Call Center Compliance Flexibility As Rules Change Continuously

Regulations in the call center industry are constantly evolving, and businesses that don’t stay ahead risk costly disruptions. Recent shifts, such as the repeal of the FCC’s one-to-one consent rule and the ongoing Hobbs Act Supreme Court review, show how quickly compliance landscapes can change.

The key to long-term success is not guessing what will happen next. It’s building flexibility into your compliance strategy so you can adapt no matter what comes your way.

Regulatory uncertainty requires strategic flexibility

Compliance rules don’t stand still. 

If the FCC’s one-to-one consent rule taught call centers anything, it’s that regulations can shift overnight, leaving businesses scrambling to adjust. With the Supreme Court reviewing the Hobbs Act, yet another regulatory change could be on the horizon—one that could reshape how courts handle TCPA-related lawsuits.

Regulatory changes are unpredictable, but businesses don’t have to be caught off guard. Instead of trying to guess what will happen next, companies should focus on building flexible strategies that work under multiple scenarios. 

McKinsey research backs this up, emphasizing that the key to long-term compliance success isn’t predicting the future perfectly—it’s preparing for multiple possible outcomes. The companies that take this approach stay ahead of compliance risks, avoid wasted efforts, and pivot quickly when needed.

The FCC’s one-to-one consent rule may be gone, but businesses should take a broader lesson from the ruling. Just because the court struck down this specific regulation doesn’t mean compliance standards are becoming more lenient. In fact, scrutiny around consent practices is only increasing.

“We are in the midst of a complex regulatory environment,” says Aaron Parry, a Mac Murray & Shuster attorney. “It's only going to get more restrictive, and really, what they’re trying to do is protect consumers’ data, make sure that the consumer understands who they are consenting to contact them and do business with, and that all that is clearly disclosed.”

Compliance isn’t something you can set and forget. The businesses that stay ahead are the ones constantly adjusting, not waiting until they’re forced to react.

Eric Troutman, attorney at Troutman Amin, says, “Everything is changing under our feet. Our job is to be adaptable. Our job is to be thoughtful, intelligent, and adaptable, and respond to information as we receive it.”

Staying informed is just as important as having a solid compliance strategy. Reliable industry resources like Convoso’s articles and webinars help call centers track regulatory updates and adjust strategies before changes catch them off guard.

The FCC One-to-One Consent Rule repeal and its impact

You probably spent months preparing for the FCC’s one-to-one consent rule—adjusting lead generation, updating compliance processes, and maybe even shifting to in-house lead generation. Then, just days before it was set to take effect, the rule was struck down completely.

This is why businesses need compliance flexibility. McKinsey’s framework for strategy under uncertainty calls this "Level Two Uncertainty"—when companies can see possible outcomes but can’t predict which one will happen. 

With so much uncertainty around one-to-one, businesses had two choices: wait for clarity or take preemptive action. Some call centers held off on major changes, while others moved quickly to comply, only to find themselves unprepared when the Court of Appeals for the Eleventh Circuit overturned the rule.

For businesses that rushed in, the repeal was a costly lesson. Many companies made drastic compliance adjustments in anticipation of the rule, only to suffer major setbacks when it was revoked.

Michael Francik, Co-Founder of True Alliance, shared a real-life example from when the FCC first started discussing the one-to-one rule:

“The FCC [was] working on some possible regulation changes with consent. A lot of media companies pulled aged data off the market because they wanted to prepare for the regulatory changes to come. But a lot of businesses were dependent on that aged data, so as soon as it was pulled, their production dropped by 40-50%.”

Instead of reacting to every rule change, businesses need compliance tools that can adapt in real time. Advanced contact center software with automation and dynamic compliance features allows call centers to seamlessly adjust to new regulations rather than scraping together compliance solutions using outdated systems.

In contrast, businesses that hardcode compliance rules into rigid systems or rely on outdated dialers often find themselves restructuring entire workflows whenever regulations shift, wasting both time and resources.

Regulations aren’t slowing down, and businesses that stick to rigid strategies will struggle to keep up. The key is building adaptability now before the next rule forces another scramble.

The Supreme Court review of the Hobbs Act and why it matters

Another major compliance issue call centers need to watch is the Supreme Court’s review of the Hobbs Act. This decades-old law requires district courts to defer to federal agencies’ interpretations of the laws they enforce—including the FCC’s rulings on the TCPA.

For call centers, this means that any district court hearing a TCPA case must follow the FCC’s rulings, even if there are arguments that the agency got it wrong. 

