International STIR/SHAKEN: Compliance for Foreign Carriers Entering the US Market

Foreign carriers entering the US market face unique challenges with STIR/SHAKEN compliance. The framework was designed primarily for domestic US providers, and international traffic introduces specific issues. This guide covers everything international carriers need to know about STIR/SHAKEN compliance when entering the US market.

The International STIR/SHAKEN Challenge

One of the main challenges with unwanted communications is that many originate internationally — the robocall mitigation regulatory initiative was not conceived to consider international communications. No telcos outside the US implement STIR/SHAKEN, international intermediate gateway providers can only use 'C' attestation at best, and international robocalls remain largely untouched by the framework. The consequence: genuine international traffic is often blocked, impacting businesses and end-users globally.

What Attestation Can International Gateway Providers Use?

All calls rendered by an international intermediate gateway provider will be attested to 'C.' This raises a real question: what is the value of that attestation versus no attestation at all? The benefit to consumer safety is minimal, while the cost of implementing STIR/SHAKEN remains heavy.

Requirements for Foreign Carriers

Under the updated definitions, a Foreign Voice Service Provider is any voice service provider created, incorporated, or organized outside the U.S., regardless of whether it has an office within the U.S.

To operate in the US, foreign carriers must: form a US-registered business entity, obtain an EIN from the IRS, register with the FCC (get a 499 Filer ID), apply for an OCN via NECA, complete STI-PA registration, obtain a STIR/SHAKEN certificate, and register in the RMD.

How Foreign Carriers Can Enter the US Market

Option 1 — Establish a US Entity: Foreign nationals can form a US LLC in states like Delaware, Wyoming, or Florida without being a US citizen. STIRSHAKEN.AI handles the complete US business formation package for international operators.

Option 2 — Partner with a US Provider: Work with an existing US carrier that can handle compliance on your behalf.

Option 3 — Use a Hosted Solution: Register as "Hosted" in the RMD and rely on an upstream US provider's STIR/SHAKEN compliance.

The Technology Gap

STIR/SHAKEN can only be used on IP technology — the CLI attestation is encrypted in the IP headers, and it doesn't work on legacy networks. Any attested-CLI traffic that passes through a non-IP network loses its attestation entirely. Some US carrier ecosystems do not run on IP networks and cannot implement STIR/SHAKEN, meaning investment and effort in deploying it can lose value as soon as calls reach a non-IP network.

What Foreign Carriers Should Do

1. Form a US entity — work with a compliance specialist and obtain an EIN via IRS Form SS-4, which applies to foreign passport holders.

2. Complete all FCC registrations — get your 499 Filer ID, apply for an OCN, complete STI-PA registration, and obtain your STIR/SHAKEN certificate.

3. Register in the RMD.

4. Consider a compliance partner — STIRSHAKEN.AI specializes in helping international carriers enter the US market with full compliance.

Conclusion

While STIR/SHAKEN presents unique challenges for international carriers, the path to compliance is clear. By establishing a US entity, completing all FCC registrations, and working with experienced compliance partners, foreign carriers can enter the US market with confidence.