FCC Rule Changes Could Affect Your Outbound Calling Strategy

The FCC recently rolled out some updated rules that could change how some Twilio customers handle outbound calls in the U.S.,especially when it comes to STIR/SHAKEN compliance and call authentication responsibilities. While there is no change to how Twilio delivers traffic, these updates may affect whether customers are now considered a Voice Service Provider (“VSP”) under FCC regulations.

Here’s a quick overview of what’s changing, why it matters, and what customers should do next.

What’s changing?

Back in November 2024, the FCC issued an Eighth Report and Order that updates its definition of a VSP and tightens the rules around how calls are authenticated using the STIR/SHAKEN framework.

The new rules, which could be enforced as soon as June 20, 2025, may apply to businesses that originate calls to the public switched telephone network (“PSTN”) on behalf of others or control the phone numbers being used in outbound calls– even if they aren’t traditional telecom providers.

If your business is a VSP, the FCC now requires the business to: 

• Get their own SPC token and STIR/SHAKEN certificate
• Sign their outbound calls
• Assign appropriate attestation levels (A, B, C)

So what should customers do?

Since this is a regulatory change, Twilio strongly recommends that customers consult their legal counsel to determine whether their business qualifies as a VSP under the new rules and what obligations that may entail. The FCC’s definition is broad, and determining applicability can be complex. 

Please note that Twilio cannot provide legal advice, so the best course of action is for each customer to check with their legal team and make sure they’re prepared ahead of the enforcement date.

If impacted, here’s how Twilio can help

For Twilio customers who are affected by these changes, we’re here to help with features that support compliance: 

• Elastic SIP Trunking customers can use our PASSPorT Pass-Through feature to sign their own calls. 
• Programmable Voice customers will soon be able to use our upcoming Bring Your Own Token (BYOT) feature, giving you more control over how your calls are signed and attested.

We know this kind of change can feel daunting. That’s why we’re keeping a close eye on the evolving regulatory landscape, and working to offer tools that help customers stay ahead. Be sure internal systems, processes, and legal reviews are in place before enforcement begins.

Thanks for building with Twilio!