Know-your-customer (KYC) is the identity and business checks a carrier runs before it lets an account send traffic. For wholesale voice, KYC is part of how a provider meets its robocall obligations, and it is the first thing a fraud team looks at when traffic behaves oddly. This guide explains what carriers typically verify, what the FCC has proposed, and how to prepare for onboarding.
What KYC means for a wholesale account
A wholesale account is a business relationship, and the provider needs to know who it is carrying traffic for. Most checks fall into three groups:
- Identity: the legal name of the business, its physical address, and the person authorized to act for it.
- Business standing: registration documents, a tax or registration number, and proof of good standing.
- Traffic profile: what the traffic is for, where it terminates, how many calls and minutes to expect, and the network the calls will come from.
The exact list differs by provider. Treat any list here as a starting point and confirm the requirements for your account in writing.
What the FCC has proposed
The FCC has proposed expanded KYC requirements for originating providers in a further notice of proposed rulemaking issued in May 2026 (Docket 17-59). Comments were due June 25, 2026, and reply comments July 27, 2026. These are proposals, not final rules. At the time of writing, no final order had been published, so check the docket in ECFS for current status.
As proposed, originating providers would verify before provisioning service:
- The customer's name
- The customer's physical address
- A government-issued identification
- An alternate phone number
The checks would apply at onboarding and again at renewal or when service is modified, not only once. Commentators have described additional items for high-volume and wholesale accounts, such as the intended use of the service, business registration documents, and the IP addresses calls will come from. Those items are commentators' readings and should be checked against the FCC notice itself. The FCC does ask whether requirements should vary by customer type, service model, and risk.
The proposal also asks how long KYC records should be kept, and it seeks comment on a base penalty of $2,500 per call for carriers that violate the new rules. Both points are still under review.
What to prepare before you apply
Having these ready usually shortens onboarding. Providers that ask for more than this are usually asking for a reason, so ask what each item is for.
- Legal business name, registration number, and tax identifier
- The name, title, and identification of the authorized representative
- Business address, and a phone number that is not the same as the account's main number
- A description of the traffic: the calling purpose, such as sales, support, or outreach
- Expected volume by destination, measured in calls per second (CPS) and minutes per month
- Average call duration (ACD) and the dialer or platform that generates the calls
- The public IP addresses the calls will come from, and whether you use IP authentication or registration
- How you will handle caller ID, including whether you need CLI or NCLI routes
The traffic profile is where most onboarding questions come from. A provider that knows your ACD, CPS, and destinations can price the route, provision capacity, and set fraud thresholds. Be specific, and tell the provider when your traffic changes. A profile that no longer matches the account's approved traffic is a risk the provider has to act on.
What a responsible provider should have in place
- A written fraud policy that covers destination blocking, velocity limits, and what happens when a limit is hit.
- Traffic monitoring that flags sudden changes in volume, destination mix, or call duration.
- A traceback process with a named owner, and a clear way to respond when a traceback request arrives.
- Re-verification at renewal, and a way to update your details without opening a new account.
The proposal does not spell out each of these controls, so they are not requirements in themselves. They are a reasonable test of any provider, because they show whether it can meet the verification and monitoring duties the proposal describes.
Questions to ask before you sign
- Which documents do you require, and which are required again at renewal?
- How long do you keep KYC records, and how do you protect them?
- How do you monitor traffic, and what triggers a review or suspension?
- What is your process for a traceback, and how long does a response take?
- How do you notify me of a change to my account, a rate, or a verification requirement?
Related reading
KYC sits alongside the filings a provider must keep current. The RMD, Form 499, and attestation guide covers those obligations. For what a buyer should measure once traffic is live, see the quality metrics guide, and for how billing increments affect cost, the billing increments guide.