Regulatory Analysis · March 2026

Published by SONIQCX · U.S. Call Center Policy Update

FCC vs. Congress: The 2026 Call Center Onshoring Proposals Explained

Two separate regulatory conversations are developing around U.S. call center operations. The FCC's Notice of Proposed Rulemaking and the Keep Call Centers in America Act (S. 2495) are not the same - they differ in scope, legal authority, and current status. Neither is finalized law. Here is an accurate breakdown of what each proposes, who it would affect, and what it means for companies thinking ahead about their CX operations.

Two Separate Proposals. Different Scope. Different Status.

The FCC and Congress are approaching call center regulation from different legal angles. It is important to understand what each actually proposes, who it would affect, and what is still undecided. Neither framework is finalized law as of this writing.

FCC NPRM · Proposed · March 2026

FCC Notice of Proposed Rulemaking

The FCC issued a Notice of Proposed Rulemaking - meaning it is exploring potential rules, not adopting them yet. A public comment period is open before any rule is finalized. The FCC's jurisdiction is limited to companies it regulates: primarily telecom carriers, cable providers, broadband, and VoIP services. It does not broadly apply to all call centers or all industries.

  • Status: Proposed - not yet final law. Subject to public comment and revision.
  • Regulatory authority: Federal Communications Commission
  • Industries in scope: Telecom carriers, cable, broadband, VoIP - not all businesses
  • Proposed rules may include: Disclosure when calls are routed offshore; option for customers to request transfer to a U.S.-based agent
  • Potential enforcement tools under consideration: Fees or compliance measures - no finalized penalty structure yet
  • AI disclosure: Not a confirmed provision of this NPRM. AI-related disclosure conversations are coming from separate legislative discussions, not this FCC rulemaking.
S. 2495 · Proposed · Senate Bill

Keep Call Centers in America Act

This is a Senate bill that has not been enacted into law. It would affect companies receiving federal contracts or subsidies that move call center jobs offshore. Its scope is broader than the FCC proposal but still limited to entities with federal funding relationships.

  • Status: Proposed legislation - not yet enacted into law
  • Regulatory authority: Congress (Senate, S. 2495)
  • Industries in scope: Federal contractors and subsidy recipients that offshore call center jobs
  • If enacted, proposed mechanisms include: Public registry of offshoring companies; potential loss of federal contracts; possible tariff and procurement exclusions
  • Note: Specific enforcement penalties would be defined in final bill text and implementing regulations

What Each Framework Proposes: A Comparison

The two proposals address different things at different levels. This comparison reflects what is currently proposed - not confirmed law. Many details remain subject to public comment, revision, and final rulemaking.

Area FCC NPRM (Proposed) Keep Call Centers in America Act (Proposed)
Current status Notice of Proposed Rulemaking - open for public comment. Not yet final. Senate bill - not yet enacted into law.
Who it affects FCC-regulated entities: telecom carriers, cable, broadband, VoIP providers. Not all businesses. Companies receiving federal contracts or subsidies that offshore call center jobs.
Location disclosure Proposed: disclosure when calls are routed offshore at the start of an interaction. Not a call-level requirement; operates at the business reporting and registry level.
Transfer to U.S. agent Proposed: customers may be able to request transfer to a U.S.-based agent on demand. Not addressed at the call level in the current bill text.
AI disclosure Not a confirmed provision of this NPRM. AI-related disclosure is being discussed in separate legislative conversations. No AI disclosure requirement in current bill text.
Registry Not applicable - FCC maintains regulatory records, not a public offshoring registry. Proposed: public registry maintained by Department of Labor listing companies that offshore call center jobs.
Federal funding FCC authority is sector-specific; funding leverage applies only to FCC-licensed operators. Proposed: federal contractors on the registry could face loss of federal contracts or subsidies.
Potential penalties Enforcement tools under consideration. No finalized penalty structure. The FCC is exploring fees and compliance measures - nothing confirmed yet. If enacted: potential tariff exposure, exclusion from federal procurement, and possible merger/acquisition complications for listed companies.

Operational Considerations: What These Proposals Signal

Even though neither framework is final law, the direction of regulatory attention matters for how companies think about their CX operations going forward. Here is what forward-looking operators should be considering - with a clear distinction between confirmed obligations and emerging signals.

