On September 8, 2026, a bipartisan coalition of 49 state and territorial attorneys general filed reply comments with the Federal Communications Commission (FCC), urging the agency to make its “Know Your Upstream Provider” (KYUP) requirements mandatory for voice service providers. The coalition is led by North Carolina Attorney General Jeff Jackson, who also chairs the Anti-Robocall Multistate Litigation Task Force. The filing follows the coalition’s July 27 letter to the FCC seeking stronger vetting obligations for originating voice service providers and extends that position to providers that accept and route traffic further down the call path.

Background

A call typically passes through several providers before it reaches a consumer. Each provider accepts traffic from the provider before it in the chain, referred to as its upstream provider. Since 2022, FCC rules have required a voice service provider to take reasonable steps to ensure that its upstream providers are not using its network to carry high volumes of illegal calls. The current rules do not specify what those steps are, leaving each provider to determine what diligence is reasonable.

In a Further Notice adopted May 20, 2026, the FCC proposed replacing that discretion with a prescribed baseline covering five categories: collecting information about upstream providers, reviewing their compliance, verifying the information collected, monitoring them on an ongoing basis, and taking responsive action, including refusing or discontinuing service to providers that are not following the law. Comments closed August 10, with reply comments due September 8.

In their reply comments, the attorneys general argue that flexibility has not worked. Providers have been subject to these obligations since 2022 — and to potential liability under the Telemarketing Sales Rule and the Telephone Consumer Protection Act before that — but illegal traffic continues to reach consumers at scale. “That’s why we’re asking the FCC to go further,” Jackson said in announcing the filing, “and put in place requirements that actually stop these calls from passing through the network to begin with.”

Where the Coalition Agrees and Asks for More

The coalition endorses all five proposed categories, and its additions are largely about specificity — replacing standards a provider can satisfy on paper with requirements it must actually perform.

• Verified addresses, not corporate formalities. The comments ask providers to collect verified physical places of business and treat registered agents, virtual addresses, P.O. boxes, and shared suites as insufficient. They also seek identification of human principals, owners, parents, and affiliates, aimed at shell entities and nominal executives.

• Public filings are not proof of compliance. The attorneys general urge the FCC to direct providers not to treat a Robocall Mitigation Database entry or a Form 499-A filing as establishing compliance, citing undeliverable subpoenas sent to database addresses and facially defective mitigation plans. They also ask that state attorney general enforcement actions be added to the data points a provider must weigh.
• Fixed intervals, not event-driven review. A provider today generally reviews an upstream customer when entering or renewing an agreement, or when there is evidence that the customer may be breaking the law. The coalition instead asks for recurring monitoring on annual timelines, with a 10-day window for upstream providers to report changes.
• Consequences that attach. The comments seek per-call base forfeitures, retention of vetting records for the full limitations period, and no exemption for small providers, on the theory that bad actors will route traffic wherever scrutiny is lightest.

The coalition makes a parallel request regarding STIR/SHAKEN, the caller ID authentication framework, arguing that the entities issuing and overseeing its credentials should face the same vetting requirements.

Where the Coalition Parts With the FCC

The reply is not a blanket endorsement. The FCC proposed a safe harbor that would shield a provider from enforcement when its upstream provider holds a Service Provider Code token under STIR/SHAKEN. The attorneys general oppose it, arguing that holding a credential is not a substitute for diligence. They do support a separate safe harbor for good-faith decisions to refuse or discontinue service.

Why It Matters

There is no rule yet. The comment cycle has closed, but no order has been circulated and no vote has been scheduled. Providers are evaluating their vetting practices against a proposal, not a requirement. Whatever the FCC ultimately adopts will be built on the record that closed September 8.

Paper compliance is the specific target. The through line in the coalition’s additions is a distrust of documentation that can be produced without being true. A provider whose onboarding file consists of a database entry, a certification, and a corporate registration is describing the type of practice the attorneys general are asking the FCC to declare insufficient.

The comments accompany an active enforcement effort. The Anti-Robocall Multistate Litigation Task Force launched Operation Robocall Roundup in 2025. In its first phase, it sent warning letters to 37 smaller voice providers; the FCC has since ordered six of them to address their robocall mitigation practices or risk losing the ability to route calls. A second phase extended the effort to four of the largest intermediate providers. Positions advanced in these comments should be expected to surface in enforcement theories, whether or not the FCC adopts them as rules.

