Breaking down how the FCC’s New Call Blocking Order Will Impact the ARM Industry
The FCC’s new call blocking order introduces stricter compliance requirements for all voice service providers, including businesses that rely on outbound calling.
How the Order Impacts Businesses and Contact Center Providers
The FCC’s new call blocking order introduces stricter compliance requirements for all voice service providers, including businesses that rely on outbound calling. Under this rule, every provider in the call path must block calls from numbers flagged on a Do-Not-Originate (DNO) list, and callers must receive clear notification when their calls are blocked. This change is designed to reduce fraudulent robocalls, but it also means that businesses must ensure their outbound calls comply with new blocking and authentication standards to avoid unintended disruptions.
For companies using legacy contact center solutions or outdated dialers, this rule presents a significant challenge. Without the ability to properly handle SIP Code 603+ for call blocking notifications, businesses risk higher call rejection rates and disruptions to customer engagement. Outbound calls flagged by providers’ analytics could be mistakenly blocked, leading to missed opportunities, customer frustration, and lower conversion rates. Businesses that fail to adapt to these requirements may find their calls going unanswered or blocked altogether.
To stay compliant and maintain high call connection rates, businesses must ensure their technology aligns with FCC-approved call authentication and blocking measures. Now is the time to evaluate outbound calling solutions and migrate to a compliant contact center platform that integrates advanced call verification, redress mechanisms, and real-time blocking notifications. By proactively upgrading dialers and working with providers that support robust call authentication, businesses can protect their outbound operations, enhance customer trust, and avoid regulatory penalties in this evolving landscape.
Our Deep Dive Into the FCC’s
Expanded Call Blocking Rules
Expansion of Do-Not-Originate (DNO) List Blocking to All Providers in the Call Paths
Previous Rule:
The requirement to block calls based on a Do-Not-Originate (DNO) list previously applied only to gateway providers (those handling international call traffic entering the U.S.).
New Requirement:
Now, all U.S.-based voice service providers in the call path—including originating, intermediate, and terminating providers—must block calls that originate from numbers on a reasonable DNO list.
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DNO List Definition
The DNO list includes numbers that should never make outbound calls, such as:
- Unallocated or unused numbers (numbers not assigned to any provider).
- Numbers for which a subscriber has requested blocking.
- Inbound-only numbers (e.g., government agency hotlines that never make outbound calls).
Key Impact on Providers
- All providers must implement DNO list-based blocking, rather than just the final provider in the call path.
- Intermediate providers (which pass calls between the origin and destination) now share responsibility for blocking, which may require system upgrades.
- Failure to comply could result in penalties or removal from the Robocall Mitigation Database, which is required for handling international call traffic.
New Notification Requirement: SIP Code 603+ for Blocked Calls
Previous Rule:
When a call was blocked based on analytics, providers were required to notify callers using Session Initiation Protocol (SIP) codes 603, 607, or 608.
New Requirement:
The FCC now requires the exclusive use of SIP Code 603+ for notifying callers when their calls are blocked due to analytics-based filtering.
- Why the Change?
SIP 603+ provides clearer notification that a call has been blocked by the network rather than declined by the recipient. - Other SIP codes (603, 607, and 608) did not provide sufficient information on why the call was blocked or how to seek redress.
- SIP 608 included a jCard (JSON Card) for redress information, but many providers had not implemented it correctly, limiting its usefulness.
Implementation Deadline & Impact to Providers
Providers have 12 months from the publication of the order in the Federal Register to transition to SIP Code 603+.
- Voice service providers must upgrade their systems to return SIP Code 603+.
- This requirement applies only to IP networks (not traditional Time-Division Multiplexing (TDM) networks).
- Intermediate providers must properly forward SIP Code 603+ to ensure accurate notification to originating callers.
No Mandate for a Standardized DNO List, But It Must Be “Reasonable”
Previous Rule:
The FCC had not mandated a single uniform DNO list but allowed providers to develop and maintain their own lists.
New Requirement:
Providers must use a “reasonable” DNO list, which:
- May include invalid, unallocated, and unused numbers.
- Must include numbers that government agencies or private entities have specifically requested for blocking due to high levels of spoofing.
No Mandate for a Standardized DNO List, But It Must Be “Reasonable”
The FCC has chosen not to mandate a single, central DNO list but instead allows providers to maintain their own reasonable lists.
Providers are encouraged to use more comprehensive lists, but they are not required to include every possible unused or unallocated number.
No Immediate Mandate for Caller Name (CNAM) Display
- The FCC declined to mandate caller name display when a provider authenticates a call using STIR/SHAKEN.
- The FCC is encouraging industry development of Rich Call Data (RCD) to improve transparency for consumers.
- A future mandate remains possible if caller authentication tools do not improve.
Consumer Protections & Transparency for Blocked Calls
- New transparency measures ensure that legitimate calls are not blocked in error.
- Providers must offer an easy method for disputing erroneous blocking.
- Providers are required to notify the caller with SIP Code 603+, making it clearer why a call was blocked and how to seek redress.
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Conclusion: Seize the Opportunity
A pro-business regulatory shift could be a game-changer for the debt collection industry, unlocking unprecedented growth potential. However, agencies must act swiftly and strategically to capitalize on this short window of opportunity. With
Intelligent Contacts’ state-of-the-art solutions, your agency will be ready to scale revenue operations, outperform competitors, and achieve 2X growth in 2025.
Let’s prepare for this new era together—because the future of collections belongs to those ready to innovate and lead.
Stay compliant and maintain high call connection rates
Let’s discuss how proactively upgrading dialers and working with providers that support robust call authentication, businesses can protect their outbound operations, enhance customer trust, and avoid regulatory penalties in this evolving landscape.
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