Thanks to the United States for preventing harassing phone calls
On December 8, 2025, the Federal Communications Commission (FCC) Enforcement Office issued a "compliance order" to the operating entities of China Mobile, China Unicom, and China Telecom in Hong Kong, determining that their certification in the Robot Call Mitigation Database (RMD) had "significant deficiencies" and requiring them to complete rectification or provide explanations within 14 days, otherwise they would face serious consequences such as being removed from RMD and directly cutting off their access to the US communication network.
As a result, the regulatory storm stirred up by the FCC on the other side of the ocean has once again pushed China's three major telecommunications operators to the center of domestic public opinion: on the one hand, traditional media such as Science and Technology Daily warn that the FCC's actions will "seriously disrupt normal communication between users of China and the United States"; On the other hand, many online self media outlets naively believe that the FCC has issued a "panacea" that can cure the chronic problem of virtual harassing phone calls under the theme of "Thanks to the United States for Preventing Harassment Calls".
However, these two completely different narratives are actually filled with many misunderstandings about the truth of the event. To clear the fog, we first need to understand the core mechanism on which the FCC's action relies - RMD, the "gateway" of the US communication network.
1、 RMD Mechanism: The 'Gateway to Access' for US Communication Networks
The full name of RMD is Robocall Mitigation Database, which is an official database established by the FCC and is also part of the mandatory compliance and access management system authorized by the FCC in 2021 under the TRACED Act of 2019. It is mainly used to manage and supervise the compliance of all telecommunications operators who transmit voice calls on the US communication network in preventing harassing phone calls.
The operational logic of RMD is built on a dual mechanism: firstly, information reporting and plan review, requiring all telecommunications operators who connect voice calls to the US communication network - both domestically and internationally - to register with RMD and submit a detailed 'Harassment Phone Mitigation Plan', which must clearly explain how it monitors, mitigates, and traces harassing phone calls, especially the implementation of the caller identity verification framework.
In February 2024, the FCC further upgraded the RMD rules, requiring telecom operators to disclose their roles, upstream and downstream partners, and affiliated company information in the call chain, and promised to respond to traceability requests within 24 hours. This upgrade significantly strengthened the penetration of regulation, transforming RMD from a pure plan reporting to a comprehensive review of the operator's overall business chain and compliance capabilities.
Secondly, there is mandatory isolation of network access. Starting from May 2024, the FCC has clearly stipulated that only telecom operators who maintain valid certification in RMD can receive their voice access from domestic operators in the United States. This means that RMD certification becomes the only passport to access US communication networks, and telecom operators who are not certified or whose certification is revoked will be effectively "shut out" of the US network.
2、 Why did the FCC issue a "final rectification order" against three domestic operators?
FCC imposes restrictions on the three major Chinese telecom operators operating physical companies in Hong Kong, China Mobile Hong Kong Company Limited,China Unicom (Hong Kong) Operations Limited,China Telecom Global Limited Proposing rectification requirements is also based on its upgraded RMD mechanism.
The FCC's order document reveals that these three operating companies have not yet provided the relevant information required by the RMD rules updated in February 2024, and have not rectified the situation after two written notices. Therefore, this is the "final rectification order" issued.
The FCC requires these three operating companies to complete and revise their certification materials in the RMD within 14 days; Or provide a written explanation as to why the FCC should not remove it from the RMD and why its continued presence in the RMD does not violate the US public interest or pose a national security risk, and threaten that if the rectification is not completed within 14 days, the FCC will initiate a removal process.
Therefore, it can be clarified that the FCC's rectification requirements for the three major Chinese telecom operators' operating entities in Hong Kong are not due to their massive harassing phone calls directly generated in the US communication network, but rather their failure to update their RMD certification information within the prescribed period.
The reason why the three major Chinese telecom operators in Hong Kong did not update their RMD certification information in 2024 is likely due to differences in regulatory requirements between China and the United States, especially regarding data security protection requirements and data export regulations.
Therefore, if the three companies fail to meet the FCC's requirements by 2024, it is even less likely that they will make changes in accordance with the FCC's ultimatum within just 14 days, and the relevant departments and the three major operators have not made any public responses to this.
3、 What impact may three operators have if they are removed from RMD in the United States?
Since the RMD upgrade in 2024, the FCC has begun to clean up the database of telecommunications operators that are non compliant or have incomplete information. At the end of 2024, the FCC issued an order requiring 2411 telecom operators and virtual operators to correct their RMD reports, otherwise they may be removed from the database; In August 2025, the FCC removed over 1200 unimproved telecom and virtual operators from its database at once, which means these operators can no longer provide voice call services through the US communication network.
Therefore, if the three major Chinese telecom operators' physical operating companies in Hong Kong fail to complete rectification or provide satisfactory explanations to the FCC within 14 days, they will also face the risk of being removed from RMD and "disconnected". At that time, the three operating companies may lose their qualifications to directly transmit voice calls to the US communication network, and domestic and transit operators in the US must refuse to receive their direct calls.