“Any district court that hears a case on the TCPA that is affected by these new rules will be required to follow the ruling that the FCC issued,” Michele Shuster, founding partner at Mac Murray & Shuster, says. 

“[The Hobbs Act] has a significant impact on the TCPA and the requirement for the district courts to follow what the FCC has put out there.”

This setup keeps rulings consistent but also limits businesses from pushing back against outdated or overly broad FCC interpretations—some of which may no longer align with modern communication technology.

To put this into perspective, Spencer Elg, general counsel at What If Media Group, gives an example:

“If a company is sued for sending text messages and argues that the TCPA shouldn’t cover text messages because they didn’t exist when the law was enacted, the court would follow the FCC’s ruling that text messages are covered. Even if a company believes the FCC’s interpretation is wrong or unsupported by the statute, the Hobbs Act prevents it from challenging that interpretation in court.”

Elg’s example highlights the real-world impact of the Hobbs Act: businesses cannot challenge FCC interpretations, even when they appear outdated. The Supreme Court is now reviewing whether that restriction should remain in place.

If the Hobbs Act is overturned, call centers could face a wave of inconsistent rulings, making TCPA compliance harder to predict.

If the Hobbs Act remains in place, businesses won’t face the same level of legal uncertainty—but they must continue to follow FCC guidance closely, knowing that future agency rulings could still introduce new compliance burdens.

This uncertainty is precisely why McKinsey warns against relying too much on existing rules. When businesses assume stability, they set themselves up for surprises. 

With the Hobbs Act under review, call centers must stay informed and flexible—because regulatory frameworks can shift at any time. Call centers that build flexible compliance strategies now won’t have to overhaul processes in a panic, no matter how the courts rule.

What call centers can learn from these compliance shifts

If the FCC’s one-to-one consent rule repeal and the Hobbs Act Supreme Court review prove anything, it is that regulatory uncertainty isn’t going away. Compliance rules can shift unexpectedly, and if you are not actively monitoring legal developments, you could be forced into costly last-minute adjustments that disrupt operations.

McKinsey’s research on navigating uncertainty suggests that businesses should not just react to rule changes after they happen. Instead, you should monitor "trigger points"—early warning signs that indicate which regulatory outcome is becoming more likely.

This is exactly what successful call centers did with the one-to-one rule challenge.Businesses that tracked key trigger points saw signs that the rule might not take effect as planned, giving them time to plan for different scenarios instead of making rushed, expensive changes. 

Some of the warning signs included:

• Multiple legal challenges from industry groups arguing that the FCC overstepped its legal authority.

• Growing political pressure. Business groups and trade associations warned that the rule would harm lead generation and outbound sales.

• Insights from oral arguments. Legal experts, including Michele Shuster, noted that the 11th Circuit judges appeared skeptical of the FCC’s position, signaling that the rule was at risk of being overturned.

These signals allowed businesses to hold off on costly, irreversible changes and instead develop flexible strategies they could adjust based on the final outcome.

By keeping an eye on these early indicators, businesses can prepare in advance, ensuring they stay compliant without making unnecessary, disruptive changes. Companies that wait until a ruling is final risk reconfiguring operations at the last minute, while those that track key regulatory trends can stay ahead of compliance shifts before they become urgent.

6 ways to stay ahead of regulatory changes and manage compliance

So how do you avoid scrambling every time a new rule is proposed or overturned? The key is building flexibility into your compliance strategy so you can adjust quickly when regulations shift. 

Here are concrete steps to make your compliance approach more adaptable.

1. Diversify lead generation sources to avoid single points of failure

Relying too heavily on one method of obtaining leads, like third-party lead vendors with rigid consent structures, can put your business at risk when regulations change. Instead, invest in multiple lead-generation channels, including in-house lead generation, multi-channel opt-ins (web, SMS, and inbound calls), and AI-driven lead verification tools.

“Now’s a good time to diversify your sales approach because it’s important for mitigating risk. If all of your eggs are in one basket and something breaks, it’s completely detrimental to your company,” Francik says.

While diversifying lead sources is essential, businesses must also ensure that the leads they acquire comply with legal requirements. Without proper oversight, companies could end up purchasing non-compliant leads that expose them to litigation risks.

2. Strengthen vendor oversight and compliance monitoring

Even though the one-to-one rule is gone, businesses must still be proactive about vendor agreements and compliance processes. The legal focus on consent and transparency remains strong, meaning you can’t afford to assume your vendors are automatically following best practices.

A key part of this is ensuring that lead sources are legitimate—something that has become more difficult as some businesses prioritize volume over compliance. The demand for high lead volumes has created a market where questionable lead-generation practices thrive.