For FCC-Regulated Companies

Disclosure Infrastructure

If the FCC NPRM is finalized, telecom carriers, cable, broadband, and VoIP providers would need systems to disclose offshore routing at the start of customer interactions. Building that capability now is less expensive than building it under a compliance deadline.

For Federal Contractors

Registry Risk

If the Keep Call Centers in America Act is enacted, companies receiving federal funding that offshore call center work would face public registry listing and potential loss of federal contracts. Companies in active federal procurement should monitor this bill's progress closely.

Broader Signal

The Direction of Regulatory Travel

Both proposals reflect growing political and regulatory attention on call center transparency and domestic operations. Even companies outside the immediate scope of either framework should recognize that this is the direction customer-facing regulation is moving.

For FCC-Regulated Companies

Transfer Capability

If the FCC proposal includes a transfer-on-request rule, companies routing calls offshore would need a domestic escalation path. Companies with no U.S.-based agent capacity would face a practical compliance gap if that rule is adopted.

Broader Signal

AI Transparency Is Coming

While this FCC NPRM does not include a confirmed AI disclosure requirement, separate legislative conversations are moving in that direction. Companies deploying fully automated AI-handled customer interactions should anticipate that disclosure requirements will emerge, whether through the FCC or other regulatory channels.

Universal Consideration

Customer Trust Is Not Waiting for Regulation

Regardless of whether these proposals become law, customers increasingly notice and react to offshore routing and non-human interactions. The reputational and revenue risk of poor transparency is real regardless of the regulatory outcome.

Where Things Stand: Timeline and Status

Both proposals are active but unfinished. Here is an honest read of where each stands as of March 2026.

March 2026: FCC NPRM Issued

The FCC issued a Notice of Proposed Rulemaking exploring offshore call center disclosure rules for companies it regulates. The public comment period is open. No rules have been finalized. The FCC will review comments before deciding what - if anything - to adopt.

Comment Period and Rulemaking

After the comment period closes, the FCC will evaluate feedback and may issue a final rule, modify the proposal, or take no action. Companies in FCC-regulated industries (telecom, cable, broadband, VoIP) are the relevant audience - not all businesses.

S. 2495: Senate Progress Ongoing

The Keep Call Centers in America Act remains a Senate proposal. It has not been enacted. Its trajectory depends on Senate floor time, potential amendments, and House action. Federal contractors should watch its progress - others are less directly in scope.

Why SONIQCX Is Built for the Direction These Conversations Are Heading

SONIQCX was not designed around regulatory compliance. It was designed around doing CX right: U.S.-based teams, transparent operations, and outcomes that are actually measurable. That happens to align closely with the direction both regulatory frameworks are pointing - not because we anticipated the rules, but because the model is built on the same principles driving them.

The regulatory conversation is moving toward what SONIQCX already does.

Companies building BPO operations on offshore labor cost savings or undisclosed AI interactions may face increasing friction as this regulatory environment develops. SONIQCX operates with U.S.-based agents, transparent AI co-pilot systems, and performance-based accountability. That is good business practice regardless of what rules are ultimately adopted.

U.S.-Based Operations

SONIQCX operates with U.S.-based agents. There is no offshore routing, no registry risk, and no disclosure friction at the start of a customer interaction. Federal contractors and regulated-sector companies can partner without compliance concern.

Compliance-Ready Infrastructure

The SONIQCX operating model already supports transfer-on-request scenarios, transparent performance reporting, and outcome-based accountability that regulators and enterprise customers are increasingly requiring from BPO partners.

Revenue Protection

Customer trust is the underlying asset that both regulatory frameworks are trying to protect. SONIQCX protects that asset proactively through quality interactions, real human engagement, and measurable outcomes - not because regulation requires it, but because it drives better economics.

Discuss Your Compliance Position

This analysis is published by SONIQCX for informational and thought leadership purposes. It is based on publicly available regulatory materials as of March 2026, including the FCC Notice of Proposed Rulemaking and S. 2495 bill text. Neither framework described here has been enacted as final law as of this publication date. The FCC NPRM is a proposal subject to public comment and revision. S. 2495 is a Senate bill that has not been enacted. This content does not constitute legal advice. Specific details may change as regulatory processes develop. Companies should consult qualified legal counsel to assess their specific situation under applicable regulatory frameworks.