美国联邦通信委员会为外国呼叫中心提出新规则——覆盖范围可能会让你感到惊讶

US – March 2026 The Federal Communications Commission(FCC) is expected to adopt a Notice ofProposed Rulemaking (NPRM) that couldaffect businesses that either operate customer Indeed, the FCC makes clear that part of its motivation is thatconsumers “often are not satisfied with the customer servicethey receive from providers that have moved their customer But there are clear indications that the FCC is considering apotentially much broader application. First, the proposal would apply to “affiliates” of the CoveredProviders listed above. Per the NPRM, that would includeany entity that provides internet access service, and As proposed, such call centers outside the US would facenew obligations and restrictions on their ability to make calls.These include English proficiency requirements, caps onthe percentage of calls that can be handled by offshore call Second, the FCC is asking whether the proposed rules shouldapply to providers of internet-only services, such as internetaccess and non-interconnected VoIP, even if they have no Third, the FCC is asking whether the proposed rules shouldapply to non-voice communications such as email, textmessaging and online chat. These services are not currently Why Is the FCC Considering This Proposal? The FCC justifies the proposal on several grounds. It citesnumerous consumer complaints about unhelpful interactionswith representatives at foreign call centers. But it placesparticular emphasis on the lack of data security at foreign callcenters. The FCC notes that some call centers have failed toprotect consumers’ sensitive personal information. It points Fourth, the FCC indicated that call centers operated by thirdparties on behalf of Covered Providers may be subject to thesame requirements, on the grounds that entities subject toFCC regulation are responsible for the acts and omissions oftheir employees and independent contractors. That means Fifth, the FCC expressly opens the door to a much broaderapplication of the proposed rules, beyond call centers usedby Covered Providers or run by third parties on their behalf.Specifically, the FCC cites its jurisdiction under the TCPA toask whether it should “extend some or all of our proposals toall calls covered by sections 227(c) and (d) [of the TCPA] thatoriginate outside the US, not just calls on behalf of the typesof providers already discussed.” That could include all callsmade using any automatic telephone dialing system, and/orartificial or prerecorded telephone messages. The FCC’s fact The FCC also points to its jurisdiction under the TelephoneConsumer Protection Act (TCPA), and its concern with scamcalls originating abroad. Specifically, it indicates that “some ofthe foreign scammers who make scam calls to the US have In the end, however, the America-first and job-repatriationframing that Chairman Carr used in this public announcementis inescapable. How the proposal and potential modificationscould contribute to onshoring foreign call centers is likely to Who Would Be Covered? That is not entirely clear. As proposed, the rules apply to thecall centers of providers of telecommunications services,commercial mobile services, interconnected Voice over InternetProtocol (VoIP) services, cable television services and direct Does the Proposal Only Apply To Voice Calls? •Sensitive transactions and information– The FCC isproposing to prohibit Covered Providers from handlingconsumer transactions involving sensitive information Not necessarily, the proposed rules facially apply to phonecalls placed from, or received at foreign call centers used byCovered Providers. However, the FCC is considering whetherthe proposed rules should be broadened to cover non-voicecommunications such as email, text messaging and onlinechat.(such as passwords, and bank and credit card accountinformation) in call centers outside the US. It is alsoproposing to prohibit Covered Providers from making thissensitive information available at calling centers outside theUS. This transaction-level restriction would apply regardless What New Requirements Would Apply To •Tariffs and bonds– The FCC is considering measures toincrease the cost of unlawful calls originating outside theUS. One option is establishing a tariff that would applyto unlawful calls coming from foreign countries. Anotheroption is requiring Covered Providers to post a bond thatwould be drawn upon in cases of unlawful calls. Such arequirement may broadly apply to other providers, such •Percentage cap on calls– The FCC is proposing a cap onthe percentage of a Covered Provider’s calls that may behandled by a foreign call center. The proposed cap is 30%,but the FCC is seeking comments on whether that limitwould be appropriate and effective to improve customer •Prohibition of certain calls– The FCC is consideringmandating that phone transactions involving passwords,multifactor authentication information, or bank account orcredit card information be handled exclusively in US-basedca