Ron Kerbs: The FCC Robocall Scorecard Should Grade the Whole Call Path
By grading only retail carriers, the FCC's robocall Scorecard skips the upstream providers where illegal traffic actually enters the network.
The FCC did something unusual on September 2, 2026. In the same document where it proposed publishing a public grade for voice providers, it wrote down the reason the grade will be incomplete.
“Mitigating illegal robocalls involves actions that run across the entire life of the call,” the Consumer and Government Affairs Bureau notes, “and a consumer’s provider does not control every stage of that life cycle.”
That is the most honest sentence in the Public Notice. It is also the one the proposal does not act on. The Bureau proposes to rate only domestic voice service providers with retail customers, and to exclude those operating solely as wholesale or intermediate providers, including gateway and non-gateway intermediate providers that do not bill consumers directly.
The reasoning is easy to follow. A consumer cannot switch to a gateway provider, so grading companies nobody buys from looks like wasted effort. But that reasoning proves less than it seems, and the gap it leaves is not small.
A retail grade mostly measures inherited traffic
By the time an illegal robocall reaches a terminating carrier, most of the decisions that mattered have already been made. Someone onboarded the customer, someone accepted the traffic at the border, and someone chose whether to look closely at a suspicious, cheap route. The retail provider at the end of the chain is running defense against a problem it did not create and cannot see the origin of.
Two carriers can run identical mitigation programs, staff their trust and safety teams identically, and answer every traceback within hours, and still land in different tiers, because one sits downstream of a cleaner interconnection than the other. A grade that cannot distinguish between those two situations is not measuring provider effort. It is measuring provider luck.
The Bureau’s own question about false positives makes this sharper. It asks, correctly, how to measure blocking accuracy and how to weigh the erroneous blocking of legitimate calls. But a carrier receiving heavy volumes of poorly attested traffic has to block more aggressively to reach the same outcome, and aggressive blocking produces false positives. Score that carrier on false positives without any view of what it is handed, and you have penalized the provider closest to the consumer for the conduct of a company two hops upstream that the Scorecard does not name.
The Bureau already asked half the question
Paragraph 15 of the notice contains the opening. The Bureau asked whether it should consider “only those [metrics] that measure efforts to protect their retail customers or also those that focus on protecting other consumers as well,” giving the example of responding to traceback requests that originate with other providers’ customers.
The answer is yes, and it should go further than traceback. Three changes would close most of the gap without any new rule or new data collection.
- Score upstream-facing conduct. How a provider handles Know-Your-Customer and Know-Your-Upstream-Provider obligations, how it treats traffic it originates or hands off, and how it responds to tracebacks concerning other companies’ subscribers are all measures of whether a provider is a good citizen of the network rather than merely a good landlord to its own customers.
- Grade companies, not divisions. Many of the providers large enough to appear on this Scorecard also sell wholesale termination or origination services. Rating the retail arm while ignoring what the same corporate parent carries wholesale produces a number that flatters exactly the wrong behavior.
Grade wholesale and intermediate providers too. The Commission already holds Robocall Mitigation Database filings and enforcement records for these companies, so the material exists. The Bureau’s objection is that the consumers cannot choose a gateway provider. True, but consumers are not the only buyers who need the signal. Carriers, aggregators, and enterprises select upstream routes constantly, and largely on price, because nothing public exists to weigh against it. A grade that shapes who wins wholesale business will do more to clean up origination than one that only tells a consumer which retail plan to buy.
Why this is worth fixing now
This is not a rulemaking. The Bureau said so plainly, which means the cost of getting the scope right is a comment, not a proceeding. It also means the Scorecard will function as a market signal long before any rule does. Procurement teams and enterprise buyers will read those grades. So will plaintiffs’ lawyers.
The Commission has spent years building a regime that attacks robocalls at every point in the call’s life. It would be a strange outcome if the only public artifact consumers actually see graded is the last stop.
Comments in CG Docket No. 26-239 are due September 22, 2026 with reply comments October 2, 2026. The industry has three weeks to tell the Bureau where the calls actually come from.
Ron Kerbs is the founder and CEO of Kidas. He holds an MSc in information systems engineering and machine learning from Technion, Israel Institute of Technology, an MBA from the Wharton School of Business and an MA in global studies from the Lauder Institute at the University of Pennsylvania. Ron was an early-venture capital investor, and prior to that, he was an R&D manager who led teams to create big data and machine learning-based solutions for national security. This Expert Opinion is exclusive to Broadband Breakfast.
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