Keep Call Centers in America Act: Key Requirements

Written by: Matt Beucler, CEO, Plura AI

Key Takeaways

• S.2495 requires 120-day DOL notice before any offshore relocation of call-center work and bars noncompliant firms from federal grants or loans.
• Agents must verbally disclose their physical location and AI involvement at the start of every customer interaction, and callers can request transfer to a U.S.-based human agent.
• The law applies to any U.S. employer operating or contracting call-center work for 50 or more employees and interacts with the FCC NPRM (CG Docket No. 26-52) and state onshoring statutes.
• Operators must maintain detailed documentation, including call recordings, routing logs, and infrastructure records, to support their compliance posture and avoid DOL public-list placement.
• Plura supplies the FCC-licensed carrier and 100% U.S. infrastructure by architecture that enables operators to document “100% U.S.-handled” status, see how the platform supports your compliance requirements.

Executive Summary

S.2495 imposes four core obligations: advance notice to the DOL before relocating call-center work, real-time disclosure of agent location and AI involvement, on-demand transfer to a U.S.-based human agent, and federal-funding consequences for noncompliance. The bill interacts directly with the FCC’s Notice of Proposed Rulemaking (NPRM) in CG Docket No. 26-52 and with active state-level onshoring statutes.

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Scope of the S.2495 Keep Call Centers in America Act of 2025

S.2495 is federal legislation introduced in the 119th Congress that establishes disclosure, notice, and other obligations for U.S. employers that operate or contract call-center work. The bill’s scope extends to any business operating or contracting call-center work, regardless of industry vertical.

S.2495 operates alongside, but independently from, the FCC’s March 2026 draft NPRM (CG Docket No. 26-52). The FCC draft NPRM proposes rules that would apply to telecommunications carriers, VoIP providers, cable operators, satellite broadcasters, and affiliated internet access providers, while S.2495 applies broadly to any covered employer. The FCC proposal would require covered communications providers to disclose when a consumer call is routed to an offshore call center, allow consumers to request transfer to a U.S.-based representative, track and report compliance, and restrict certain sensitive customer data transactions to U.S.-based contact centers only.

A companion bill, the Foreign Robocall Elimination Act (H.R. 6152 / S. 2666), would require voice service providers handling U.S.-bound international calls to post bonds of up to $100,000 and create an interagency robocall enforcement task force. State laws in New York, New Jersey, Connecticut, Missouri, and Florida add additional layers that may apply concurrently with federal requirements. Operators should consult qualified legal counsel to assess how these frameworks interact for their specific operations.

Which Employers Fall Under S.2495

The Keep Call Centers in America Act applies to businesses that operate or contract call-center work.

“Call-center work” under the bill encompasses customer service, sales, and support functions handled via telephone or electronic communication on behalf of a U.S. business.

Coverage is determined at the employer level, not the individual facility level. Operators running distributed contact-center networks, franchise systems, or agency-managed call operations should assess aggregate headcount and hours across the enterprise when determining coverage. Consult qualified legal counsel for a definitive coverage determination.

Caller Disclosure and Transfer Requirements

Under S.2495, customer service agents must disclose their physical location and whether AI is involved when interacting with callers, and callers must be able to request and receive a transfer to a U.S.-based human agent. These disclosures are required at the outset of each interaction.

The following sample verbal disclosure scripts reflect the framework described in S.2495 and the parallel FCC NPRM. They are provided for illustrative purposes only and do not constitute legal advice. Operators should have qualified counsel review any disclosure language before deployment.

• Domestic human agent: “Thank you for calling [Company Name]. My name is [Agent Name] and I’m located in [City, State]. How can I help you today?”
• AI agent, domestic infrastructure: “Thank you for calling [Company Name]. You’re speaking with an AI assistant. All calls are handled on U.S.-based infrastructure. You may request a transfer to a U.S.-based human agent at any time.”
• Offshore agent (if applicable under the 30% FCC cap): “Thank you for calling [Company Name]. I’m located in [Country]. You have the right to request a transfer to a U.S.-based representative at any time.”

