For years, companies - including many in the business process outsourcing (BPO) space - have relied on nearshore and offshore call center staffing to cut costs, deal with U.S. staffing shortages, and offer services around the clock.
However, a series of Federal Communications Commission (FCC) Notices of Proposed Rulemaking (NPRMs) is putting this model at risk.
These proposed regulations cover:
- Call branding (FCC 25-76), including – and notably - from outside of the U.S.
- Call center onshoring (FCC 26-16).
Both have a common thread: foreign traffic, near/offshore agents, and call centers that route U.S. campaigns through international providers, all of which are now squarely in the FCC’s sights.
But these proposed changes could impose a real operational and compliance burden on not only customer service, but also on marketing campaigns and debt collection outreach efforts (see BOX 1).
The new rules, should they go into effect, likely will affect how companies and their BPO partners operate and comply with regulations.
Consequently, companies relying on near/offshore call center staffing should be ready to make necessary adjustments to avoid compliance exposure.
Retailers Oppose Proposed Onshoring Rule
The FCC’s NPRM on onshoring and English-language proficiency (26-16) has elicited strong opposition from one of the largest and one of the most powerful business sectors that also relies on contact center services: retailers.
The National Retail Federation (NRF) wrote to the FCC on April 21, 2026, urging it to shelve the proposed rule.
“The caps, disclosures, and transfer requirements included in the NPRM would only harm, not help, consumers by increasing wait times and reducing service efficiency,” wrote David French, Executive Vice President Government Relations.
“A mandated right to transfer to a U.S.-based representative, combined with limits on offshore handling, would likely create operational bottlenecks, longer queues, higher abandonment rates, and duplicative handling of the same customer issue.
“The Commission should be cautious about requirements that drive costs up and service levels down at a time when households remain sensitive to price increases.”
The NRF also warned that the proposed rule could limit multilingual service and accessibility for non-English-speaking consumers.
“Retail serves diverse communities nationwide, and language access is a core feature of effective customer care,” said French. “Prescriptive ‘American Standard English’ requirements and restrictions on global staffing could reduce retailers’ ability to deliver fast, accurate support for consumers who prefer languages other than English.”
Critically - and this is the kicker - the NRF says the FCC’s proposed regulations could result in fewer, not more, American contact center jobs by accelerating automation.
“A policy intended to preserve domestic jobs could therefore have the opposite effect by hastening transitions that reduce human roles over time,” warned French.
Call Branding
The call branding FNPRM (the F stands for further), released October 29, 2025, would require incoming/outgoing calls from outside the U.S. to transmit a visible foreign-origin indicator to devices.
But this rule, if implemented, could cripple offshore call centers with near-zero answer rates for debt collection, financial services, healthcare, and lead generation.
...these proposed changes could impose a real operational and compliance burden...
Industry comments submitted expressed concerns over issues such as accuracy identifying the calling party, and man-in-the-middle (MITM) call hijacking.
In response, the FCC did soften some of the proposed provisions between the circulated draft of the FNPRM and the version it adopted, such as by making the labeling and spoofing rules clearer.
Call Center Onshoring
The FCC NPRM on call center onshoring and English-language proficiency (26-16), published in the Federal Register on April 23, 2026, extends the call branding FNPRM’s foreign-call themes with onshoring requirements, English proficiency standards, and gateway-provider accountability.
This NPRM floats strict limits on offshore telecom call center work. A March 26, 2026 Law360 article, “FCC Floats Cap For Offshore Telecom Call Center Work” notes the agency wants to cap foreign-staffed calls when callers struggle with U.S. English or local context. The FCC sees these limits as a national priority tied to scam prevention and service quality.
Chairman Brendan Carr’s statement, released when this NPRM was adopted on March 26, 2026, frames it bluntly: offshore centers mean “confusing service, delayed support, and even security risks,” with scammers learning the ropes before launching their own fraud operations.