“So many of these lead buyers that we've spoken to are just looking for volume,” Troutman says. “And that creates this marketplace [that makes it necessary to ask are] these legitimate leads or not?”

Call centers should not assume that third-party vendors are following best practices. Instead, they should:

• Audit their lead sources regularly

• Verify consent records to ensure compliance

• Ensure contracts clearly outline compliance expectations

3. Use dynamic consent language and adaptable software solutions

Beyond lead sourcing, compliance flexibility also extends to how businesses collect and document consent. Businesses that hardcoded one-to-one consent into their lead intake processes now face the costly task of reversing those changes.

Instead, advanced lead management and automation tools allow call centers to seamlessly update consent disclosures and compliance settings in real time without needing a full system overhaul. This ensures you can pivot quickly as new regulations emerge while maintaining efficiency and compliance.

Regulators and courts are examining not just whether businesses obtained consent, but how clearly and unmistakably they presented it to consumers. This means businesses should avoid overly generic or buried consent language and instead structure their disclosures to withstand legal challenges.

“Marketing companies in particular are really going to have to be careful about how they try to balance impacts on conversions with how the page would actually look from the perspective of a judge,” Chris Deatherage, General Counsel at Apollo Interactive.

4. Monitor legal developments and regulatory trends 

Don’t wait until a rule is finalized to start planning. Set up alerts for regulatory updates from the FCC, FTC, and key court cases to track potential changes before they happen. Designate a compliance lead or legal team to review industry updates and assess whether upcoming shifts could impact your operations.

“It’s really important to know which way the courts are deciding these cases so that you don’t set your practices in stone and fail to adjust as the law shifts,” Elg says.

5. Create a playbook for compliance adjustments

Develop pre-planned workflows for handling regulatory changes, including:

• Steps for modifying consent language

• Updating agent scripts

• Retraining staff on new requirements

• Adjusting lead acquisition strategies

A structured plan ensures you can react quickly rather than playing catch up when a rule changes.

6. Choose compliance-minded technology partners

Keeping up with compliance shifts requires more than just knowing the rules. The right tools let you adapt your operations quickly. Outdated or rigid systems can slow down updates and leave your business vulnerable when regulations change.

Call centers need a technology partner that prioritizes compliance. “We build solutions [at Convoso], and compliance has always been built into our platform. We've always taken a compliance-first mindset here,” says Daniel Foppen, VP of Product & Product Marketing at Convoso.

Here’s what to look for in a compliance-first technology partner:

• Automated list management – Support compliance with TCPA and state-specific rules with built-in list scrubbing and time-of-day restrictions​.

• Dynamic scripting tools – Automatically adjust scripts based on compliance needs so agents provide the correct disclosures across different states​.

• Caller ID reputation management – Prevent “Spam Likely” flags with tools like Convoso’s ClearCallerID™, which helps maintain high contact rates​.

• RND Scrubbing for reassigned numbers – Reduce compliance risks and wasted calls by scrubbing leads against the Reassigned Numbers Database (RND). 

Compliance support from CSMs – Look for a provider that gives proactive support from day one.

Download the State Calling Restrictions Guide featuring call times and frequency restrictions by state as well as holiday and emergency rules

Stay flexible, stay informed, stay competitive

The FCC’s one-to-one consent rule repeal and the Hobbs Act review make one thing clear: compliance rules aren’t set in stone. Regulations can shift unexpectedly, and businesses that fail to prepare often find themselves rushing to adjust.

Instead of reacting after a rule is finalized, call centers should proactively prepare for multiple outcomes. McKinsey research shows that businesses that prepare for uncertainty—rather than waiting for clarity—come out ahead.

“If you’re in this industry and you’re a seller relying on lead generators, you need to really pay attention to what’s going on,” Shuster says. “Being able to be nimble and understanding what your practices are now—so in case you have to change them, you know where you need to change them—is going to be critically important.”

The call centers that stay informed and adaptable will be in the best position to handle future regulatory shifts with minimal disruption. That’s why tracking legal developments, refining compliance strategies, and staying ahead of potential risks is crucial.

Trusted industry sources like Convoso’s webinars and compliance updates keep you ahead of rule changes, so you’re ready to act before they take effect.

DISCLAIMER: The information on this page, and related links, is provided for general education purposes only and is not legal advice. Convoso does not guarantee the accuracy or appropriateness of this information to your situation. You are solely responsible for using Convoso’s services in a legally compliant way and should consult your legal counsel for compliance advice. Any quotes are solely the views of the quoted person and do not necessarily reflect the views or opinions of Convoso.