Financial and Operational Consequences

The Keep Call Centers in America Act (S.2495) requires customer-service agents to disclose their physical location and makes companies that relocate call-center work overseas ineligible for certain federal grants or loans. The DOL publishes a public list of firms that have offshored customer support. Firms on the DOL list become ineligible for new federal grants or guaranteed loans.

Civil penalties under New York’s Call Center Jobs Act, a state-level analog, reach up to $10,000 per day. Federal grant and loan ineligibility under S.2495 compounds the financial exposure for operators that rely on government-backed financing or federal contracting revenue. Federal agencies are also required to prioritize contracting with companies that keep call centers in the United States, and any federally contracted call-center work must be performed onshore.

Impact on AI-Enabled Contact Centers

S.2495 permits the use of AI in call centers provided there is transparency about whether the interaction involves AI and a human fallback option is available upon request. AI-powered contact centers therefore face two distinct documentation obligations. They must provide real-time disclosure that the caller is interacting with an AI system and maintain a verified, on-demand transfer path to a U.S.-based human agent.

Infrastructure location matters as much as agent location. The FCC NPRM (CG Docket No. 26-52) would prohibit offshore call centers from handling sensitive customer information such as passwords, Social Security numbers, bank account numbers, and credit card numbers for entities under FCC jurisdiction. AI platforms that route voice traffic through foreign infrastructure or store call recordings offshore face exposure under both the NPRM and S.2495’s documentation requirements. Operators should consult qualified legal counsel to assess their specific infrastructure posture.

Core Requirements and Documentation Table

The table below consolidates the core obligations under S.2495, the threshold that triggers each requirement, the timing, and the documentation operators typically maintain to support their compliance posture.

Obligation	Threshold	Timeline	Documentation Needed
120-day DOL relocation notice	Covered employers	Before any offshore relocation	Written notice to DOL with relocation details
Verbal location and AI disclosure	All covered interactions	Start of every customer interaction	Script records, call recordings, audit logs
Caller transfer right to U.S. human agent	All covered interactions	On-demand during any interaction	Transfer logs, routing records
Ineligibility for federal grants or loans	Firms relocating call centers overseas	Ongoing	Documentation of U.S. operations
Federal grant/loan eligibility maintenance	Firms on DOL public list	Ongoing unless remediated	Evidence of job repatriation or contract amendment

Federal and State Onshoring Rules Compared

S.2495 operates alongside state-level onshoring statutes, and multi-state operators often must align with whichever framework imposes the most restrictive standard. The table below maps key requirements, covered entities, and primary sources for the federal framework and several active state regimes.

Jurisdiction	Key Requirement	Covered Entities	Primary Source
S.2495 (Federal)	120-day DOL notice, verbal location and AI disclosure, transfer rights, ineligibility for federal grants or loans	U.S. employers operating or contracting call-center work, all industries	Congress.gov
FCC NPRM CG Docket 26-52	30% offshore cap (proposed), sensitive-data prohibition, disclosure and transfer rights, compliance reporting	Telecom carriers, VoIP, cable, satellite, and affiliates	Federal Register / FCC.gov
New York Call Center Jobs Act	90-day DOL notice before offshore relocation, public list, penalties up to $10,000 per day	100+ employees, 30% or more of call-center volume offshore	NY Department of Labor
New Jersey (mirror statute)	Mirrors NY structure, notice and public-list requirements	Covered employers per NJ statute	NJ.gov Wage and Hour
Connecticut	State-contract bans for offshore call-center operators	State contractors	Connecticut General Assembly