Marketing efforts could also face heavy exposure here too: especially with lead-generation and appointment-setting campaigns. Many campaigns run through Philippines or Indian contact centers, where agents call U.S. numbers from places like Manila or Bangalore.
Debt collection sees similar risks. Offshore teams often struggle with understanding specific state laws or handling disputes properly, leaving customers frustrated and issues unresolved.
Onshoring NPRM Details
Specifically, the onshoring NPRM:
- Proposes percentage limits on the number of offshore customer service calls allowed for U.S. telecom carriers with oversight extending to their BPO vendors and contractors.
- Mandates English proficiency certification for agents handling American consumers, drawing from benchmarks like TOEFL or TOEIC to check language skills, cover tone, idioms, and cultural fit.
- Requires start-of-call disclosures for calls routed overseas, alerting customers of their option to easily switch to a U.S.-based agent.
- Suggests strict rules barring offshore handling of sensitive info like passwords, Social Security numbers, and payments.
- Seeks comment on whether these protections should extend to emails, texts, and online chats.
Several of these proposed requirements echo the Keep Call Centers in America Act (S.2495) introduced in 2025. That bill requires location disclosure at call start and free transfers to U.S. agents.
...inbound follow-ups...would trigger disclosures like “This call is from (country). Do you prefer U.S.?”
Providers of telecom, CMRS (wireless carriers), interconnected VoIP, cable, and DBS (satellite) services - plus affiliates - also fall under the scope of this NPRM, with extensions eyed for internet access service.
- Proposed caps may limit foreign calls to 30% of volume (as an example), pushing onshoring but without completely banning foreign calls.
- Monthly, quarterly or annual reports would track foreign percentages, transfer rates, and complaints, while broadband labels disclose U.S. call usage at service signup.
- To deter scams, bonds or fees are suggested to target gateway providers carrying risky foreign traffic, layering onto Robocall Mitigation Database (RMD) filings and tracebacks.
Implications for Outbound Marketing
Marketing campaigns lean heavily on offshore scale for dialing and qualification. Should the call center onshoring NPRM go into effect in its current form, BPOs serving telemarketers must now track volumes and certify compliance, risking contract losses if caps hit.
Not only that, inbound follow-ups i.e., opt-outs and billing queries, would trigger disclosures like “This call is from (country). Do you prefer U.S.?” This adds Federal Trade Commission (FTC) Telemarketing Sales Rule (TSR) and FCC Telephone Consumer Protection Act (TCPA) layers as poor clarity fuels do not call (DNC) complaints.
U.S. wages are, from our sources, two to three times higher than offshore rates and training costs pile on top: so expenses increase. While nearshoring to Mexico cuts some pain, the English proficiency rules will still apply.
The upside is better trust: telecom already sits low in American Customer Satisfaction Index (ACSI) rankings due to language gaps. Companies mixing outbound work with service calls should re-evaluate vendor lineups, leaning toward hybrid U.S. - offshore models.
Nuances for Debt Collection Outreach
Collections face the same pressures as marketing, but the Fair Debt Collection Practices Act (FDCPA) and Reg F make it tighter. Offshore agents chasing accounts often fumble with notices or disputes, drawing Consumer Financial Protection Bureau (CFPB) scrutiny alongside FCC heat.
Sensitive financial data must stay U.S.-only, aligning with Department of Justice (DOJ) rules on foreign adversaries. Meanwhile, gateway bonds (posted by gateway providers, surrendered upon exceeding a “threshold of reported unlawful robocalls”) raise costs for blended dialing.
Quick U.S. transfers cut deception claims but squeeze capacity. As a result, profit margins suffer short-term, but debt resolution rates get better in the long term.
Broader Contact Center and BPO Effects
Inbound support, billing, and technical help get hit with disclosures first. Routing must handle transfers without delays to cut down on the cultural nuances/gaps that drive escalations through the roof.
BPOs - 70% of companies offshore “something” - now face reshoring pressure, bringing jobs back but at the price of jacked-up operating costs.
