Adopted April 15, 2026
USTelecom Blocking and Labeling Working Group
Voice Service Providers (VSPs) are generally obligated to complete all calls, but under a regulatory safe harbor,[1] terminating VSPs may choose to rely on reasonable analytics to block calls it believes are illegal or unwanted, both directly and in conjunction with third parties, such as analytics engines (AEs).
In addition to blocking, VSPs may either themselves or in conjunction with an AE vendor partner choose to label calls (for example, “Potential spam”, “Scam likely”, or “Spam risk”) based on reasonable analytics for the purposes of informing consumers about the risk of certain calls being a nuisance or fraud.
VSPs and AEs recognize that erroneous call blocking and labeling may harm legitimate callers and impact call recipient behavior. They have established these best practices for the redress of issues relating to alleged improper call blocking, beyond what has already been mandated by Congress and the FCC. Additionally, VSPs and AEs recognize that the labeling of calls may impact call recipient behavior and believe it is important to establish best practices for redress of call labeling as well.
This document encapsulates best practices for redress requests submitted to the VSP or, as directed by the VSP, to the AE directly by the calling party or by the calling party’s voice service provider. The process to address claims of alleged improper call treatment raised by independent third parties may vary from the procedures outlined herein.
Definitions
Analytics Engine (AE): A company that uses data and analytics to detect nuisance and fraud calls, typically on behalf of a VSP.
Business Day: A day during which the entity fielding redress requests is open for normal business, typically any day from Monday through Friday during standard local business hours, excluding Saturdays, Sundays, and public or legal holidays.
Call Blocking: Refers to the action of blocking a call by a VSP or, as directed by the VSP, to the AE agent. Notably, this does not refer to blocking specifically implemented at the direction of a consumer in an application or on a mobile device.
Call Labeling: Refers to the act of adding a label to an incoming call with a warning to the user that their VSP believes that there is a risk that the call is nuisance or fraud.
Critical Redress Requests: Refers to requests submitted for critical communications necessary for the health and safety of consumers – including but not limited to emergency services, law enforcement, public health alerts, extreme weather notifications, fraud prevention efforts including fraud alerts or multi-factor authentication, or urgent medical provider notices.
Redress: Refers to the ability of a caller to request a change to network analytics treatment of their calls, and the process for the review of that request.
Standard Redress Requests: Refers to good faith redress requests that are not otherwise categorized as critical.
Voice Service Provider (VSP): A provider of voice telephony services.
Blocking and Labeling Redress Submission and Review Process
Redress requests should be accepted via a method as published by the VSP/AE. The published method must include at least one of the following:
- a VSP’s single point of contact, as required by the FCC;
- a VSP or, as directed, AE’s complaint/ticket resolution system; or
- a VSP or, as directed, AE directly through the process prescribed.
VSPs and AEs should establish clear, publicly available information on a website(s) describing submission processes, requirements, and a timeframe for response. Submission processes should be reasonably designed to allow for efficient submission of requests, limit requester confusion, and provide assistance to help correct any errors in submission.
The following USTelecom website can assist with identifying the submission process, which VSPs and AEs will endeavor to ensure is up to date with the appropriate contact information.
https://www.ustelecom.org/call-redress
Redress Request Submission Requirements
- VSP/AEs may require at a minimum, the following information:
- Name of business or organization of calling party
- Name of the submitting contact person from the calling party
- Contact email and/or phone number of the submitting contact person from the calling party
- The calling phone number(s) impacted by the alleged improper blocking or labeling
- Assertion the calling party has the right to use the calling telephone numbers submitted
- To the best of the submitter’s knowledge, the date(s) and time(s) of the blocked or labeled calls
- Statement asserting why treatment is inappropriate
VSPs and AEs reserve the right to refuse to address requests not made in good faith, including but not limited to:
- Repeated redress submissions without material change in the underlying circumstances of the caller or calls
- Redress requests where the requestor has no reasonable belief that call labeling or blocking has been occurring, especially for requests on a large set of numbers
- Redress requests mis-stating the request type (defined below)
VSPs or AEs should acknowledge receipt of an un-qualifying redress request within the same period identified herein to address redress requests, inform the requesting party the redress process has not been initiated, and provide the requesting party with the minimum requirements and standards of good faith requests outlined above that the request did not meet to assist in qualifying their request for redress.
Redress Process
Redress process for blocked calls
Redress for blocked calls refers specifically to instances of call blocking when a calling party believes that blocking has been improperly applied to its calls by a VSP and/or AE and is seeking removal of the alleged improper blocking.
When a calling party’s telephone number(s) are being blocked and they are not engaging in illegal, deceptive, or highly unwanted calls, the calling party may engage the terminating VSP and/or their AE to begin the redress process.
