FCC Proposes Sweeping New “Call Center Onshoring” Rules Affecting Telecom, VoIP, Broadband, Cable, And Direct Broadcast Satellite Providers

On April 23, 2026, the Federal Communications Commission (“FCC,” “Commission”) published in the Federal Register a Notice of Proposed Rulemaking titled “Improving Customer Service and Protecting Consumers Through Onshoring.” The NPRM proposes a broad new regulatory framework intended to encourage the onshoring of customer service operations, restrict the use of foreign call centers for sensitive consumer interactions, and impose new transparency, reporting, and consumer-choice obligations on covered communications providers. Comments are due May 26, 2026, and reply comments are due June 22, 2026.

The FCC proposes to apply the new requirements to providers of telecommunications services, commercial mobile radio service (“CMRS”), interconnected VoIP service, cable television service, and direct broadcast satellite (“DBS”) service, as well as such providers’ affiliates. The Commission also proposes applying these rules to foreign call centers used for customer communications about internet services, and asks whether it has the legal authority to expanded the proposed rules to cover these and other types of communications service providers.

Executive Summary

The NPRM is significant because it would move the FCC into direct regulation of where and how covered providers conduct customer service operations. Although framed around customer service quality and protection of sensitive consumer information, the proposal would impose operational, reporting, vendor-management, privacy, and national-security obligations on a wide range of communications providers.

If adopted, the proposed rules could require covered providers to:

• ensure that foreign call center representatives are proficient in spoken and written American Standard English;
• limit the percentage of customer service calls handled by foreign call centers (for example, to no more than 30% of all calls);
• disclose at the beginning of each call that the call is being handled outside the United States;
• provide customers the right to transfer to a U.S.-based representative, with no longer wait time than customers routed directly to U.S.-based representatives;
• ensure that sensitive transactions involving passwords, password resets, MFA codes, Social Security numbers, bank account numbers, or credit card numbers are handled only by U.S.-based representatives;
• prohibit the use of customer representatives located in “foreign adversary” nations (and potentially, employing citizens or residents of such nations);
• track and report compliance with the new requirements;
• add call-center-location information to broadband consumer labels; and
• potentially comply with additional requirements for non-voice customer service channels, including online chat, texts, and email.

The NPRM also seeks comment on using fees, bonds, or similar financial mechanisms to deter unlawful foreign-originated calls.

Who Would Be Covered?

The NPRM proposes applying the core foreign call center requirements to the following categories of providers:

• telecommunications service providers;
• CMRS providers;
• interconnected VoIP providers;
• cable television operators;
• DBS providers;
• affiliates of the foregoing providers that provide internet access service; and
• potentially, other communications providers, including stand-alone internet access providers, non-interconnected VoIP providers, and other internet-only providers, if the FCC determines it has legal authority to reach them.

This scope is especially important because the NPRM is not limited to traditional telecommunications carriers. Cable operators, DBS providers, broadband providers, interconnected VoIP providers, and affiliated internet access operations may all be affected if they use foreign-based customer service representatives or make customer information available outside the United States.

Key Proposed Rules

1. English Proficiency Requirements for Foreign Call Center Representatives

The FCC proposes to require covered providers using offshore call centers to ensure that foreign call center staff are proficient in both spoken and written American Standard English. The Commission seeks comment on whether this requirement should include not only vocabulary and grammar, but also understanding of tone, idioms, and American cultural context.

The NPRM asks how such proficiency should be measured, whether individual representatives should be tested, whether call centers should be assessed by average scores, and whether existing language exams such as TOEFL, TOEIC, or other workplace-oriented assessments would be appropriate. The Commission also asks how to treat foreign call centers serving non-English-speaking U.S. customers, including whether representatives handling Spanish-language or other non-English communications should still be required to maintain some English proficiency because account records, scripts, and support materials may be maintained in English.

2. Caps on Foreign Call Center Use

The FCC proposes to limit the percentage of customer service calls that covered providers may make from, or answer at, foreign call centers. The specific cap has not yet been set; the proposed rule text uses a placeholder percentage, and the NPRM asks whether a 30% limit would be appropriate.

