Effective date released.
SUMMARY
SUMMARY
On September 29th, the Federal Communications Commission (FCC) released the effective date to be compliant with the February 28, 2025 Order on Robocalls. The Order requires all U.S. based voice service providers in the call path implement a reasonable Do-Not-Originate (DNO) list and block calls traversing their network based off of the DNO list. The FCC did not adopt a single uniform list, instead it allows providers the flexibility to purchase a list from, such as Somos, Inc. or the Industry Traceback Group (ITG), or develop their own list and what type of numbers to be included.
The DNO list MUST include:
- Any inbound-only government numbers where the government entity has requested the number be included;
- Private inbound-only numbers that have been used in imposter scams, when a request is made by the private entity assigned such a number.
The DNO list may also include, but is not required to, any invalid, unallocated, and unused numbers as well as numbers for which a subscriber has requested blocking due to it being used for inbound calls only.
While there is not a standard framework for the DNO list, the FCC may deem a list unreasonable if it is so limited in scope that it does not include the most obvious type of numbers that should be included.
SIP Code 603+ Exclusive Use for Blocking Using Reasonable Analytics
In addition, for providers using analytics for call blocking, SIP Code 603+ must be used exclusively to immediately notify callers when a call has been blocked based on the use of reasonable analytics. SIP Code 603+ is not required if the call is blocked based off the DNO.
THIS MAY APPLY TO YOU IF…
- You are a voice service provider.
ACTION ITEMS & TIMELINE
- Implement a reasonable DNO list and block calls based off the list by December 15, 2025
- Implement 603+ as the exclusive code to notify callers when a call has been blocked based on reasonable analytics by March 25, 2026. If you use analytics for call blocking, contact your analytics vendor to assist with determining if this obligation is applicable to your company.