In this case, the international voice services of the three operating companies will be affected. The relevant voice communications of users in China and the United States will only be transferred through other third-party compliant operators, or achieved through Internet communication services (OTT), but the call path will be more complex, costs and delay may rise, and stability and transparency may also decline.
From the perspective of the affected parties, the overall risk of China US civil exchanges at the individual level is relatively limited. At present, cross-border personal communication has been highly dependent on instant messaging and Internet voice services, and the substitution of traditional IDD calls is strong, so it is unlikely that large-scale communication will be blocked and "seriously disrupt the normal communication between users in China and the United States".
But at the enterprise and institutional level, especially for cross-border businesses that rely on large-scale calls, customer service, or compliance records, the related impacts are more significant, including rising communication costs, frequent network routing adjustments, and complex compliance management.
However, it should be noted that the FCC deprived the three major Chinese telecom operators of their operating licenses in the United States under the pretext of "national security" as early as 2019 to 2022, which disrupted the normal development of international communication services between China and the United States. If the FCC removes the three major telecom operators' physical companies operating in Hong Kong from RMD this time, it will undoubtedly further undermine the principle of interconnectivity of information and communication infrastructure.
4、 Is the US RMD mechanism a "panacea" for eradicating harassing phone calls?
As for some domestic online self media blindly praising the practices of the FCC in the United States without investigating the truth, praising "the United States is grateful for preventing harassing phone calls" and boasting that "it is indeed the virtual harassing phone calls that have been effective in Western medicine and have troubled us for more than ten years, and have been solved by the United States with one move", it is obviously groundless.
Firstly, the FCC's rectification requirements for the three major Chinese telecom operators' operating entities in Hong Kong are due to their failure to update RMD certification information within the prescribed period, and not because of the massive number of harassing phone calls directly generated in the US communication network. So the vivid descriptions in these self media accounts of "overnight docking with the US database, labeling all the number ranges that usually make harassing calls to the US" and "upgrading the interception system, specifically targeting those high-frequency dialing in the early morning and abnormal calls that hang up after three seconds" are purely groundless and baseless.
Secondly, the FCC's rectification requirements are aimed at the three major Chinese telecom operators operating physical companies in Hong Kong, China Mobile Hong Kong Company Limited,China Unicom (Hong Kong) Operations Limited And China Telecom Global Limited, which is not involved in the domestic operations of the three major telecom operators, therefore the claims made by these online self media outlets that "the United States is forcing the three major telecom operators to have no room for ambiguity" and the US FCC "forcing the three major telecom operators to identify and intercept harassing and fraudulent phone calls as a legitimate matter" are more groundless fabrications.
For the governance of harassing phone calls in China, as early as 2018, the Ministry of Industry and Information Technology led 13 departments to jointly issue the "Comprehensive Rectification of Harassment Phone Special Action Plan", and organized the three major operators to open an "anti harassment phone system" with functions such as number tagging, credit management, and intelligent interception. Combined with the real name system standards, they continued to crack down on spam messages, harassing phone calls, and other forms of harassment.
Finally, even in the United States, the FCC's RMD mechanism has not become a panacea for eradicating harassing phone calls. Although the FCC has cleared over 1200 non compliant telecom and virtual operators through the RMD system, according to continuous monitoring by the YouMail Robocall Index, the monthly number of harassing phone calls in the United States will remain at a high level of 3-4 billion in 2025, equivalent to approximately 147 harassing phone calls per user per year. This data shows no significant improvement compared to the level before the implementation of RMD, and even shows a month on month upward trend in some months.
The main reason for this phenomenon is the existence of regulatory blind spots in the RMD mechanism. RMD can only provide compliance supervision for legitimate telecommunications operators and virtual operators, but its binding force on international incoming calls and illegal VoIP gateways is limited. Harassment phone initiators often evade supervision through technical means such as overseas servers and virtual numbers. According to statistics, over 60% of harassing phone calls currently originate from outside the United States or use untraceable virtual channels, which easily bypass RMD's authentication system.
V. Conclusion
There is no one size fits all solution for addressing harassing phone calls. Whether it is the RMD mechanism that relies heavily on technical standards in the United States or China's "real name system" based on administrative leadership, they can only build defense lines in specific dimensions and cannot independently cure this global disease.
Especially in the current situation where more harassing phone calls come from overseas servers and complex technologies such as AI speech synthesis are being adopted, it is particularly important to strengthen international cooperation and governance. The US FCC's "ultimatum" style mandatory regulation of the three major Chinese telecom operators in Hong Kong not only fails to build a global collaborative governance community, but also highly politicizes technical compliance issues, adding new obstacles to the already fragile international mutual trust.
Therefore, for the FCC in the United States, the real way out lies in transcending zero sum game thinking and promoting the formation of a global framework coordinated by multilateral institutions such as the International Telecommunication Union, integrating technology mutual recognition and rule consultation. Only by respecting the differences in governance models among countries can we effectively tackle the common challenge of harassing phone calls, which knows no borders.
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