> ## Documentation Index > Fetch the complete documentation index at: https://docs.orbit.devotel.io/llms.txt > Use this file to discover all available pages before exploring further. # FCC Robocall Mitigation Database (RMD) certification > Prepare, file, and keep current your FCC RMD certification from the compliance console — required for every US voice originator under 47 CFR § 64.6305. # FCC Robocall Mitigation Database (RMD) certification If your organization originates US outbound calls, the FCC's Robocall Mitigation Database (RMD) requires you to file a robocall-mitigation certification and keep it current. Terminating carriers must refuse traffic from providers whose certification is missing or deficient — so an absent filing can stop downstream carriers from accepting your calls at all. The console at **Settings → Compliance → RMD** (`/settings/compliance/rmd`) is where you prepare the filing, track its lifecycle, and watch the recertification clock. Every control here is **tenant-owned**: you draft the certification, you file it with the FCC, and you keep it current. Orbit records the state for your audit trail — this page does not transmit to the FCC or wire a carrier on your behalf. Restricted to **owner** and **admin** roles. This page is not legal advice. Confirm your filing obligations and program wording with counsel. ## 1. Who needs a filing — and where it shows up downstream 47 CFR § 64.6305 requires every voice service provider to hold a current RMD certification before traffic terminates in the US. Scope is **US outbound voice only** — messaging, email, and non-US voice are out of RMD scope. If you do not place US calls at all, this obligation does not apply to you. Two places your RMD record surfaces downstream: * **Intercarrier reviews.** When you onboard a carrier or vendor, they verify your RMD record as part of STIR/SHAKEN attestation (see [STIR/SHAKEN attestation](/channels/voice/stir-shaken)). A missing or stale record rejects the review before it starts. * **Traceback response.** When a flagged call routes back to you, an absent or deficient filing sharpens the ITG's position — see [ITG traceback workflow](/guides/compliance-traceback-itg) for the full response workflow. Pair this with your other gate surfaces: an RMD certification is a passing prerequisite in the [send-gates preflight checklist](/guides/send-gates-preflight-checklist) and the [campaign list-hygiene projection](/guides/campaign-list-hygiene-projection), and a hard stop in the [compliance emergency stop](/guides/compliance-emergency-stop). ## 2. Open the console Go to **Settings → Compliance → RMD**. The page has two cards: your registration (or an invitation to start one), and below it the **Call-time origination enforcement** setting. That second setting is opt-in and off by default — do not switch it to **Enforce** while you are still drafting, or Orbit blocks every outbound call on this organization. ## 3. Prepare the certification The FCC filing needs five pieces of company information. Assemble them before you open the form so you are not drafting by guess: | Field | What it carries | | --------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------- | | Company name and business address | The legal entity that files. | | OCN | Operating Company Number — the carrier identifier the FCC uses to index your record. Optional in the form, but it anchors the filing at the FCC. | | STIR/SHAKEN implementation | Complete, partial, or none. This decides whether a mitigation plan is mandatory. | | Robocall-mitigation plan | Required unless STIR/SHAKEN is **complete** network-wide. Describe how you prevent illegal robocall origination — vetting, CDR monitoring, traceback response. | | Compliance contact | Name, email, and optionally phone — the person carriers and the FCC reach on this filing. | Match the entity details to your [Organization KYC profile](/guides/organization-kyc-onboarding) before you submit. The most common validation loop with carriers is a name or address mismatch between the filed entity and the KYC record — identical spelling, not just "close enough". ## 4. File it — the lifecycle The certification moves through a five-state lifecycle. Orbit renders the live status as a badge on the registration card, and only the actions legal from the current state show as buttons. | State | Meaning | Next legal move | | ---------------------- | -------------------------------------------------------------- | --------------------------------------------------------------- | | `Draft` | Saved locally, not yet filed. | **Submit filing** | | `Submitted` | You filed with the FCC and recorded the filing reference here. | **Mark active** once the FCC publishes it | | `Active` | Published and accepted. This starts the recertification clock. | **Flag remediation** if a carrier or the FCC flags a deficiency | | `Remediation required` | A deficiency was flagged and must be corrected. | **Resolve & re-certify** once corrected | | `Withdrawn` | Superseded or intentionally pulled. | Re-open to a draft and re-file | Before you submit, the