Troutman Pepper Locke State Attorneys General Team

	Ashley Taylor – Co-leader and Firm Vice Chair Ashley is co-leader of the firm’s nationally ranked State Attorneys General practice, vice chair of the firm, and a partner in its Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. He helps his clients navigate the complexities involved with multistate attorneys general investigations and enforcement actions, federal agency actions, and accompanying litigation.
	Clay Friedman – Co-leader Clay co-leads the firm’s State Attorneys General practice and is nationally ranked by Chambers USA for AG Government Relations and in Best Lawyers for Advertising Law. He has dedicated his entire career to state attorney general and federal work, serving for nearly a decade in a senior role and more than 25+ years in private practice. Clay focuses his practice on helping industry-leading companies mitigate the risks associated with state and federal regulatory investigations and associated litigation.
	Chris Carlson Chris advises clients on regulatory, civil, and criminal investigations and litigation. With a background as an assistant attorney general, he provides practical guidance to clients with matters involving state attorneys general and federal regulatory agencies.
	Lauren Fincher Lauren has vast experience handling state attorneys general investigations, navigating complex regulatory compliance matters, and providing strategic counsel in enforcement actions across various industries. She helps clients manage high-stakes regulatory matters and guides them through complex legal landscapes.
	Stephen Piepgrass Stephen leads the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, representing clients in single and multistate enforcement actions, including inquiries and investigations involving state attorneys general and other state and federal governmental enforcement bodies including the CFPB and FTC. He regularly represents clients in highly regulated sectors such as financial services, emerging technologies, health care, insurance, and education.
	Michael Yaghi Mike handles high-profile investigations led by state attorneys general, the FTC, and other federal and state regulatory bodies. He assists clients through these complex government inquiries, assisting them throughout the entire life cycle of investigations, from regulatory enforcement through formal litigation.
	Matthew J. Berns Drawing on his experience in senior leadership roles in the New Jersey Attorney General’s and Governor’s Offices and as a trial attorney for the U.S. Department of Justice, Matt provides an insider’s perspective when guiding clients through complex government investigations, litigation, and other actions.
	Jeff Johnson Jeff helps clients navigate complex regulatory and litigation challenges with local, state, and federal authorities. His clients benefit from his decade of broad litigation experience, understanding of emerging state and federal regulatory issues, and strong relationships with attorneys general across the U.S. In addition to handling cases from trial through state or federal appeals, Jeff serves as amicus counsel in advancing legal rules to support his clients’ vital interests.
	Jay Myers Jay assists clients in heavily regulated industries, including health care, energy, insurance, emerging industries, and data privacy. He provides both regulatory legal advice and government relations strategies. Jay’s past and current clients include Fortune 10 companies, startups, nonprofits, industry associations, and advocacy groups. Recognizing that state government matters are often complex and multifaceted, he utilizes regulatory guidance, government advocacy, or both in tandem to deliver tailored solutions for each client’s unique needs.
	Zoe Schloss Zoe represents clients in litigation and government investigations. As former deputy attorney general for the Delaware Department of Justice, she is an experienced litigator who understands the enforcement priorities that impact her clients. Zoe works with individuals and corporate entities in highly regulated industries, including financial services, health care, and energy.
	Jessica Birdsong Jessica is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. She received her J.D. from the University of Richmond School of Law, magna cum laude, where she served as associate articles editor of the Journal of Law & Technology.
	Sydney Goldberg Sydney is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. She advises clients on regulatory compliance and state attorney general (AG) investigations in highly regulated industries, including health care and life sciences. She routinely helps clients navigate alcohol compliance and licensing issues, helping proactively manage regulatory risk.
	Troy Homesley Troy is an accomplished litigator who has represented and defended clients across a wide range of complex, high-stakes disputes at both the trial and appellate levels. He has represented technology companies, business executives, law firms, investment funds, high-ranking federal officials, international non-profits, and asylum seekers. Troy draws on his broad litigation experience to advise clients before litigation arises, while claims are pending or threatened, and leading up to and through trial and appeals.
	Namrata Kang Namrata (Nam) is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, based in the Washington, D.C. office. She routinely advises clients on a wide variety of state and federal regulatory matters, with a particular emphasis on state consumer protection laws relating to consumer financial services and marketing and advertising. Nam’s experience transcends multiple industries, including financial services, telecommunications, media, and sports betting.
	Michael Lafleur Michael is an associate in the firm’s Regulatory Investigations, Strategy, and Enforcement Practice Group. Based out of the firm’s Boston office, Mike has deep experience in litigation, investigations, and other regulatory matters involving state-level regulators and state attorneys general.
	William LaRosa Bill represents clients in complex regulatory investigations, state attorneys general matters, and enforcement proceedings. He draws on his experience as a former assistant U.S. attorney and as a private-sector litigator advising corporations in high-stakes litigation and regulatory investigations, including multistate AG investigations.
	Lane Page Lane represents financial institutions and other clients in federal and state regulatory investigations and complex civil litigation. He is particularly focused on consumer protection and fair lending issues.
	Dascher Pasco Dascher provides strategic counsel and representation to clients navigating regulatory compliance, enforcement, and high-stakes litigation. She regularly represents clients in both single and multistate state attorney general (AG) investigations and enforcement actions, as well as before other state enforcement bodies and local government agencies.
	Kyara Rivera Rivera Kyara is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. She received her J.D. from the University of Richmond School of Law, cum laude, where she served as publications and online editor of the Public Interest Law Review.
	Timothy Shyu Timothy advises clients on regulatory compliance and enforcement in highly regulated industries, including health care and life sciences, data privacy and cybersecurity, and emerging technology. He assists companies in navigating complex investigations and enforcement actions, helping them mitigate regulatory risk proactively.
	Trey Smith Trey focuses his practice on representing and advising regulated utilities before state public utility commissions. He routinely helps clients obtain certificates of public convenience and necessity for transmission infrastructure. In this role, Trey works with his clients’ subject-matter experts to manage administrative proceedings, including by preparing initial filings; responding to discovery requests; drafting rebuttal testimony; and litigating any disputed issues.
	Daniel Waltz Dan helps clients navigate all aspects highly regulated relationships between industry participants and federal, state and local governments. Whether engaging with regulators, negotiating transactions or representing clients in the courtroom, he delivers solutions that help his clients achieve their strategic goals.
	Stephanie Kozol Stephanie is Troutman Pepper Locke’s senior government relations manager in the state attorneys general department.