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The FCC robocalling paradox

The FCC robocalling paradox

When protection collides with permission

By
Kyra Loew
November 21, 2025
Security & Compliance
7
minute read
Phone screen displaying an unknown caller ringing

The FCC is shifting its strategy against robocalls, moving on two seemingly opposing fronts. On one hand, it has intensified enforcement, expelling more than 1,200 noncompliant voice providers while strengthening regulatory requirements for caller identification. On the other, it has begun to relax long-standing protections that once gave consumers control over who could reach them, introducing a paradoxical landscape where calls may be safer but not necessarily more welcome. 

For legitimate contact centers, small businesses, and communications providers, anticipating the tension between protection and permission will be critical to staying compliant while preserving consumer trust. This blog post covers the latest policy developments in caller authentication, evolving rules around consumer consent and outreach, and proactive strategies companies can use to cut through the growing noise. 

The crackdown on robocalls

Since its launch five years ago, STIR/SHAKEN — a regulatory framework designed to restore trust in caller ID — has helped curb unwanted calls (both illegal and nuisance) by more than half. Before reaching recipients, each call is digitally “signed” (or attested) by the providers it traversed, enabling networks to confirm the displayed number is accurate and hasn’t been spoofed. 

Building on STIR/SHAKEN, the FCC requires voice providers to cooperate with traceback efforts by identifying call sources and responding promptly to requests from other carriers or law enforcement. Providers must also submit a detailed robocall mitigation plan to the FCC’s Robocall Mitigation Database (RMD) to stay certified and avoid removal from the voice ecosystem. 

Despite this increased scrutiny, spam and scam calls remain a game of whack-a-mole. Robocalls surged 11% in the first half of the year, surpassing 4 billion each month. That same month saw the lowest share of verified calls in 18 months, exposing a widening gap in caller authentication.

Vulnerabilities in authentication 

Robocall volumes remain high in part because STIR/SHAKEN only applies to calls carried over Internet Protocol (IP) networks. Tier-1 carriers, which have largely modernized to IP systems, can sign 80 to 100 percent of their traffic, whereas smaller carriers operating on legacy, non-IP networks only attest about 20% of traffic. When calls travel through these older systems, authentication metadata can be lost, creating vulnerabilities for AI-driven bad actors to take advantage of.

To improve transparency and traceability, the FCC recently proposed expanding the STIR/SHAKEN framework, which would require providers to:

  • Originate calls on SIP networks and eventually sign all unsigned SIP-delivered calls 
  • Display verified caller details for authenticated calls 
  • Alert the recipient when a call originates internationally
  • Flag calls coming from outside the U.S.
  • Maintain a reasonable Do-Not-Originate (DNO) list to block unauthorized numbers

These rules strengthen defenses against spoofing. However, the FCC has also proposed rollbacks to the consumer consent framework, potentially ushering in a new wave of calls that are technically verified yet still intrusive.  

A dilution of consumer protections

Since March 2025, the FCC has reviewed and considered eliminating obsolete telephony rules following the “Delete, Delete, Delete” initiative. These changes aim to streamline regulatory compliance for telemarketers or other callers (e,g., tracking and documenting call data), to accelerate infrastructure deployment, and target unlawful robocalls more effectively.

Some proposals under review, however, have prompted concerns among advocates that they could inadvertently weaken opt-out protections, leaving consumers, contact centers, and small business owners more exposed to unwanted telemarketing calls: 

