If you’ve been putting off thinking about your offshore call center strategy, now’s the time to pay attention. The Keep Call Centers in America Act got reintroduced last summer with bipartisan support and some teeth we haven’t seen in previous versions. More importantly, it directly addresses AI in customer service, something earlier versions completely ignored.
What Changed in the 2025 Version
Senators Ruben Gallego (D-AZ) and Jim Justice (R-WV) introduced S. 2495 in July 2025, and the House followed with H.R. 4954 in August. The bill is currently sitting in the Senate Commerce, Science, and Transportation Committee, but here’s what makes this version different: it’s not just about offshoring anymore.
The AI Disclosure Requirements
Companies using AI, chatbots, or automated systems for customer service must now disclose that fact at the beginning of every interaction. Not buried in fine print. Not after three minutes of frustration. Right at the start.
And here’s the kicker: customers can immediately request transfer to a human agent located in the United States. No runaround, no “let me see what I can do,” just an immediate transfer.
This matters because customer frustration with AI systems has reached a breaking point. We’ve all been there, repeatedly saying “representative” into the void while a bot cheerfully ignores us. The bill acknowledges what everyone in CX already knows: AI works great until it doesn’t, and when it doesn’t, people want a human.
Location Disclosures
If your agent is physically located outside the United States, they must disclose that at the beginning of the call. Again, customers can request immediate transfer to a US-based agent.
This isn’t about banning offshore operations. It’s about transparency. Companies can still use offshore centers, but they can’t hide it.
The Federal Funding Hammer
Here’s where it gets expensive. Companies that relocate call centers overseas get added to a public Department of Labor list for five years. While on that list, they’re:
- Ineligible for federal grants
- Ineligible for federal guaranteed loans
- Excluded from preference consideration for federal contracts
- Required to pay monthly penalties equal to 8.3% of any federal funds already disbursed (with potential award cancellation after one year)
For federal contractors specifically, any call center work under those contracts must be performed inside the United States. No exceptions.
The Notice Requirement
Companies must notify the DOL at least 120 days before relocating call center work overseas or contracting at least 30% of call center work to offshore providers. Fail to do this? Up to $10,000 per day in civil penalties.
Annual FTC Certification
Companies must certify compliance with these disclosure requirements annually to the Federal Trade Commission. Violations get treated as unfair or deceptive acts under the FTC Act.
Who This Actually Affects
The bill applies to businesses with 50 or more full-time employees, or those employing 50+ workers who collectively work at least 1,500 hours per week.
Industries with the highest exposure:
- Financial services (banks, credit unions, mortgage servicers, fintech)
- Healthcare providers
- Telecommunications companies
- Retail operations
- Federal contractors across all sectors
When This Takes Effect
The disclosure requirements (both AI and location) would kick in one year after enactment. Other provisions, including the 120-day notice requirement and federal funding restrictions, would take effect immediate
How CTG Clients Can Prepare
Even if this bill doesn’t pass exactly as written, the direction is clear. Federal policy is moving toward transparency, domestic operations, and consumer choice in AI interactions.
Immediate Actions
Audit operations: Map touchpoints, agent locations, AI deployment, and vendor roles.
Check federal ties: Review contracts, grants, or loans that trigger compliance.
Update vendor contracts: Require location/AI disclosure and advance notice, you’re liable for violations.
Prep disclosure scripts: Build compliant location and AI transparency protocols.
Test US transfers: Ensure capacity to route customers to US-based human agents on demand.
The Bigger Picture
Several states already have similar requirements around offshore call center notifications. State-level laws vary, but generally include advance notice requirements (ranging from 100 to 120 days), penalties for non-compliance (up to $10,000 per day in some states), and funding restrictions for companies that offshore work. This federal bill would standardize and expand those protections nationwide.
More interesting: the AI disclosure requirements signal a broader policy shift. Regulators are starting to recognize that “AI or human” isn’t a technical question. It’s a consumer rights question.
For contact center leaders, this means AI deployment can’t just be about cost reduction anymore. You need transparency protocols, escalation paths, and genuine human backup when customers request it.
What Happens Next
The bill is still in committee. It could pass as-is, get amended, or die quietly. But the bipartisan support and the practical focus on both AI and offshoring suggest this has momentum.
Even if it doesn’t pass this year, the conversation has shifted. Five years ago, offshore operations were standard practice with minimal scrutiny. Now there’s genuine political pressure to bring work back, disclose AI usage, and give consumers choice.
How CTG Can Help
This is exactly the kind of strategic inflection point where our vendor intelligence and operational experience matter most.
Need to evaluate US-based BPO providers? We’ve vetted 40+ domestic providers and can shortlist options matched to your specific requirements within days.
Need to assess AI platforms with built-in disclosure capabilities? We track every major conversational AI vendor and can tell you which ones actually support compliant deployment.
Need to redesign your entire CX operation to comply with these requirements while maintaining service quality? Our 120+ former VP and SVP-level consultants have managed these exact transformations.
Whether this bill passes or not, the trend is clear: transparency wins, domestic operations get incentivized, and AI deployment needs thoughtful strategy, not just cost optimization.
We can help you navigate that shift.
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