The FCC seeks comment on how to calculate the cap, including whether it should apply separately to inbound and outbound calls, whether inbound and outbound calls should be aggregated, and whether compliance should be measured daily, monthly, quarterly, or annually. The Commission also asks whether the cap should be phased in to account for transition costs, domestic labor capacity, and operational burdens, particularly for small and rural providers.

3. Mandatory Disclosure of Foreign Call Center Use and Right to Transfer

The proposed rules would require covered providers to inform customers at the beginning of each call that the call is being handled by a representative located outside the United States. Providers would also be required to tell customers that they have the right to transfer the call to a representative located within the United States. Upon request, the provider would have to transfer the call, and the wait time for transferred calls could be no longer than the wait time for calls routed directly to U.S.-based representatives.

This proposal could require providers to redesign call scripts, IVR routing, workforce management, transfer protocols, vendor contracts, and compliance-monitoring systems.

4. U.S.-Only Handling of Sensitive Consumer Transactions

The NPRM proposes a particularly important privacy and security rule: certain transactions involving sensitive consumer information would have to be handled only by customer representatives located within the United States. The proposed rule identifies passwords, password resets, multi-factor authentication codes, Social Security numbers, bank account numbers, and credit card numbers as examples of information that may trigger this requirement.

Notably, this requirement would apply not only to voice calls, but also to other customer service communications such as email, text messages, and online chat when those communications involve access to or transmission of sensitive consumer, account, or financial information.

The FCC also seeks comments on whether it should go further and prohibit providers from making certain sensitive consumer information available for access at foreign call centers at all.

5. Proposed CPNI Rule Amendments

For telecommunications carriers, the FCC proposes to amend its Customer Proprietary Network Information (“CPNI”) safeguards rule, 47 C.F.R. § 64.2009, to add new obligations where a carrier or its affiliate uses foreign customer representatives or otherwise uses CPNI outside the United States.

The proposed CPNI rule would require a telecommunications carrier or covered affiliate that uses customer representatives located outside the United States, uses CPNI outside the United States, or makes CPNI available to a foreign customer representative to:

• ensure foreign representatives are proficient in spoken and written American Standard English;
• ensure that no more than a specified percentage of calls to or from customers are handled outside the United States;
• disclose at the beginning of each call that the call is being handled outside the United States;
• provide a right to transfer to a U.S.-based representative;
• ensure sensitive consumer, account, or financial communications are handled by U.S.-based representatives;
• avoid use of customer representatives located in foreign adversary nations; and
• track and report compliance.

The NPRM also asks whether these requirements are necessary to ensure compliance with Section 222 of the Communications Act and the FCC’s CPNI rules, including as applied to interconnected VoIP providers under the Commission’s ancillary authority.

6. Foreign Adversary Restrictions

The FCC proposes to prohibit covered providers from using call centers located in “foreign adversary” nations, as defined by Department of Commerce regulations. The Commission also seeks comment on whether it should go further by prohibiting use of any call center, wherever located, that employs citizens or residents of foreign adversary nations.

This proposal is part of a broader FCC trend toward integrating national-security and foreign-adversary concepts into communications regulation. For providers with offshore customer support, vendor relationships, subcontracting arrangements, or distributed workforces, this proposal could require careful mapping of call center locations, employee access rights, subcontractor chains, and data-access permissions.

7. Broadband Label and Transparency Requirements

The FCC proposes to amend the broadband consumer label rules to require broadband internet access service providers to disclose the percentage of customer service calls handled by customer representatives located within the United States. The proposed disclosure would be added to the existing “Customer Support” section of the broadband label, below phone number and website information.

The Commission also seeks comment on whether providers of non-broadband services covered by the proposed rules should be required to make similar disclosures on their websites.

8. Reporting, Certification, and Compliance Tracking

The NPRM asks whether providers should be required to submit monthly, quarterly, or annual reports regarding foreign call center use, English proficiency, transfer rates, complaint rates, and other metrics. The Commission also asks whether providers that obtain numbering resources from the North American Numbering Plan Administrator should be required to certify compliance as a condition of obtaining numbering resources.

These proposals could create new recordkeeping and reporting obligations for providers that have not historically treated customer service location data as a regulated FCC compliance metric.