  • Internal Do-Not-Call (DNC) lists may be eliminated. Without these lists, consumers not on the national registry — or those receiving exempt calls like  informational, political, charitable, or business-to-business calls — could have less control over stopping calls.
  • Consumer consent revocation may become more business-directed. While consumers can revoke consent through any “reasonable means,” the FCC is seeking comment on whether telemarketers and other callers should be permitted to specify how revocation must occur. This could reduce ambiguity, but may also limit flexibility and shift some control to businesses. 
  • Sharing of consent across entities may increase. With the court-ordered removal of the One-to-one Consent Rule, companies can share consent and are no longer individually accountable for honoring revocation requests, a “lead generator” that could result in repeating waves of robocalls every time this consumer data is sold. 
  • Automated opt-out from prerecorded calls may be removed. Currently, recipients can immediately and easily opt out of pre-recorded calls, without needing to navigate complicated menus, make additional calls, or send emails. Eliminating an automated opt-out mechanism could shift control to the telemarketer, forcing consumers and small businesses to expend more time and effort to halt unwanted calls. 

From a regulatory standpoint, these changes are framed as “modernization.” With a leaner network and more vigorous targeting of illegal traffic, lawful callers will have a clearer path to scale legitimate outreach.

From a consumer and small business perspective, however, these proposed changes for consent may unintentionally reduce how much control they have over who contacts them, how often, and under what basis. The result is a paradox: a more trusted yet noisier environment where legal calls may still overwhelm recipients, hinder productivity, and tie up telephone lines. 

Driving trusted communications 

While it may be safer and easier for businesses to call, it will be harder to be heard. To break through the noise, companies need more than compliance; they need adaptable, data-driven systems that preserve customer trust, flag emerging threats, and keep essential customer communications and operations flowing securely. 

1. Leverage pre-answer risk scoring

As robocall volumes increase, so do authentication and handling costs. FreeClimb Risk Scoring (FCRS) allows businesses to assess suspicious calls before they ring through, minimizing not only fraud exposure, but unnecessary authentication and handling costs. The IVR or agent can then route traffic according to its risk score – whether it’s streamlining trusted callers through the IVR, escalating to a fraud specialist, or hanging up altogether. 

2. Utilize AI-powered behavior analytics 

With 72% of consumers ignoring calls they don’t recognize, businesses need actionable insight into what drives engagement. FreeClimb Interaction Analytics analyzes 100% of customer conversations, delivering real-time intelligence on customer sentiment, team performance, and opportunities for automation. With a clear, holistic view of interactions, businesses can refine their outreach strategies and connect with customers more effectively. 

3. Make opting out easy

Even if regulatory opt-out rules loosen, maintaining consumer choice remains the cornerstone of trust. All automated campaigns should ensure consent is clear, affirmative, and documented for at least four years. Lists should be regularly cleaned to remove unsubscribed or DNC-registered numbers. Smooth, channel-agnostic opt-out flows, such as “one-click” revocation via voice, text, or web, can help differentiate responsible brands that respect customer control. 

4. Audit your outbound calling and text campaigns

Organizations should regularly inventory every messaging campaign to understand who’s being contacted, how consent was obtained, and which systems are in use. Classifying outreach correctly is essential, since each category – telemarketing, informational, and transactional – has distinct compliance obligations. All messages should clearly identify business and purpose.

5. Tailor your call handling strategy

Ensuring high-quality calls is as important as maintaining security. By prioritizing outreach to the most valuable or highly engaged customers, businesses can reduce unnecessary calls and improve overall performance. A configurable call handling strategy, supported by custom blocklists and allowlists, can help stop unwanted numbers from reaching agents while allowing them to spend time on meaningful interactions.

Win with transparency 

A verified caller ID alone won’t guarantee engagement. As robocall tactics and regulations evolve, businesses must ensure their calls are not only trusted but welcomed. 

For over 30 years, FreeClimb has helped businesses of all sizes manage customer communications efficiently. Powered by AI, machine learning, third-party integrations, and millions of call metadata points, FreeClimb solutions adapt to evolving threats and business needs. From pre-answer risk scoring to customizable call routing to customer-agent interaction analytics, FreeClimb offers tools across the entire call path to help businesses build trust and engage callers cost effectively. 

Is your contact strategy ready for the evolving FCC landscape? Find out how FreeClimb can help.