HWG LLP Client Alert Update: (PDF)

By: Jennifer Bagg, Jocelyn Aqua, John Nakahata, Rakesh Patel, & Katie Mellinger

HWG is continuing to monitor the Federal Communications Commission’s (“FCC” or “Commission”) Notice of Proposed Rulemaking (“NPRM”) pertaining to offshore call centers, which was officially published in the Federal Register on April 23, 2026.  The NPRM remains largely unchanged from the draft version, discussed in our last client alert, but the Commission has made some notable updates to the final published version, which we have laid out below. The Commission will accept comments on the NPRM until May 26, 2026, and accept reply comments until June 22, 2026.

What’s Changed:

  • New Prohibition on Foreign Adversary Call Centers and Representatives: The Commission proposes to prohibit covered service providers from using call centers or customer service representatives located in “foreign adversary” countries to protect U.S. consumers’ sensitive, personally identifiable data. The Commission follows the Department of Commerce’s designation list of “foreign adversaries” found in 15 C.F.R. § 791.4, which includes China, Cuba, Iran, North Korea, Russia, and Venezuelan politician Nicolás Maduro.
  • New Broadband Label Transparency Requirements: The Commission proposes to amend its Broadband Label rule, 47 C.F.R. § 8.1, to require covered broadband service providers to display, in the labels, the percentage of customer service calls handled by representatives located within the United States.
  • New Transparency Requirements for Non-Broadband Service Providers: The Commission proposes to require providers of non-broadband services, such as telecommunications service, commercial mobile radio service (“CMRS”), interconnected voice over internet protocol (“VoIP”) service, cable television service, and direct broadcast satellite (“DBS”) service, to make available, on their websites, the percentage of customer service calls handled by representatives located within the United States.

Providers should carefully assess how these proposals could impact their customer service operations, vendor relationships, and compliance strategies and consider filing comments.
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HWG LLP’s cross-disciplinary telecommunications practice and privacy practice advises clients on federal and state legislative and regulatory proceedings, company compliance, and related litigation matters. Please contact the authors for more information. This client alert update is not intended to convey legal advice. It is circulated publicly as a convenience and does not reflect or create an attorney-client relationship.