Potential Extension to Online Chat, Texts, Email, and Other Communications Channels

Although several proposed rules focus on calls, the NPRM expressly seeks comment on whether the FCC should apply all of the proposed requirements, not only the sensitive-transaction rules, to non-voice customer service channels, including online chat, text messages, email, and potentially video conferencing.

This could be one of the most consequential aspects of the proceeding. Many providers rely on distributed support teams, outsourced chat vendors, ticketing systems, or offshore back-office support for customer interactions that may not involve a traditional “call center.” If the final rules reach these channels, providers may need to revisit not only call-routing practices, but also customer support platforms, CRM access permissions, authentication workflows, and vendor data-processing arrangements.

Foreign-Originated Calls, Fees, Bonds, and Related Robocall Proceedings

The NPRM also goes beyond customer service onshoring. The Commission seeks comment on ways to increase the cost of unlawful calls originating outside the United States, including possible government-imposed fees on illegal traffic or bond requirements. The FCC asks whether bond obligations should apply to foreign providers, international gateway providers, providers that accept “mass” voice or text traffic from international sources, or providers that have been subject to traceback requests or removed from the Robocall Mitigation Database.

This portion of the NPRM should be read alongside other FCC robocall mitigation and caller-identification proceedings. In a related proceeding, the Commission has been considering new rules involving caller identity, call authentication, foreign-origin indicators, and restrictions affecting calls that originate abroad using U.S. NANP numbers. These proposals may have significant implications for legitimate communications providers, especially nomadic VoIP providers, resellers, international service providers, and providers serving customers who travel or operate globally.

Why Policy Advocacy Is Crucial

The FCC’s proposed rules on call center onshoring introduce a new layer of regulatory scrutiny that echoes concerns raised in earlier robocall and caller identity proceedings. As policymakers seek to address fraud and protect consumers, it is equally important to ensure that regulatory approaches remain precise, technologically realistic, and mindful of unintended consequences for legitimate service providers. Drawing on its prior advocacy in this space, the Consumer Access & Choice Coalition (“CACC”) offers a perspective grounded in promoting consumer choice, innovation, and fair competition while cautioning against overly broad measures that could disrupt lawful communications and impose disproportionate burdens across diverse provider models.

In prior advocacy, CACC has cautioned that overly broad foreign-origin labeling, rigid caller identity mandates, and one-size-fits-all compliance frameworks can create false positives, harm lawful providers, undermine consumer trust, and impose disproportionate burdens on smaller or consumer-focused providers.              

The call center onshoring NPRM raises similar issues. Providers that rely on offshore support, serve privacy-sensitive customer bases, operate nomadic or international communications services, or use reseller and vendor-based models may be affected in ways that are not fully captured by the FCC’s current framing. A coordinated coalition filing can help similarly situated stakeholders develop a more complete record, share costs, and advocate for rules that are targeted, technologically feasible, privacy-protective, and proportionate to actual risk.

What Providers Should Do Now

Affected providers should begin evaluating their current customer service and support operations, including:

• where customer service representatives are located;
• whether support is performed in-house, by contractors, or through subcontractors;
• what percentage of customer calls are handled inside versus outside the United States;
• whether foreign representatives access CPNI, PII, account credentials, payment information, MFA codes, or password-reset workflows;
• whether customer support vendors operate in or rely on personnel located in foreign adversary jurisdictions;
• how quickly calls can be transferred from foreign to U.S.-based representatives;
• whether existing call scripts disclose offshore handling;
• whether support through chat, email, text, and ticketing platforms involves offshore access to sensitive information; and
• whether broadband labels, websites, customer support disclosures, and compliance records would need to be updated.

Providers should also consider whether to file comments individually or participate through a coordinated coalition effort such as CACC. The NPRM leaves many critical questions unresolved, including the percentage cap, compliance measurement period, treatment of small providers, application to non-voice channels, scope of sensitive information, treatment of affiliates, legal authority, and potential alternatives to prescriptive onshoring mandates.

Next Steps

The CommLaw Group will continue monitoring this proceeding closely. Comments are due May 26, 2026, and reply comments are due June 22, 2026. Providers that may be affected by the proposed rules should consider engaging early, particularly if their business models depend on offshore customer support, outsourced customer service, international operations, nomadic VoIP services, reseller arrangements, or privacy-sensitive customer relationships.