Operation Robocall Roundup: The Year of Enforcement

Today, we’re diving into a topic that impacts nearly every voice service provider in the U.S.: robocalls. As 2026 begins, the FCC and FTC are ramping up enforcement, and states are joining the fight. 

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• Don’t Leave Your Robocall Obligations Behind in 2026!

About the authors

• Jill Canfield, Esq
• Peter A. Gregory

Transcript

Welcome to Womble Perspectives, where we explore a wide range of topics, from the latest legal updates to industry trends to the business of law. Our team of lawyers, professionals and occasional outside guests will take you through the most pressing issues facing businesses today and provide practical and actionable advice to help you navigate the ever changing legal landscape.

With a focus on innovation, collaboration and client service. We are committed to delivering exceptional value to our clients and to the communities we serve. And now our latest episode.

Host 1:

Welcome to Womble Perspectives! Today, we’re diving into a topic that impacts nearly every voice service provider in the U.S.: robocalls. As 2026 begins, the FCC and FTC are ramping up enforcement, and states are joining the fight. 

Host 2:

That’s right. Illegal robocalls and robotexts aren’t just annoying, they’re a major regulatory focus. The FCC kicked off the year with back-to-back actions, and the FTC is reporting record complaints. So, what’s changing, and what do providers need to do to stay compliant? Let’s break it down.

Host 1:

First up, the FCC. On January 6, they published a summary of a new Report and Order in the Federal Register. This order introduces stricter requirements for the Robocall Mitigation Database. Every voice service provider must register and outline how they prevent unlawful robocall traffic.

Host 2:

Not only that, but providers must recertify their filings by March 1 every year. If anything changes, you’ve got 10 business days to update. And keep an eye out for any inaccuracies. False or outdated info could cost you big. The FCC set penalties at $10,000 per violation for false filings and $1,000 for failing to update.

Host 1:

The order also creates a new reporting mechanism for violations, so regulators, consumers, and advocacy groups can request investigations. While the order takes effect February 5, some rules still need further approval. 

Host 2:

Now, let’s talk about the TCPA consent revocation rule. This rule, adopted in 2024, lets consumers revoke consent for calls and texts using any reasonable method. It even applies to both marketing and informational messages, which has caused a lot of concern for businesses.

Host 1:

Exactly. Last year, the FCC granted a one-year waiver of the “revoke all” requirement, and now they’ve extended that waiver until January 31, 2027. The FCC is still considering whether to modify or eliminate the rule altogether. So, while there’s breathing room, businesses should keep an eye on this. It’s not going away quietly.

Host 2:

Meanwhile, at the FTC, the Do Not Call Registry added 4.8 million new numbers last year, and complaints jumped to 113,000 per month. That’s up by 40,000 from 2024 averages.

Host 1:

And enforcement is serious. The FTC has brought 151 actions so far, resulting in $178 million in civil penalties and $112 million in restitution or disgorgement. 

Host 2:

The states are stepping up too. The Anti-Robocall Litigation Task Force—51 attorneys general working with the FCC—launched “Operation Robocall Roundup.” They’ve issued warning letters to dozens of providers and even removed 13 companies from the Robocall Mitigation Database.

Host 1:

And they’re not just targeting small carriers. Big names like Lumen Technologies, Peerless Network, Bandwidth, and Inteliquent received letters demanding action. Plus, states are tightening laws. Texas confirmed its mini-TCPA expands private rights of action, and Virginia enacted new telemarketing restrictions effective January 1.

Host 2:

So, what does all this mean for providers? Robocalls and robotexts are getting more sophisticated, and enforcement is ramping up. 

Host 1:

Here’s your checklist:

1.     Develop a robust Robocall Mitigation Program.

2.     Implement STIR/SHAKEN caller ID authentication.

3.     Maintain a Do Not Originate list and block suspicious traffic.

4.     Prepare for traceback requests.

5.     Keep your RMD filings accurate and up to date.

Host 2:

And remember, there’s no one-size-fits-all solution. Tailor your mitigation plan to your network and risk profile. The regulators are watching, and the penalties are steep.

Host 1:

That’s it for today’s episode of Womble Perspectives. For more insights, visit our show notes and subscribe for updates. Thanks for listening, and we’ll see you next time!

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