On March 31, the FCC published a report confirming that STIR/SHAKEN must be implemented in the IP portions of service provider networks by June 30, 2021 (in accordance with the TRACED Act) while also asking for comments on the idea of extending the deadline by a year for small carriers and those with TDM network.
To be clear, they have not yet made any decision on an extension. What they’ve done is to publish a “Further Notice of Proposed Rulemaking” in which they ask for feedback on the idea of extending the deadline.
Small service providers get a break?
Here’s what they say:
The first category of voice service providers identified by the TRACED Act for a potential extension due to undue hardship is voice service providers that use TDM network technology…
The second category of voice service providers identified by the TRACED Act for a potential extension due to undue hardship is small voice service providers. We propose granting a one year implementation extension for such providers and we seek comment on this proposal.FCC 20-42 REPORT AND ORDER AND FURTHER NOTICE OF PROPOSED RULEMAKING, March 31, 2020
They define “small voice service providers” as those with fewer than 100K subscribers, and the logic behind an extension is that they expect multiple vendors to offer solutions and this competition between vendors will “drive down prices and improve the quality of SHAKEN/STIR offerings for smaller providers”.
What about TDM calls?
You’ll also notice that the language here is focused on IP network. So what’s going on with TDM calls?
The original TRACED Act required the FCC to:
…require a provider of voice service to take reasonable measures to implement an effective call authentication framework in the non-internet protocol networks of the provider of voice service.Senate Bill 151, 116th Congress “Pallone-Thune TRACED Act”
But then the Act also gave the FCC an out, saying that the FCC could grant a delay “to the extent that . . . a provider or class of providers of voice services, or type of voice calls, materially relies on a non-[IP] network for the provision of such service or calls.”
In other words, non-IP calls wouldn’t have to comply by the deadline.
What happens next?
First, I should stress that this is just a proposal. The FCC has not made any definite decision yet. Instead they are seeking comments from the industry, and once they’ve received comments (the deadline is May 15, 2020) they’ll make a decision.
It seems very likely that they’ll grant an extension for both TDM calls and small service providers.
Does this mean I shouldn’t bother implementing STIR/SHAKEN yet?
I don’t think it’s that simple. As I’ve shared before there are important benefits to implementing STIR/SHAKEN even without a government mandate. The Tier 1s have already implemented this in their networks, and their subscribers are going to start to expect calls to be authenticated.
If your calls aren’t authenticated then they’re more likely to be classified as spam – either by a data analytics platform deployed at a large carrier, or more casually by the recipient who notices that this call isn’t certified like all the others.
So a deadline extension from the FCC would certainly be helpful, but I’d still encourage you to implement STIR/SHAKEN sooner rather than later for the sake of your subscribers.
We will soon be launching a service where we’ll walk you through the process and get everything configured on your switch – using either Metaswitch or TransNexus as your vendor. If you’d like to be added to the wait-list of service providers who are interested in this service please complete our contact form – and you’ll be the first to know when we officially launch.
NOTE: I am not a lawyer, and the FCC document is 92 pages long, so this document is inevitably a gross simplification of the official text. You should do your own research to make sure you’re complying with the rules.