The Federal Communications Commission wants to put a number on something no carrier currently has to publish: how well it actually blocks illegal robocalls, as opposed to what anti-robocall tools it claims to run in the background. A public notice the agency released September 2 proposes building a consumer-facing scorecard that would rate voice providers, and it is still just that, a proposal open for comment, not a grading system any carrier has been assigned yet.
Reply comments on the plan are due October 2, a little over a week from now, which means the fight over what the scorecard actually measures is still being argued in filings rather than settled in a final rule.
Two different ways to define “good at blocking calls”
The notice, filed under CG Docket No. 26-239, splits potential grading criteria into two camps. Conduct-based metrics would score what a provider does: whether it offers consumers call-labeling and blocking tools, whether it participates in network-level blocking, how it responds to traceback requests from the Industry Traceback Group, and whether it has implemented STIR/SHAKEN call-attestation standards. Outcome-based metrics would instead score what happens to a call once it enters the network: complaint volumes reported to the FCC and FTC, the rate at which illegal calls actually get blocked once false positives are subtracted out, and how many illegal robocalls still reach a subscriber’s phone despite whatever tools a provider has switched on.
The two approaches can produce very different report cards for the same carrier. A provider could check every conduct-based box, offering the labeling apps and joining the traceback group, while still letting a high volume of illegal calls slip through in practice, which is exactly the gap outcome-based metrics are designed to expose. A carrier graded only on outcomes, meanwhile, could score poorly even after adopting every recommended tool, simply because it serves a customer base that scammers target more heavily than average, a distinction the FCC’s notice does not yet say how it would account for.
A banking-industry pushback over which metric wins
The proposal has already drawn a pointed response from outside the phone industry. The American Bankers Association, joined by several other financial services associations, filed comments urging the FCC to build the scorecard around outcomes rather than compliance checklists. The associations argued the scorecard should “encourage prevention, not merely removal of illegally spoofed calls after they have entered the provider’s network,” according to a summary of their filing published in the ABA Banking Journal. Their reasoning is specific to fraud aimed at bank customers: a provider that blocks millions of spoofed calls but still lets a smaller number of convincing bank-impersonation calls through can still cause significant financial harm, so the associations want the FCC to score originating and intermediate carriers, not just the one delivering the final call, and to extend the same scrutiny to illegal text messages on wireless networks.
The request would broaden the scorecard well past a simple pass-fail on call-blocking software. CommLawGroup’s analysis of the underlying notice describes a third bucket of “other inputs” the FCC is also weighing, including Robocall Mitigation Database filings, the agency’s own enforcement records, and data voluntarily supplied by providers themselves, any of which could end up folded into a final scorecard depending on how the comment record shapes it.
A docket clock already running
The formal deadlines are tight relative to how contested the underlying question is. Initial comments on the proposal closed September 22, and the reply window that lets parties respond to each other’s filings runs only through October 2. FCC Chairman Brendan Carr framed the stakes in the agency’s public notice announcing the plan, stating that “combatting the scourge of illegal robocalls remains the FCC’s top consumer protection priority.” A summary from Mac Murray & Shuster of the same docket notes that the commission has not committed to any particular weighting between conduct and outcome metrics, leaving that decision for after the record closes.
What the FCC does with a closed comment record is its own separate step. A scorecard proposal moving through public notice and reply comments is not the same as an adopted rule, and nothing in the docket’s own text sets a date by which the agency must finalize grading criteria or publish an actual scorecard once it does.
What a carrier would actually be graded on, eventually
If the FCC ultimately sides with the outcome-based approach the banking associations are pushing for, the scorecard would function less like a marketing checklist and more like a report on how many illegal calls a subscriber can expect to still receive after signing up with a given carrier. If it leans conduct-based instead, the score would mostly reflect which tools and standards a provider has adopted, regardless of how effective those tools prove to be once deployed. Which version reaches consumers, if either does, depends on a comment record that will not even finish accumulating replies until October 2.
This article was produced with the assistance of AI and reviewed by Morning Overview editors prior to publication.
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