FCC Proposes Rules for Offshore Call Centers and Phone Number Access

​In an open meeting held on March 26, 2026, the Federal Communications Commission (FCC) voted to adopt a Notice of Proposed Rulemaking (NPRM) proposing sweeping restrictions on the use of offshore call centers by FCC-regulated entities, including telecommunications carriers, VoIP providers, cable operators, satellite broadcasters, and their affiliated internet access providers.

The FCC also adopted an NPRM proposing significant changes to how telephone numbers are accessed, utilized, reported, and resold. If adopted in their current form, each of these NPRMs will dramatically transform both the telecommunications and the contact center industries.

The Offshore Call Centers NPRM

The Offshore Call Centers NPRM seeks public comment on ways to encourage and facilitate the onshoring of call center operations, and adopts rules in furtherance of that goal; rules which were initially proposed by FCC Chairman Brendan Carr in a March 4th announcement. The proposed rules are summarized below:

English Proficiency: Call center staff at offshore facilities must be certified as proficient in Standard American English.

Cap on Offshore Call Volume: Providers would be limited to routing no more than 30% of customer service calls to offshore centers (the specific threshold is open for comment).

Mandatory Disclosure: Providers must disclose at the start of every offshore-handled interaction that the call is being handled outside the United States, potentially including the specific country.

Consumer Transfer Right: Consumers must be offered the right to transfer to a U.S.-based representative at any point during an offshore interaction, with no longer wait times than calls initially routed to U.S. agents.

Sensitive Data Prohibition: Offshore call centers would be barred from handling any transaction involving sensitive consumer information — passwords, MFA codes, Social Security numbers, bank account numbers, and credit card numbers.

Tracking and Reporting: Providers would be required to track and report compliance metrics, including offshore call volumes, transfer completion rates, and language proficiency results.

The Offshore Call Centers NPRM seeks comment on financial deterrents for illegal robocalls originating abroad, including requiring bonds or imposing tariff-style duties on unlawful calls entering the U.S., potentially requiring a bond to file in the Robocall Mitigation Database.

The Commission also asks whether these rules should extend beyond voice to online chat, text, and email handled offshore, and whether they should apply to non-interconnected VoIP and internet-only service providers.

The Numbering Policies NPRM

The Numbering Policies NPRM was initially released in draft form on March 5th, 2026, when it was placed on the tentative agenda for the March 26th open meeting. The NPRM opens a new front in the Commission’s crusade against illegal robocalls by proposing significant changes to how telephone numbering resources are utilized, reported, and resold by voice service providers. The key proposals are:

Expanded Certification Requirements: Robocall mitigation certification obligations are currently limited to VoIP providers with direct number access. This would be extended to all service providers that receive numbering resources directly from the North American Numbering Plan Administrator (NANPA), and to resellers of telephone numbers. New certifications would require attestation of no-illegal-robocall use, STIR/SHAKEN compliance, 911 obligations, and CALEA compliance.

Single-Level Resale Restriction: The most consequential proposal would prohibit the resale of telephone numbers beyond a single level, targeting multi-tier resale chains that obscure accountability for parties conducting illegal robocall campaigns.

Enhanced NRUF Reporting: The Commission proposes improvements to the Numbering Resource Utilization/Forecast (NRUF) reporting system (FCC Form 502) to obtain more granular data on how numbers are assigned, used, and potentially misused, including better tracking of intermediate number holders who often evade current reporting obligations.

The NPRM seeks comment on whether the Tracking and Reporting Absent Community-Members Everywhere (TRACE) Act grants the FCC sufficiently broad authority to impose new access restrictions on potential robocallers, and also asks whether the FCC should delegate greater authority to state regulators to restrict access to numbering resources, and how to expand numbering data sharing with state regulators.

The NPRM Process Timeline

After the Commission votes to adopt an NPRM at an open meeting, its text is released publicly, setting out the proposed rules and a series of questions on which the agency seeks public input. Following that triggering event, the proposed rules outlined in the NPRM become final rules through the following process:

• Federal Register Publication (2–4 weeks after adoption): The NPRM is published in the Federal Register. This is the official start of the comment clock. Most FCC NPRMs set a 30 to 60-day initial comment period and a reply comment period running an additional 15–30 days after the initial deadline. Complex or controversial rulemakings sometimes receive extended or multiple comment windows.
  
• Comment & Reply Comment Period (1–4 months): Stakeholders — industry, consumer groups, state regulators, and the public — file initial comments, then reply comments responding to what others have filed. The docket is public on the FCC’s ECFS system.
  
• Ex Parte Period / Lobbying & Agency Review (3–18+ months):
After the comment window closes, FCC staff analyze the record, draft a Report and Order (R&O), and hold ex parte meetings with stakeholders. This is typically the longest and most unpredictable phase; politically significant rulemakings or those with heavy opposition can stall here for years, while more routine items may move in a few months.
  
• Circulation & Commissioner Votes: A draft R&O is circulated to all five commissioners for review. Commissioners may negotiate modifications, concur with reservations, or signal a dissent. A final vote is typically scheduled at a subsequent open meeting.
  
• Adoption of Report and Order (Final Rule): The Commission votes to adopt the R&O at an open meeting. The rules are officially “adopted” at this point, though they are not yet legally effective.
  
• Federal Register Publication & Effective Date (2–6 weeks after R&O adoption):
The R&O is published in the Federal Register. Rules not requiring Office of Management and Budget (OMB) approval under the Paperwork Reduction Act typically take effect 30 days after Federal Register publication. Rules containing new information collection requirements must first receive OMB approval, which can add several additional months before the rules become operative.