form enforces completeness: the mitigation plan is mandatory unless STIR/SHAKEN is complete, contact fields are required, and the entity identity is present. A rejection after filing is typically a deficiency the FCC or a carrier flagged — record it with **Flag remediation**, correct the draft body (withdrawn and draft registrations stay editable), and resolve. The console also carries the **recertification verdict** on every read: | Verdict | Meaning | | ------------------------- | -------------------------------------------------- | | `Current` | Within the recert interval. | | `Review due soon` | Approaching the review date. | | `Recertification overdue` | Past the review date — carriers can gap you here. | | `Not certified` | Never marked active, or filed but never confirmed. | The default interval is 365 days; the form accepts a custom interval up to 3,650 days. A material change to your business details must be reflected in the RMD within the 10-business-day window the console displays on the registration card. ## 5. Keep it current Three classes of change trigger a refiling — always within the 10-business- day update window: * **Business details.** Entity name, address, or OCN changed. * **Mitigation program.** The robocall-mitigation plan you filed is revised (new vetting step, new monitoring tool, changed traceback SLA). * **STIR/SHAKEN status.** Your implementation level changed — partial upgrading to complete drops the mandatory plan, for example. The console surfaces staleness two ways: the recertification verdict badge flips to `Review due soon` and then `Recertification overdue`, and the update window readout on the card reminds you how long you have to reflect a material change. Treat `Review due soon` the way you treat an expiring cert — book the review before it flips overdue. ## 6. The certification id and how it interacts with traceback After you file with the FCC, store the confirmation or filing id in the **Filing reference** field (you get the prompt on Submit, and again on Mark active). That reference is what carriers ask for when they verify your record, and what you cite back when a traceback reviewer asks which filing covers the implicated traffic. For the traceback workflow itself, see [ITG traceback workflow](/guides/compliance-traceback-itg). ## 7. One posture surface in a broader profile RMD is one surface of your full compliance posture — the assembly that also carries your KYC record, your DPA/BAA papers, your sender registrations, and your policy scanners. Assemble that profile as one unit in [Compliance profiles](/guides/compliance-profiles-assemble) instead of managing each surface alone. ## Worked example: a healthcare org opening US calling A clinic already handling EU voice signs a US customer and needs to originate US calls. Sequence: 1. Counsel confirms the organization files as the voice originator. 2. The admin opens **Settings → Compliance → RMD** and starts a registration — fills the legal entity exactly as it appears in Organization KYC, declares STIR/SHAKEN **partial** (deployment in progress), and writes the mitigation plan describing patient-vetting and traceback-response SLAs. 3. Because declaration is partial, the plan is mandatory — the form keeps it required. 4. They file with the FCC, come back, click **Submit filing**, and paste the FCC confirmation id as the filing reference. 5. Once the FCC publishes the record, they click **Mark active**. The recertification clock starts; the badge shows `Current`. 6. Six months later the mitigation program changes — new vetting step. They edit the draft plan inside the 10-business-day window, re-file at the FCC, and the record stays current. ## Troubleshooting | Symptom | Likely cause | Fix | | --------------------------------------------- | ------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------- | | FCC or a carrier rejected the filing | Incomplete plan, or entity details that do not match KYC | Record **Flag remediation**, correct the draft, **Resolve & re-certify** | | Record flipped `Recertification overdue` | Review interval passed without a refresh | Re-certify now; the interval restarts when you mark active | | Carrier says the legal contact does not match | Entity name/address filed ≠ the KYC record | Align the entity fields exactly with [Organization KYC](/guides/organization-kyc-onboarding), then re-file | | You cannot edit the draft | Registration is in `submitted`, `active`, or `remediation_required` state | Withdraw to re-open the draft, edit, and re-file | *** ## Deep dives * [ITG traceback workflow](/guides/compliance-traceback-itg) — the downstream surface your RMD record is cited back on. * [STIR/SHAKEN attestation](/channels/voice/stir-shaken) — the signing your mitigation program complements. * [Organization KYC](/guides/organization-kyc-onboarding) — the entity identity your filing must match. * [Compliance profiles](/guides/compliance-profiles-assemble) — the assembly RMD sits inside. * [RMD registration API reference](/compliance/rmd-registration) — the endpoint surface behind this console.