For over two decades, global Customer Experience (CX) delivery has been anchored in the core principle of cost optimization. The largest and the most effective tool enterprises have used to that end has been through offshore scale. That model is now coming under pressure from a different force altogether. And this time it isn’t technology disruption, but regulatory intent.
Recent developments in the US, which include the Federal Communications Commission (FCC)’s Notice of Proposed Rulemaking (NPRM) and the proposed Keep Call Centers in America Act (KCCAA), signal a decisive shift toward transparency, customer rights, and tighter control over CX delivery models.
This does not mean the industry is headed toward blanket reshoring. It means offshore CX is entering a more regulated era, where delivery models will need to be more transparent, segmented, and tightly governed.
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What the new regulations cover
FCC NPRM directly targets telecommunications and related providers. It proposes upfront disclosure of agent location, gives customers the option to transfer to a US-based agent, and tightens scrutiny on offshore handling of sensitive customer data. It also points to stronger expectations around language proficiency, offshore concentration, and compliance reporting. Because it is a live rulemaking process, it could move relatively quickly from proposal to enforcement.
The KCCAA extends the issue beyond telecommunications. It pairs offshoring-related provisions with financial and reputational consequences, including advance notice before relocating call center work, penalties and public disclosure for noncompliance, and possible limits on access to federal funding. It also strengthens customer rights around agent location and requires disclosure when Artificial Intelligence (AI) is used in customer service.
Even before formal enforcement, regulatory intent is beginning to shape enterprise behaviors, procurement expectations, and risk assessments. In that sense, the impact starts well before the rules are fully in force.
Who is most exposed
Exposure will not be uniform across enterprises. The most exposed are telecommunications, broadband, cable, and Voice-over-Internet-Protocol (VoIP) providers within FCC scope; companies with large offshore voice operations in sectors such as Banking, Financial Services and Insurance (BFSI), healthcare, travel, and technology support; and organizations handling sensitive customer data offshore, particularly where regulatory scrutiny or federal funding exposure is high.
Digital-first enterprises with lower voice intensity are less exposed in the near term, but they will still face growing expectations around AI disclosure and transparency.
How enterprise CX models can get impacted
The regulatory direction toward greater transparency, control, and customer rights will reshape how enterprises design and govern CX delivery. The key implications include:
- Delivery location will become a visible part of the CX, with greater pressure to disclose agent location and enable access to US-based support
- CX delivery models will become more risk-segmented, with clearer separation between high-sensitivity and standard interactions
- Sensitive customer data will require tighter handling controls, with greater use of domestic or tightly governed environments
- AI-led interactions will require stronger disclosure, governance, and human fallback mechanisms
- Cost structures will shift toward hybrid delivery, increasing the need for automation, self-service, and smarter channel mix
- Governance expectations will also rise across internal operations and provider ecosystems, with greater emphasis on transparency, auditability, and compliance readiness
What enterprises should do now
Enterprises should move quickly from broad concerns about offshore exposure to a more targeted action plan. The priority areas are clear:
- Map exposure at the journey and workflow levels
Build a granular view across delivery locations, interaction types, data sensitivity, and provider dependence to identify where regulatory, operational, and customer-facing risks are most concentrated - Redesign CX delivery around risk segmentation
Separate high-sensitivity interactions from standard ones so that regulated or higher-risk work is routed through compliant environments, while lower-risk work continues to benefit from offshore and automated delivery - Consider plans for credible US fallback capacity
Plans for having enough domestic support capacity to respond to likely regulatory requirements and customer requests without disrupting service levels or cost structures - Strengthen governance across CX operations
Place greater emphasis on location transparency, auditability, AI disclosure, and human fallback mechanisms, especially for sensitive or escalated interactions - Reassess the role of providers
Enterprises should increasingly expect providers to support delivery redesign, compliance readiness, and operational resilience, not just supply capacity. That shift in provider expectations is discussed below
Impact on providers and key implications
The providers under the greatest pressure are offshore-heavy players, especially India- and Philippines-led models, providers with large voice-based CX portfolios, and those serving telecommunications and other highly regulated sectors such as financial services and healthcare. Exhibit 1 illustrates a heatmap to show how exposure varies more broadly by offshore concentration and client industry mix.
At a broader level, this regulatory shift requires providers to rethink both how they deliver CX and how they compete. Cost arbitrage alone will no longer be enough. Providers will increasingly be judged on their ability to deliver transparent, auditable, and compliant operations through hybrid delivery models that combine offshore, onshore, and AI-led channels more deliberately. Voice-heavy offshore work in regulated industries will face the greatest pressure, while automation, portfolio mix, and delivery footprint will become more important differentiators.
Final thoughts
The FCC NPRM and KCCAA are not isolated developments. While they are rules that are still in proposal or draft stages, they are early signs of a broader shift in how customer service will be designed, delivered, and governed.
The future of offshore CX will be defined by whether enterprises and providers can build models that are transparent, risk-aware, and flexible enough to adapt to a more regulated environment.
The winners in this next phase will not simply be those with the lowest-cost footprint. They will be those with the most credible ability to balance cost, compliance, customer choice, and operational control.
If you found this blog interesting, check out, CX Tech Edge: Contact center as a service is evolving into enterprise CX OS: Why enterprises must take note now – Everest Group Research Portal, which delves deeper into another topic relating to CX.
If you’d like to continue this discussion, contact Tushar Patela ([email protected]) or Sharang Sharma ([email protected]).