On March 26, 2026, the FCC adopted a Notice of Proposed Rulemaking that takes direct aim at offshore call centers. If you run outbound calling operations, buy or sell leads, or contract with third-party call centers outside the United States, this proposal will change how you operate.
The timing is not accidental. Congress has been pushing the Keep Call Centers in America Act of 2025, and the FCC is now building regulatory scaffolding around the same concerns: consumer protection, transparency, and domestic workforce preservation. Together, these efforts mean offshore calling operations face real operational constraints for the first time.
Here is what was proposed, who it affects, and what you should be doing right now.
What the FCC Is Proposing
The NPRM introduces several requirements that would apply to telecommunications providers and, potentially, to any entity making TCPA-covered calls and texts. The core proposals include:
Caps on offshore call center usage. The FCC is considering requiring providers to limit the percentage of customer interactions handled by offshore call centers. The specifics of these caps are still being defined through the comment period, but the direction is clear: the agency wants to reduce dependence on foreign-based operations for consumer-facing calls.
Call-by-call disclosures. Under the proposal, when a consumer reaches an offshore agent, they would need to be informed that they are speaking with someone located outside the United States. This is not a one-time buried-in-the-terms disclosure. It would need to happen on every call, at the start of the interaction.
Right to request a US-based agent. Consumers would have the right to ask for a transfer to a domestically located agent. Providers would need to have the infrastructure to honor these requests, which means maintaining parallel domestic capacity even if the bulk of operations are offshore.
English proficiency standards. The FCC is proposing minimum English language proficiency requirements for call center workers handling US consumer calls. This addresses a common consumer complaint and adds a new dimension to workforce qualification requirements.
Reporting obligations. Providers would be required to report on their offshore call center usage, giving the FCC visibility into how extensively the industry relies on foreign operations. This data collection alone signals that enforcement is coming, not just rulemaking.
The Congressional Push: Keep Call Centers in America Act
The FCC is not acting alone. The Keep Call Centers in America Act of 2025, introduced as Senate Bill 2495, takes a legislative approach to the same problem. The bill aims to incentivize companies to keep call center jobs in the United States and imposes additional requirements on companies that move operations offshore.
When an agency rulemaking and a congressional bill are moving in parallel toward the same goal, the probability of some version of these restrictions becoming final goes up significantly. Companies that wait for final rules before preparing are going to find themselves scrambling.
Who This Affects
The obvious targets are telecommunications carriers and large service providers with offshore customer service operations. But the NPRM explicitly asks whether these rules should extend to TCPA-covered calls and texts.
That question should get the attention of every lead generation company, insurance marketer, home services provider, and financial services firm that uses outbound calling to convert leads.
If you are buying leads and routing them to offshore call centers for follow-up, you are squarely in the zone where these rules could apply. If you are a lead generator selling to buyers who use offshore calling operations, your leads may become harder to monetize if buyers face new compliance burdens on their calling operations.
The TCPA extension question is particularly significant. Current TCPA rules already require prior express written consent for marketing calls and texts. Adding offshore disclosure and transfer requirements on top of existing consent obligations creates a layered compliance challenge that many operations are not built to handle.
The Consent Verification Problem Gets Harder
Here is where this gets practical for lead generation companies.
Imagine a consumer fills out a lead form, gives consent to be contacted, and then receives a call from an offshore call center. Under the proposed rules, that call now requires a disclosure that the agent is offshore, and the consumer has the right to request a domestic agent.
Now imagine that same consumer files a TCPA complaint, claiming they never consented to be called in the first place, or that they were not informed they would be contacted by a foreign call center. Your defense depends entirely on what you can prove about the consent interaction.
If your consent documentation consists of a database record showing a form was submitted, you have a problem. That record does not show what the consumer actually saw, what disclosures were presented, or whether the consent language covered contact from offshore operations.
This is where consent verification becomes a front-line compliance function, not a back-office checkbox. When regulators are scrutinizing your offshore operations, every outbound call needs to trace back to a verifiable consent event. You need to be able to show exactly what the consumer agreed to, when they agreed to it, and what disclosures were visible at the time of consent.
Session-level evidence, the kind that captures the actual consent interaction as the consumer experienced it, becomes the difference between a defensible position and a costly settlement. eConsent’s consent certificates capture this evidence at the moment of consent: the full session recording, the disclosure language presented, the consumer’s affirmative action, and the technical metadata that proves the record has not been altered.
When an offshore-related complaint triggers a regulatory inquiry or litigation, that level of documentation is the difference between producing evidence and producing excuses.
What Your Consent Language Needs to Cover
If your lead forms currently include consent language authorizing contact by phone or text, you should evaluate whether that language is specific enough to cover offshore contact scenarios.
Under the proposed rules, consumers would have new rights specifically tied to offshore interactions. If your consent disclosures do not mention the possibility of offshore contact, you may face arguments that consent was not fully informed. While the FCC has not finalized whether consent language must explicitly address offshore calling, getting ahead of this issue eliminates a potential attack vector in litigation. If your forms say something generic like “I agree to be contacted by phone,” consider adding specificity about the methods and locations of contact.
The Reporting Angle
The proposed reporting obligations deserve special attention. When a regulator requires you to report on specific practices, enforcement of those practices typically follows. The FCC is building a data set that will let it identify industry patterns, outliers, and targets.
For lead generation companies, this means your relationship with downstream buyers and their calling operations matters more than ever. If your leads are flowing to buyers who are heavy users of offshore call centers, you are exposed to the compliance risks those buyers face, because consent challenges will trace back to the lead source.
Knowing where your leads end up and how they are being contacted is not just good business practice. Under this proposed framework, it is a compliance necessity.
Five Things to Do Right Now
1. Audit your calling operations and vendor relationships. Map every call center, domestic and offshore, that touches your leads or makes calls on your behalf. If you use third-party buyers or call centers, find out where their agents are located. You cannot comply with rules you do not understand the scope of.
2. Update your consent disclosures. Review every lead form, landing page, and consent flow for language that may need to be updated to address offshore contact scenarios. Even before rules are finalized, stronger disclosure language reduces litigation risk and strengthens your consent defense.
3. Implement verifiable consent documentation. Move beyond database timestamps and checkbox records. Capture session-level evidence of every consent interaction so you can produce proof of what the consumer saw and agreed to. eConsent’s consent certificates provide exactly this kind of auditable, tamper-proof consent evidence.
4. Build domestic call center capacity or contingency plans. If the right-to-request-a-domestic-agent provision becomes final, you need to be able to honor those requests. Start evaluating domestic call center options now, before demand drives up costs and reduces availability.
5. Submit comments on the NPRM. The FCC is accepting public comments on this proposal. If you have a position on whether these rules should extend to TCPA-covered calls, make it known. Industry participation in the comment period shapes the final rule. Sitting this one out means accepting whatever the FCC decides without your input.
The Bottom Line
The FCC’s offshore call center proposal is not a hypothetical. It is a formal rulemaking backed by parallel congressional action. The question is not whether restrictions are coming, but how broad they will be and how quickly they will take effect.
For lead generation companies, the intersection of offshore calling restrictions and TCPA consent requirements creates a compliance burden that demands better systems, better documentation, and better operational visibility. The companies that start preparing now will be the ones that keep operating smoothly when the rules go final.
The ones that wait will be the ones scrambling to explain why their consent records cannot answer the questions regulators are asking.