Compliance Checklist for Employers With 50 or More Employees

1. Determine coverage. Consult qualified legal counsel for a definitive assessment of whether S.2495 applies to your operations.
2. Audit current offshore exposure. Map every vendor, subcontractor, and technology platform that touches customer interactions. Identify any infrastructure, data storage, or call routing that sits outside the United States.
3. Establish a 120-day notice protocol. Any planned relocation of call-center work overseas requires written notice to the DOL at least 120 days in advance. Build this into vendor-contract and operational-change workflows.
4. Draft and deploy verbal disclosure scripts. Every customer interaction must open with agent location and AI-involvement disclosures. Have qualified counsel review scripts before deployment.
5. Implement a U.S.-agent transfer path. Callers must be able to request and receive a transfer to a U.S.-based human agent. Document routing logic and test transfer completion rates.
6. Build a compliance documentation process. Assign ownership of compliance documentation. Create an internal audit trail that supports compliance with call records, routing logs, and infrastructure documentation.
7. Document infrastructure location. Obtain written confirmation from every technology vendor that voice origination, model hosting, data storage, and call recording sit on domestic infrastructure. Retain records for audit purposes.
8. Review federal grant and loan exposure. If the organization holds or pursues federal grants or guaranteed loans, assess the financial impact of potential DOL-list placement and build remediation triggers into vendor contracts.
9. Monitor FCC NPRM CG Docket No. 26-52. The FCC’s proposed 30% offshore cap and sensitive-data prohibition apply to covered communications providers and may affect operators that use telecom services subject to FCC jurisdiction. Track the rulemaking docket for final rule publication.
10. Assess state-law obligations concurrently. New York, New Jersey, Connecticut, Missouri, and Florida each impose separate requirements. Multi-state operators should map obligations by state and apply the most restrictive applicable standard where requirements overlap.

Walk through how Plura’s infrastructure documentation maps to your compliance checklist.

How Plura AI Supports 100% U.S.-Handled Documentation

Plura AI is an FCC-licensed platform. Voice originates on Plura’s own domestic audio bridging carrier, not a third-party Communications Platform as a Service (CPaaS: the API-only telecom layer that providers like Twilio sell to AI vendors that do not own their own carrier).⁴ Model hosting, data storage, and call recording all sit on U.S. infrastructure by architecture. Operators using Plura can document “100% U.S.-handled” status without offshore exposure under the FCC NPRM, S.2495’s infrastructure documentation requirements, or state onshoring laws.

The platform’s compliance engine addresses the documentation obligations S.2495 imposes by maintaining audit-ready records across every regulatory framework that intersects with call-center operations: TCPA (Telephone Consumer Protection Act) for consent management, DNC (Do Not Call) for registry compliance, HIPAA (Health Insurance Portability and Accountability Act) for healthcare data handling, SOC 2 and ISO certifications for infrastructure security, GDPR for cross-border data transfers, and SHAKEN/STIR (Secure Telephone Identity Revisited / Signature-based Handling of Asserted information using toKENs) for caller ID verification on every outbound voice call.¹ Real-time DNC scrubbing checks every number against federal and state registries before dial, so consent records are timestamped, immutable, and audit-ready. The compliance dashboard exports these records in one click, supporting the annual FTC certification filing described in the checklist.

For S.2495’s verbal disclosure and transfer-right requirements, Plura’s no-code workflow builder allows operators to configure opening disclosure scripts at the conversation node level, with warm-transfer routing to a U.S.-based human agent on demand. Every interaction is logged to the Stateful Conversation Database, providing the call records and routing documentation that support annual FTC certification filings.

Plura’s AI agents handle voice, SMS (Short Message Service), RCS (Rich Communication Services), and webchat on the same stateful infrastructure, so disclosure and transfer logic applies consistently across every channel. The platform’s TCO (Total Cost of Ownership) of $300,000-$700,000 per year replaces the traditional $4M-$7M contact-center cost structure on equivalent volume, per Plura’s AI communications strategy guide.³

Customers are responsible for their own regulatory obligations, certifications, and the claims they make to their own end users. Plura provides the infrastructure, and compliance posture downstream of that infrastructure remains the customer’s responsibility. Operators should consult qualified legal counsel before making any compliance representations to regulators or customers.

