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Telecom AI agent · Robocall mitigation

Robocall Mitigation Certification AI Agent

Track what the standing Robocall Mitigation Database filing still claims — the steps as operated, the upstream accounts, the traceback answers — and start the update clock when one of them moves.

Typical delivery
4–6 weeks
Deployment
Your stack
Perjury clause
Step-evidenced
After launch
Agent Care

What this agent does

Checks the filing, never signs it

In

  1. 01

    A traceback request arrives, and § 64.1200(n)(1) starts a 24-hour clock that counts business hours.

  2. 02

    A request lands on a Friday, and that clock does not run on weekends or on Federal holidays.

Reason

  1. 03

    An upstream provider changes, and § 64.6305(g) allows only listed, un-delisted filers.

  2. 04

    A carrier is de-listed, and the traffic stops in two business days with only 911 carved out.

  3. 05

    A know-your-customer step changes, and § 64.6305(h) allows 10 business days to update the filing.

Decide

  1. 06

    An analytics vendor is swapped, and the specific reasonable steps on file stop describing the network.

  2. 07

    A regulatory investigation closes with findings, and the two-year disclosure duty reaches it.

Out

  1. 08

    A year turns, and recertification falls on or before 1 March, a duty in force since 5 February 2026.

  2. 09

    Execute write actions only inside the approval boundaries agreed during implementation.

Product statement

The agent assembles and tracks; a named officer certifies under penalty of perjury, signs, files, and the provider answers for it.

Example workflow

One change, evidence to filing

  1. 1Change in a mitigation stepCustomer screening, upstream contracts, analytics configuration or a traceback answer
  2. 2Filing impact assembledEvery field of the standing filing the change touches, and the accounts sitting behind it
  3. 3Recertification draftedThe steps as operated, the analytics vendor, the traceback record and the two-year disclosure
  4. 4Controls appliedClock checks, evidence-sufficiency checks, field-coverage checks and completeness confidence

No human action required

Stages 1 to 4 run unaided, and nothing is filed at any of them — the agent is drafting, and the regulatory lane opens at the completeness gate.

5DecisionBranches at the completeness gate
Evidence sufficient

Goes to the signing officer to certify.

Anything thin

Adds a regulatory counsel read first.

Regulatory review

The draft is held with its clocks, its evidence and the fields it would move.

Certify and file · Append evidence · Send to counsel

Filed — by a named officer

  1. 6Account and case records updatedOnly where write access and account policy allow it
  2. 7Outcome evaluatedUpdate-clock margin, evidence completeness, counsel corrections and what review found

Corrections

Each counsel correction is counted in the evaluation.

What should not run autonomously

Human approval stays in control

Outside the boundary — human approval required

8 items

  • Certifying that the filing is true and correct.
    • Signing or filing in the Robocall Mitigation Database.
    • Blocking traffic, or ceasing to accept it.
    • Deciding a mitigation step is reasonable.

  • Automation boundary

    Agent acts unaided

    • ✓Assemble the step evidence and name the account each one governs.
    • ✓Run the 10-business-day update clock from the day a step changes.
    • ✓Check every upstream provider against its own database listing.
    • ✓Draft the recertification against the fields the filing already holds.

    Nothing is certified or filed except by a named officer, inside the agreed boundaries.

    • Judging that a de-listed provider may still be used.
    • Telling a customer that its traffic is lawful.
    • Deciding what a traceback answer should concede.
  • Changes to screening rules or certification templates.

Example output

One change, annotated

Removals ran through 2025, and an order in March 2026 gave reinstated companies fourteen days.

Recertification draft · single change

Illustrative example
Change
Upstream provider swapped in
Drafted as
Know-your-upstream step amended, filing field affected
Clock
Day 3 of 10 business days
Evidence of record
Interconnect record, 18 August 2026
Confidence
Held uncertified
Held for
The signing officer, in person

As received

Taken from the interconnect record and the listing a show-cause order read in December 2024.

What the record holds

  • Upstream screening proof
  • Database listing check
  • Traceback answer log

Why no removal call here

There is no one-strike rule, and removal runs as a two-step process.

What the score decides

Under the configured threshold a counsel read is added before the officer sees the draft.

Action

Certify and fileAppend evidenceSend to counsel

Value

Where AI adds value

The same four claims, placed at the point in the workflow where each one applies.

Where the value lands

Value 01 – 04

Every change

From the step that moved

03Evidence

The provider on the other end

Our wholesale settlement agent works the partner you invoice; § 64.6305(g) makes that same partner a listing you read before you take a call from it.

01Approved path

The filing goes stale by itself

§ 64.6305(h) has wanted a true-and-correct certification on or before 1 March since 5 February 2026, with any change filed within 10 business days and each day past it counted on its own.

02Human review

Signed under penalty of perjury

§ 64.6305(d)(3)(ii) sends the signature to 47 CFR 1.16, which carries the declaration under penalty of perjury that 28 U.S.C. 1746 allows. State telemarketer registration is not a second database.

