Last fall, Troutman Sanders reported that the Federal Communications Commission released its final report and order creating a reassigned numbers database to block robocalls. The FCC has now issued formalized policies to allow carriers to block calls by default using “reasonable analytics.”

The final version of the ruling is largely unchanged from the proposed version. The FCC now turns to carriers to follow through and block unwanted robocalls. Chairman Ajit Pai said in a statement that “now is the time for telephone companies to take the baton.”

Although robocalls are the leading basis of complaints filed with the FCC, some are worried that legitimate calls will be blocked. FCC Commissioner Michael O’Rielly stated that he “wonder[s] if it may lead to certain problematic consequences. Completely legitimate organizations and businesses regularly engage in so called ‘robocalling’ to provide consumers with critical and time-sensitive information such as fraud alerts, flight schedules changes, school closures, delivery window delays, prescription notices, appointment reminders, public safety alerts, and—yes—anti-delinquency notices.”

The FCC’s work on this issue may be far from over if legitimate calls are blocked. The FCC appears to anticipate that carriers will set up a process to address the concerns of legitimate callers, and the agency could also address call-blocking programs callers believe to be unreasonable.  It is uncertain which calls will not be blocked, and depending on how the rule works in practice, will influence the FCC’s work in the future.