Report and Order on STIR/SHAKEN, the FCC announced that all service providers will be required to file with them a certification of the STIR/SHAKEN and/or robocall mitigation steps they have taken in their network. The deadline for filing these certifications will be announced in late second quarter 2021, so very shortly. 90 days after that filing deadline, the FCC further requires service providers to reject incoming traffic from any partner network that has not filed a certification.
So, service providers can comply with STIR/SHAKEN or comply with robocall mitigation, but either way, they must comply. Failure to do so places a service provider at a serious disadvantage compared to other providers that are compliant. Non-compliant CSPs, both domestic and international (international CSPs terminating traffic that uses NANP resources to the United States) will have all calls bound for US terminations rejected, virtually isolating the provider’s network. Even before that isolation takes effect however, calls originating from the CSP will not show up on the terminating party’s phone as validated, diminishing call answer rates and spurring businesses and consumers to look for a new service provider that can provide the coveted verification mark on their calls.
Comply or Be Left Behind
Clearly, complying with the STIR/SHAKEN mandates and not seeking an extension is the best course of action. STIR/SHAKEN is the beginning of a new era in telecommunications, intended to restore consumer trust in phone networks and get people answering their phones again. With all Tier 1 CSPs and many of Tier 2/3 ones primed to be compliant by the deadline, those with an extension will be left behind and will struggle to retain customers.
NetNumber can help you achieve STIR/SHAKEN compliance by the deadline with our Guaranteed Caller solution. Designed to satisfy the requirements for both IP and non-IP networks, Guaranteed Caller enables any CSP to be STIR/SHAKEN compliant quickly and easily—and without bloated costs.
Contact firstname.lastname@example.org for further details.
This blog was written by Michael Campbell, Guaranteed Caller Product Manager, NetNumber