2026 NAAG Robocall Summit: Highlights of a Multi-Pronged Approach to Mitigate Unlawful Calls
On August 19 and 20, representatives of state AG offices from around the country convened for the 2026 NAAG Robocall Summit. Following a day of sessions open only to government staff, attendees heard from representatives of the telecommunications industry, a consumer advocacy nonprofit, AG offices, and the Federal Communications Commission (FCC) about current government- and industry-led initiatives aimed at reducing illegal robocalls to consumers. Panelists also discussed several additional regulatory proposals currently pending before the FCC that seek to mitigate unlawful traffic at all points in the “call path.”
Over the course of two panel discussions, the main topics included the following:
- Know-Your-Customer (KYC) and Know-Your-Upstream-Provider (KYUP) Standards. Panelists discussed current and proposed due diligence standards for voice service providers. In particular, they talked about the FCC’s proposals to strengthen existing KYC rules by adopting more prescriptive obligations to verify customer identities prior to providing service, as well as ongoing monitoring/due diligence standards. Shortly before the Summit, 50 state AGs submitted comments in this rulemaking proceeding urging the FCC to adopt robust customer vetting requirements. During the panel, the business representatives shared their differing perspectives about balancing consistency in KYC protocols without imposing requirements that are overly rigid. In addition, panelists discussed a separate KYUP rulemaking proceeding in which the FCC is considering adopting more specific oversight obligations with respect to upstream providers, including monitoring upstream providers’ traffic and practices and refusing or discontinuing service when there is evidence that an upstream provider is a bad actor.
- STIR/SHAKEN Data for Fraud Mitigation. During this discussion, panelists reviewed the various ways that providers can leverage STIR/SHAKEN call authentication data to root out bad actors in the calling ecosystem, such as by analyzing traffic patterns based on call signer. They also debated the FCC’s proposals in the KYUP rulemaking to apply a “more directed oversight” approach to STIR/SHAKEN governance by outlining new rules and policies intended to “restore trust” in the caller authentication process and the voice communications ecosystem. While the FCC representative suggested that more specificity is needed to promote consistency in STIR/SHAKEN implementation, industry representatives questioned whether the proposed changes would ultimately be effective.
A key takeaway from the Summit was that voice service providers understand regulators expect them to play a proactive role in the fight to stem illegal robocalls, but there is ongoing debate within the industry and between industry and regulators about the best approach. The FCC representative made clear that in the numerous ongoing rulemakings related to robocalls, they are looking for input to help develop the right formula to address vulnerabilities throughout the calling ecosystem. More than one business industry representative commented about shifting focus from merely the volume of calls towards targeting calls that are used to perpetrate fraud and scams.
In general, state AGs continue to make clear that robocalls remain a top priority, evidenced by the ongoing work of the Multistate Anti-Robocall Litigation Task Force and warning letters to carriers suspected of transmitting unlawful traffic. We’ll be diving deeper into this topic during our upcoming webinar on September 23, 2026, at 2 p.m. ET with Multistate Anti-Robocall Litigation Task Force representatives from several state AG offices to discuss robocall issues and enforcement priorities. Additional details about the webinar and a link to register are available here.