Conclusion and Next Steps

The compliance framework described above, including advance DOL notice, real-time disclosure, transfer rights, and federal-funding exposure, applies to any covered employer operating or contracting call-center work. These obligations interact with the FCC NPRM (CG Docket No. 26-52) and active state laws in New York, New Jersey, Connecticut, Missouri, and Florida.

Operators with offshore vendor exposure, AI-powered contact centers, or federal grant and loan dependencies carry the heaviest documentation burden. The checklist above provides a practical starting point, and qualified legal counsel should review any compliance program before implementation.

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Frequently Asked Questions

Does the Keep Call Centers in America Act apply to companies that use AI agents instead of human offshore agents?

S.2495 applies to covered employers based on employee count and hours thresholds, and it separately requires disclosure of AI involvement in customer interactions. A company that uses AI agents is not automatically exempt from the disclosure and transfer-right obligations. The bill requires that callers be informed when AI is involved and that they retain the right to transfer to a U.S.-based human agent on request. Operators using AI contact-center platforms should assess whether their infrastructure qualifies as “U.S.-handled” and whether their disclosure scripts align with the bill’s framework. Consult qualified legal counsel for a definitive assessment of how S.2495 applies to your specific deployment.

What is the difference between S.2495 and the FCC NPRM in CG Docket No. 26-52?

S.2495 is federal legislation that applies broadly to any covered employer that operates or contracts call-center work, regardless of industry. It is enforced through the DOL. The FCC NPRM (CG Docket No. 26-52) is a proposed rulemaking that proposes rules for telecommunications carriers, VoIP providers, cable operators, satellite broadcasters, and their affiliates. The NPRM proposes a 30% cap on offshore customer-service call volume, a prohibition on offshore handling of sensitive consumer data, and mandatory disclosure and transfer-right requirements. Both frameworks can apply simultaneously to a covered communications provider that also meets S.2495’s employer threshold. The NPRM is still in the proposed rulemaking stage.

What documentation does an operator need to support the annual FTC certification under S.2495?

The Keep Call Centers in America Act (S.2495) requires customer-service agents to disclose their physical location and makes companies that relocate call-center work overseas ineligible for certain federal grants or loans. Supporting documentation typically includes call records demonstrating verbal disclosure at the start of each interaction, routing logs showing transfer completion rates to U.S.-based human agents, infrastructure documentation confirming domestic location of voice origination, data storage, and call recording, and records of any DOL relocation notices filed. Operators using AI contact-center platforms should obtain written confirmation from their technology vendors that all infrastructure components sit on U.S. soil. The specific documentation standard for compliance should be confirmed with qualified legal counsel.

How do state onshoring laws interact with S.2495 for multi-state operators?

Multi-state operators face overlapping obligations. New York’s Call Center Jobs Act requires 90-day advance notice before offshore relocation and imposes penalties up to $10,000 per day. New Jersey’s mirror statute applies similar requirements. Connecticut bans state-contract awards to offshore call-center operators. Missouri and Florida impose additional restrictions on offshore handling of medical and financial data. Where state requirements are more stringent than S.2495, the state standard generally governs for in-state operations. Operators should map their obligations state by state and apply the most restrictive applicable standard where requirements overlap. Qualified legal counsel should review multi-state compliance programs before implementation.

Can an AI contact-center platform satisfy the “U.S.-based human agent” transfer requirement under S.2495?

The transfer-right requirement described earlier mandates that callers can request escalation to a U.S.-based human agent at any point in the interaction. An AI contact-center platform can support this requirement by routing transfer requests to a U.S.-staffed escalation queue, but the human agent receiving the transfer must be physically located in the United States. Platforms that route escalations to offshore human agents do not satisfy this requirement regardless of the AI infrastructure’s domestic location. Operators should verify that their escalation routing logic terminates with a U.S.-based human agent and document that routing path for annual FTC certification purposes. Consult qualified legal counsel to confirm that your specific transfer implementation aligns with the bill’s framework.

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