04

Build an evidence trail

The step taken, the customer it applies to and the officer who signed stay on the filing.

Integrations

Typical integrations

Five system groups connect to the same agent. Which of them are in scope is decided in discovery.

  • Filing and database

    • Robocall Mitigation Database
    • CORES registration records

  • Traceback and enforcement

    • Industry traceback consortium
    • Enforcement Bureau notices

  • Customer and upstream records

    • Onboarding
    • screening files
    • Interconnect
    • upstream contracts

Agent

Robocall mitigation evidence

  • Reads the steps
  • Drafts the filing
  • Holds for the officer

  • Analytics and case systems

    • Call analytics
    • vendor
    • Traceback case records

  • Observability & evaluation

    • OpenTelemetry
    • Langfuse
    • Supported monitoring/evaluation sources

Integration availability depends on the client's existing systems and API access.

Agent controls

Six rings between the model and the filing

Six rings, the innermost tightest of all. What clears every one is drawn in the map below.

L6 · Outermost — last line of defence

Inward → L1 · closest to the model

L6Rollback / safe modeDrop the agent back to evidence assembly if evaluation or production signals degrade.Roll back
L5Version monitoringTrack model, prompt and field changes; the § 64.6305(g) compliance date reads 24 May and 28 May 2024.Track
L4TraceabilityRecord each step, its evidence, the account it governs and every read of the draft.Record
L3Officer releaseHold the draft for a named officer; it governs signature, not whether a step is reasonable.Gate
L2Policy guardrailsTest the draft against the § 64.6305(d)(2) fields; the July 2026 Further Notice is proposed, not adopted.Restrict
L1Confidence thresholdsRoute a thin draft to a counsel read before the signing officer sees it.Require review
Model coreRecertification drafted — the steps, the accounts, the evidence and completeness
L1 – L2
Test whether a draft may stand
L3
Leaves the signature to a named officer
L4 – L5
Keep the step and the evidence behind it
L6
Holds the filing unamended when signals degrade

How Nestack evaluates it

Evaluate the whole assembly — not only the filing that comes out.

Coverage runs the whole depth of the workflow, and every layer is cut by slice.

Surface — the filing an officer signs

  1. E1Final-output evaluationDid the draft record the evidence behind each step?
  2. E2Step-level evaluationDid the agent read the right account, the right field and the live listing?
  3. E3Tool evaluationDid it read and write the correct account record and the correct traceback case?
  4. E4Confidence calibrationDo low-confidence drafts actually attract more counsel corrections?
  5. E5Slice evaluationHow does performance change across specific upstream providers?
  6. E6Business outcomeHow many drafts took a correction before the officer certified?

Floor — the outcome the provider answers for

Failure modes

Where each failure originates in the agent

Seven failure modes, each set at the stage where it actually begins.

Agent lifecycle

Direction of processing →

  1. 01 · Retrieval

    1 mode

    • IM-03

      Stale listing read

      The database listing read is not the one now live.

    Stage gathers

    The steps, the accounts, the clocks and the answers

  2. 02 · Reasoning

    2 modes

    • IM-04

      Steps claimed, not evidenced

      A step is described without the evidence behind it.

    • IM-06

      Upstream check skipped

      An account is drafted without its listing check.

    Stage proposes

    The steps taken, their evidence and completeness

  3. 03 · Tool / write

    2 modes

    • IM-02

      Update clock started late

      The clock runs from discovery, not from the change.

    • IM-05

      Disclosure omitted

      A two-year action is left out of the draft.

    Stage writes

    Only where write access and approval policy allow it

  4. 04 · Output

    1 mode

    • IM-01

      Certified, evidence unrecorded

      The record shows a filing but not what supported it.

    Stage returns

    The filing an officer signs and the Bureau reads

  5. 05 · Change / Version

    1 mode

    • IM-07

      Silent step regression

      A configuration change moves the step, not the filing.

    Stage tracks

    Model, prompt, step rules and filing fields

  • Sev-1 · a filing certified without an officer
  • Sev-2 · a stale step reaches the filing
  • Sev-3 · source degrades, draft holds unfiled
See the complete Telecom failure-mode catalogue

Affected slices

One upstream provider absorbs the corrections

A provider-level step-evidence figure can read clean while one upstream provider carries most of the corrections. Nestack reports the counsel-correction rate by upstream provider, not only in total.

Slice performance — reported separately, not only in aggregate

Illustrative example
SliceFailure rateLiftLift vs. thresholdStatus
Newly onboarded upstream providers9.8%3.6×Review
Foreign-originated traffic partners7.1%2.6×Review
Reseller and MVNO accounts4.4%1.6×Watch
Long-standing interconnect partners2.4%0.9×Normal

Bar: counsel-correction-rate lift vs. long-standing interconnect baseline · scale 0–4.0× · tick marks the 2.0× review threshold

2 of 4 slices over threshold

Evidence-linked improvement

What a stale filing costs

The loop shuts when the unreported change is a regression case. That suite is what the next filing checked is measured against.

