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Introduction

In March 2026, the Federal Communications Commission (FCC) advanced a proposal that would require telecom providers to disclose when customer service is handled outside the United States and allow customers to request US-based support at the point of interaction. The proposal was approved to move forward for public comment following a unanimous vote.

At first glance, this looks like a telecom compliance update. It’s bigger than that.

The real shift is structural: delivery location is moving from an internal design decision to a customer-influenced variable. That change introduces a new stress test for outsourcing models built around steady-state assumptions. Once choice exists, demand no longer distributes evenly across your operating footprint.

What the FCC offshore call center proposal actually introduces

The FCC’s proposal does not restrict offshore delivery. It introduces transparency and customer-level choice into how support is delivered. If implemented, organizations may be required to disclose offshore handling and provide customers with the option to request domestic-based support.

That distinction matters. For decades, location decisions have been driven by cost, scalability, and access to talent—with limited visibility to the customer. That separation allowed organizations to optimize globally without delivery location becoming part of how service was evaluated.

The proposal begins to remove that separation. Delivery location becomes part of the customer experience—not just the operating model.

Why this matters beyond telecom

When transparency becomes part of the operating requirement, location stops being something customers never see.

At the same time, customer expectations are less forgiving. According to PwC, 32% of consumers say they would stop doing business with a brand they love after just one bad experience—and trust and transparency are increasingly tied to how services are delivered, not just the outcome.

When customers are explicitly informed where support is delivered—and given a mechanism to request a different option—delivery location becomes part of how accountability is perceived. This applies immediately to industries where customer interactions are tied to regulated data, financial outcomes, or high‑stakes service interactions.

Where current outsourcing models are exposed by the FCC proposal

Most outsourcing strategies are built on stability across three assumptions: delivery location remains fixed, cost structures remain predictable, and performance can be managed within a consistent operating environment.

The introduction of transparency and customer choice introduces variability into each of these assumptions.

If demand begins to shift based on customer preference, even modest organizations can experience uneven volume distribution across delivery locations. That directly affects capacity planning, cost assumptions, and operational balance.

At the same time, maintaining a consistent customer experience across locations becomes more critical. Variability that may have been operationally manageable becomes more visible when customers are aware of where interactions are handled.

These exposures are not new. They have existed within most outsourcing models. What changes is that they are no longer contained within internal operations—and this is where “we can flex if we need to” often collides with contract realities, staffing ramp constraints, and routing limitations.

The models that hold up under this pressure are not the most efficient; they are the ones designed to rebalance demand without renegotiating the business or degrading the experience.

The implication for cost, performance, and flexibility

Cost is often the first lens applied to offshore delivery. Offshore models have consistently delivered cost advantages in the 40–60% range, depending on geography and function, as reflected across industry benchmarks.

The more material implication, however, is flexibility.

Models tightly optimized around a fixed geographic mix have limited ability to adapt when demand shifts. Introducing even partial onshore preferences, whether driven by regulation or customer choice, can disrupt cost efficiency and performance stability if the model was not designed to absorb change.

Organizations that have diversified delivery models—or deliberately built flexibility into capacity planning, governance, and contracts—are better positioned to respond without materially impacting performance.

What this looks like in practice

Consider a representative telecom provider operating with a blended delivery model where approximately 70–80% of customer support volume is handled offshore, and the remainder is supported domestically.

If even a small portion of customers—15–20%—begin requesting US-based support under a disclosure model, the impact is not linear.

Volume does not simply shift. It concentrates.

Domestic capacity, typically sized for a smaller share of total demand, would need to absorb a disproportionate increase in volume. Expanding that capacity is not immediate. Hiring, training, and onboarding introduce lag, while costs increase materially relative to offshore delivery.

At the same time, offshore capacity does not scale down at the same rate. Contracts, staffing models, and operating structures are often designed around committed volumes and forecasted routing patterns. The result is a temporary imbalance: excess offshore capacity alongside rising onshore demand.

Pressure emerges across several operational areas:

• Cost increases, as higher-cost domestic support absorbs incremental volume
• Service levels at risk, as onshore capacity catches up to concentrated demand
• Operational complexity, as routing, forecasting, and workforce planning become less predictable
• Consistency risk, if the experience differs by location in ways customers can now detect and react to

None of these outcomes reflects a failure of offshore delivery. They result from a model designed for steady-state conditions being forced to operate under customer-driven variability.

What leaders should be evaluating now

The FCC proposal is still under review, but the operating questions it raises are immediate:

• Dependency on offshore delivery: How much of the model assumes offshore locations remain unchanged?
• Flexibility of delivery: How quickly can volume shift across geographies without disrupting service or cost?
• Consistency of experience: Is the customer experience genuinely uniform across locations—or merely acceptable?
• Contract and capacity rigidity: Where are minimums, committed volumes, or ramp timelines limiting your ability to rebalance?
• Routing reality: If customer choice drives volume, can your routing logic and WFM model absorb concentrated demand without degrading the experience?
• Governance readiness: If location becomes more visible, are QA, compliance controls, and escalation paths equally strong across sites?

These are indicators of how the model performs under change—not just under steady-state conditions.

Final perspective

The FCC’s proposal does not challenge the value of offshore customer support. It changes the conditions under which that value is realized.

As customer awareness and regulatory visibility increase, the delivery location becomes more directly connected to experience, trust, and choice.

Outsourcing strategies built for stability will be tested by variability. The organizations that respond effectively will not be defined by whether they use offshore delivery, but by whether their model can adapt when customer preference moves faster than their operating structure.