The NPRM allows smaller/rural providers extra time to build U.S. capacity (staffing, facilities) before the call ceilings are enforced. Meanwhile, training in legitimate foreign call centers (to learn scripts, consumer lingo), minimizes opportunity for fraudsters.
Compliance and GRC Shifts
Governance, Risk & Compliance (GRC) teams should get into the habit of building certification logs and audit data flows as a general rule. Teams should also align consent management systems and outbound dialing workflows with the TSR and TCPA consent requirements and both federal and state DNC rules; there could also be dialing system changes (see BOX 2).
Additionally, compliance teams should become familiar with foreign adversary reporting requirements, increasing accountability.
The FCC’s tone has been set. On April 2, 2026 the agency hit a gateway provider with a proposed $4.5 million fine for routing scam traffic from unregistered foreign sources, echoing the Foreign Robocall Eliminate Act (H.R.6152) push for gateway accountability.
Reintroduced Telemarketing Bill Could Doom Autodialers
A bill now in front of Congress could, if it becomes law, make many more calls that are made today from autodialers illegal. It could also affect outbound dialing technologies.
The Protecting American Consumers from Robocalls Act (S.4307), reintroduced on April 15, 2026, broadens the definition of automated telephone dialing systems (ATDS) in the TCPA to include any means that dials from stored lists without human intervention.
It is difficult to understate the significance of this provision. The TCPA bans the use of autodialers, but a case decided by the U.S. Supreme Court in 2021, Facebook Inc. v. Duguid, narrowed the scope of the regulation to only those calls that are made with random or sequential number generation.
That ruling effectively eliminated most modern dialing systems from the ATDS definition as few systems now do that; as a result, cases/lawsuits on ATDS plummeted post-2021.
But this proposal in S.4307 would bring nearly all modern dialers (e.g., predictive, preview, power dialers) back under TCPA ATDS liability, as they store and autodial lists.
The bill’s other provisions include:
- Small businesses would be allowed to register for the Federal DNC Registry, with protections (historically, this has been limited to consumers).
- Applies after one unwanted telemarketing call, not just to more than one in a 12-month period.
The predecessor bill, S.3991, was introduced in the 118th Congress but failed to pass before Congress adjourned in January 2025.
But with the FCC’s renewed focus on restricting fraudulent calling (see main article), S.4307’s backers may be hoping that this spotlight – and continued voter anger with these calls – will drive its passage.
More Regulations Forthcoming
The FCC is not slowing down. The agency issued a release April 30, 2026 on the Know Your Customer (KYC) FNPRM (26-27). It proposes per-call penalties for originating providers that fail/skip customer verification, scaling fines to call volume and harm caused.
The proposed regulation would increase pressure on carriers to stop blocking or mislabeling valid calls. It pushes new Caller ID rules that could make contact centers spend more on compliance, exposing more foreign call traffic to labeling, blocking, and verification requirements.
..audit your foreign call reliance now...Outbound work stays solid if you build compliance-first hybrid models.
CTIA’s April 13, 2026, Ex Parte to the FCC staff underscores industry pushback. The wireless carriers highlight existing KYC and know-your-business (KYB) tools (e.g., branded calling ID) and urge flexibility to avoid stifling legitimate calls while chasing scammers.
Also, the FCC approved a FNPRM with enhanced know-your-upstream-provider (KYUP) STIR/SHAKEN requirements for voice providers. [It aims] to combat illegal robocalls, deter number spoofing, provide better information for call blocking and call labeling decisioning, and close implementation loopholes.
Industry Path Forward
The bottom line from these proposed rules is that they are designed to bring more customer service work back to the U.S. and improve accountability and service quality.
The final rules are still subject to change, and comments filed after Federal Register publication will help shape the FCC’s ultimate approach.
So, audit your foreign call reliance now. Model call volume ceilings and run pilot tests. Outbound work stays solid if you build compliance-first hybrid models.