Improvement cycle · five stages

Switchback — the path turns at Improve and returns at Learn

  1. 01

    Detect

    Counsel-correction rate rises for one upstream provider.

  2. 02

    Diagnose

    The certification that was true the day it was signed and had been wrong for a year is read back until one cause remains.

  3. 03

    Improve

    Any change goes out numbered, with the accounts behind it attached.

  4. 04

    Verify

    One upstream case still failing is enough to hold the release back.

  5. 05

    Learn

    One case joins the suite, one line joins the mitigation record.

  6. Learn → Detect

    The return edge. The next filing is measured against a suite one case longer.

Typical build scope

Twelve workstreams across six weeks

The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, filing assembly, evaluation, integration, then production validation and handover.

Workstream

Week 1Week 2Week 3Week 4Week 5Week 6

  1. 01Recertification-workflow discovery and boundary work.Week 1
  2. 02Traceback and screening sources.Week 1, Week 2
  3. 03Upstream-provider and step-evidence coverage mapping.Week 1, Week 2
  4. 04Step evidence ingestion.Week 2
  5. 05Account, field and clock binding.Week 2, Week 3
  6. 06Completeness scoring and counsel routing.Week 3
  7. 07Officer certification workflow.Week 3, Week 4
  8. 08Traceback and case-system integration.Week 5
  9. 09Traceback and screening cases.Week 4, Week 5
  10. 10Guardrails and certification controls.Week 4
  11. 11Filing-trail instrumentation.Week 5, Week 6
  12. 12Deployment, documentation and Agent Care handover.Week 6

12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallel

Final scope and sequence confirmed in discovery

Engagement tiers

What each tier includes

Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.

Capability✓ in scope · — not at this tierPilotOne provider group, one yearProductionProduction recertification workflowAdvancedMultiple entities / OCNs
Introduced at Pilot
Draft assembly from your steps✓✓✓
Named-officer certification✓✓✓
Mitigation-programme baseline✓✓✓
Introduced at Production
Reporting by upstream provider—✓✓
Certification workflow in your systems—✓✓
Approved write-back—✓✓
Traceback-system integration—✓✓
Introduced at Advanced
Multi-entity filing duties——✓
Cross-account evidence packs——✓
High traceback volume——✓
Multi-provider screening controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build price
Confirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.
Separate from build
Build pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.

What we need from you

What you bring, and what we build with it

Each input maps to a piece of build scope and a week in the delivery timeline.

  1. 01Your mitigation programme as operated

    Step mapping and evidence capture

    Week 1

  2. 02Representative tracebacks and screening files

    Traceback binding, account mapping and the draft baseline

    Week 2

  3. 03Your upstream providers and their listings

    Step mapping, account binding and the automation boundary

    Week 1

  4. 04Access to relevant APIs, feeds or exports

    Traceback, CRM and interconnect-source assessment, then integration setup

    Week 2

  5. 05Filings you would not want re-read

    Traceback cases and the evaluation suite

    Week 4

  6. 06What no mitigation filing may claim

    Completeness scoring, counsel routing, guardrails and certification controls

    Week 3

  7. 07A named officer to certify and file

    Officer certification workflow, then pilot and production validation

    Weeks 5–6

Nothing else is required

Deployment, documentation and Agent Care handover are ours.

Delivery timeline

Four phases across six weeks

Width here is worked time rather than layout space, and so two bands have to share the fifth week.

Phase

W1

W2

W3

W4

W5

W6

  1. DiscoveryW1
  2. BuildW2 – W3
  3. EvaluateW4 – W5
  4. Pilot & LaunchW5 – W6

Week focus

W1Recertification workflow discovery, step mapping and the automation boundary

W2Source integration and the mitigation-programme baseline

W3Draft assembly, clock logic and certification controls

W4Evaluation suite, traceback cases and failure-mode testing

W5Case integration, pilot changes and targeted corrections

W6One recertification year run under the signing officer, then Agent Care handover

Reading the band
A bar runs across only the weeks its own work is named in. The fifth week doubles because two phases sit in it.
At the end of W6
Once the mitigation record validates, Agent Care assumes the agent.
Duration
Six-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.

Next step · Telecom AI agent

Build a robocall mitigation agent around a filing that ages while nobody touches it.

Show us what your standing Robocall Mitigation Database filing claims today, and what has moved since. A named officer signs it under penalty of perjury, through § 64.6305(d)(3)(ii) and 47 CFR 1.16. Your CPNI certificate falls on the same day and shares nothing else with it.

Typical delivery
4–6 weeks
Deployment
Your database filing
Perjury clause
Step-evidenced
After launch
Agent Care available

Nestack Agents · Robocall mitigation

AGT-TL-18 · Agent Care available after launch

Build a robocall mitigation agent

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Your steps

No obligation. We’ll map the workflow, name the automation boundary and tell you if an agent is the wrong answer.