Participating VSPs and/or their AEs will in good faith consider the caller and calling number, the purpose of the calls, the extent of negative user feedback, and the main factors leading to call blocking (e.g., the number is on a DNO list) to determine whether the analytics systems blocked the calls erroneously. The VSP or AE will endeavor to address redress requests within a reasonable timeframe:
Redress Request Type – Time to Conclusion
Standard – Up to 2 Business Days
Critical – Up to 1 Business Day
Redress process for labeled calls
When a calling party discovers that their calls are being labeled for risk of being nuisance or fraud, the party should first evaluate their calling practices to assess whether adjustments should be made to calling behavior. If after examination the caller believes the labeling is unwarranted, the company may seek redress with the AE of the VSP that is labeling the calls. Please note that the AE may have data that would be contrary to the caller’s assessment of their calling practices.
Participating VSPs and AEs will in good faith consider the purpose of the calls, the extent of negative user feedback, and other factors to determine whether the analytics systems flagged the calls erroneously. The VSP or AE will endeavor to address redress requests within a reasonable timeframe. The timeframes below are best practices and not guarantees:
Redress Request Type – Time to Conclusion
Standard – Up to 2 Business Days
Critical – Up to 1 Business Day
Redress response and resolution time
VSPs will provide an initial status update to any redress request within 24 hours. Participating VSPs and AEs commit to reaching a conclusion on at least 95% of qualifying redress requests within the time frames cited in the tables above. If the AE requires additional information from the caller, time to conclusion will be impacted.
Factors affecting redress resolution time
The ability for VSPs and AEs to resolve requests within the time frames listed above is dependent upon several factors, including:
- Timeliness of responses to requests by VSP/AE for additional information from the requestor
- The complexity of the call analytics involved
- Cases involving multiple AEs or VSP networks
- Quantity of phone numbers submitted with the request
- Phone numbers considered invalid [2], unassigned [3], unallocated [4], or Do-Not-Originate [5]
- Submissions that incorrectly state that a call was “blocked” when the call was “labeled” or vice versa. For requests that cannot be concluded within the time frames above, VSPs and AEs will keep the requestor reasonably apprised of status and updates.
Redress process restrictions
To keep this process as efficient as possible, VSPs and AEs applying call blocking or labeling should not:
- Require or request that redress requesters pay a fee or execute an agreement for additional services;
- Market other products or services to requesters in redress materials or correspondence;
- Use information submitted as part of redress requests for marketing purposes;
- Require the registration of numbers submitted for redress via the AE or VSP’s number registration processes in order to process the redress submission;
- Require requesters to create an account or log in before, during, or after submitting a request for redress.
While registration is not a requirement for redress, VSPs and/or AEs may establish a process where businesses may register in advance of any known blocking or labeling incidents, with the objective of both mitigating the potential need for redress and to potentially accelerate any request for redress in the future.
Redress Result Process
If the outcome of a redress process is that blocking or labeling is unwarranted, AEs commit to change the treatment on completion of redress such that the unwarranted blocking and/or labeling will be removed from future calls promptly and confirm such correction to the requester within the specified time. This does not prevent reasonable analytics from restoring blocking and/or labeling if evidence surfaces that runs counter to the information gathered during redress (e.g. clear evidence of nuisance or fraudulent activity).
In the case that the treatment is determined to be warranted and the caller seeks further assistance, the AE or VSP may be able to provide assistance on calling practices or other corrective actions where obvious bad calling practices exist.
Because numbers change hands, calling purposes change, and calling practices may revert over time, VSPs or AEs may choose to limit the timeframe of any treatment impacts after which the AE service may again resume determining blocking or labeling based on standard analytics.
Endnotes
[1] See Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, WC Docket No. 17- 97, Report and Order and Further Notice of Proposed Rulemaking, 32 FCC Rcd 9706 (2017); Advanced Methods to Target and Eliminate Unlawful Robocalls, Call Authentication Trust Anchor, CG Docket No. 17-59, WC Docket No. 17-97, Declaratory Ruling and Third Further Notice of Proposed Rulemaking, 34 FCC Rcd 4876, 4886-88, paras. 33-34 (2019).
[2] An “Invalid Number” is a TN that does not conform to the North American Number Plan (NANP) structure (e.g., a TN with an unassigned area code or use of an abbreviated code such as 911 or 411).
[3] An “Unassigned Number” is a TN that the NANPA or PA has allocated to a provider but is not currently used.
[4] An “Unallocated Number” is a TN that has not yet been allocated by NANPA or the Pooling Administrator (PA) to any provider.
[5] A “Do Not Originate Number” is a TN that the subscriber does not use to make outgoing calls and requests that calls purporting to originate from that number be blocked.