Consumer coalition asks the FCC to take the safe harbors out of KYUP

EPIC joined the National Consumer Law Center, Consumer Action and the National Consumers League in comments filed 8 September backing the FCC’s proposal to tighten Know-Your-Upstream-Provider requirements and attestation levels. From the filing: “[a] more prescriptive regulatory approach that requires basic procedures for vetting upstream providers and eliminates legal loopholes and uncertainty is much-needed.”

The coalition’s asks are specific — no safe harbors, codified STIR/SHAKEN attestation standards, stronger enforcement, clearer provider-role definitions, and a new obligation on providers to collect information about the call traffic an upstream customer intends to send.

This is the reply round in WC Docket 17-97 and CG Docket 17-59, on the FNPRM the Commission adopted 20 May 2026 as FCC 26-32. Opening comments closed 10 August, replies 8 September. The same filing appears in the record as “National Consumer Law Center et al,” which is how the 25-submission reply tally lists it.

Two of the asks are doing different work. Codifying attestation standards moves a definition that currently lives in ATIS documents into the rules, which ATIS and the IP-NNI Task Force both filed against. Collecting intended-traffic information moves KYUP from verifying who an upstream provider is toward recording what it says it will send — identity versus purpose, with different failure modes and different evidentiary value later.

Clearer provider-role definitions is the ask underneath both: the duties in the proposed rules attach to roles the record does not define the same way twice. Watch the Regulatory Watch dispatches as the Commission works through the record.