FCC Regulatory Response

The standard is coming.
GCC is already here.

The U.S. Federal Communications Commission has proposed mandatory English proficiency standards for all agents serving American consumers — including offshore. They asked what type of test should apply. We answered.

FCC 26-16CG Docket No. 26-52
FiledMay 2026
Reply commentsJune 22, 2026
StatusPosition paper submitted
40s
Per call, wasted
Average time added to every interaction by communication friction and clarification loops
20%
AHT reduction
Average Handle Time reduction achievable when agents meet a validated communication clarity standard
29%
Repeat contacts
Of all customer service calls require a repeat contact — a significant portion attributable to communication failure
$42B
Sector value at stake
Philippines IT-BPM sector revenue now facing compliance requirements on English proficiency for U.S.-facing operations
The proposed rule

What the FCC is asking for — and what it has not yet defined.

In early 2026, the FCC issued a Notice of Proposed Rulemaking that would require measurable English proficiency standards for all customer-facing agents serving U.S. consumers — onshore and offshore. The rule names the problem clearly. It does not yet define the solution.

The NPRM explicitly asks: "Should we require providers to ensure that call center staff pass a test? If so, what type of test?" The FCC acknowledges that existing assessments — TOEFL, TOEIC, OET — measure baseline linguistic proficiency but are insufficient to ensure effective customer communication. What comes next has not been defined.

That gap is not a weakness in the rule. It is an invitation for the industry to provide the answer. The Global Clarity Foundation has accepted that invitation.

FCC proposes
Mandatory English proficiency standards — "American Standard English" — with no defined methodology or passing threshold.
GCC provides
The GCC Score — 15 standardised dimensions, behaviourally anchored rubrics, and a human-verified composite that answers the question proficiency tests cannot: was the customer actually understood?
FCC proposes
Independent verification that agents meet the standard — third-party assessment required.
GCC provides
The GCC Vocal Passport — independently assessed, annually renewed certification that operators can present to U.S. clients and regulators as verifiable compliance evidence.
FCC proposes
Mandatory disclosure that agents are offshore, with consumer right to transfer to a U.S.-based agent.
GCC provides
A GCC-certified offshore agent is a disclosed and verified asset — not a liability. Certification gives U.S. clients objective evidence of quality, turning disclosure from a risk into a point of differentiation.
FCC proposes
A distinction between legitimate BPO operations and fraudulent offshore actors.
GCC provides
Third-party certification draws that line in measurable terms. Certified operators have documented, independently verified communication quality. That is the distinction regulators and U.S. clients can point to.
FCC proposes
A transition pathway for operators moving toward greater onshore delivery — not immediate forced onshoring.
GCC provides
A day-one compliance pathway. Operators can certify their existing offshore workforce immediately, demonstrating good-faith compliance while transition plans are executed — protecting consumers now, not eventually.
Why existing tests are not enough

The FCC already knows automated testing falls short. Our field evidence shows why.

The NPRM acknowledges at paragraph 11 that "baseline proficiency is often not enough to ensure successful customer service interactions." The Global Clarity Foundation's own assessment data makes this concrete.

Case 01
Fundamental literacy undetected across automated pre-screening
In a cohort of 50 human-led assessments, one candidate had passed all standard automated pre-screening and completed two weeks of formal in-person training. During GCF's role-play component — which requires referencing a written scenario document — the candidate fabricated their responses entirely, repeatedly claiming they had read the material. The assessor explicitly offered unlimited time and free use of the document, with no penalty. The same pattern repeated across a second, entirely different scenario. From the consistent inability to extract any factual information from written material across two independent tests, the Foundation inferred the candidate was unable to read the document.
This candidate was cleared for deployment in a U.S.-facing customer service role — one that required reading account details, billing statements, and policy documents in real time. No automated voice assessment detected the issue.
Case 02
Script dependency exposed by unscripted interaction
A second candidate — who had passed all automated pre-screening — requested a bathroom break during the role-play component of GCF's assessment and did not return. The role-play requires candidates to respond to unscripted, adaptive consumer scenarios without preparation — replicating the conditions of a real call. The candidate had demonstrated sufficient proficiency to pass every structured prompt placed before them. When the script was removed, they could not proceed.
Automated assessments present structured prompts that candidates can learn, rehearse, and optimise. A real consumer interaction does not. This candidate's limitation was invisible to every prior test — and visible within minutes to a trained human assessor.
Case 03
The resit problem — tests that can be learned
Widely used automated proficiency assessments — including those in common use across the Philippine IT-BPM sector — permit candidates to retake the same test repeatedly until they achieve the score they require. Each resit provides greater familiarity with the test's structure, prompt types, pacing, and the patterns the algorithm rewards. Over multiple attempts, the score increasingly measures familiarity with the test format, not underlying communication ability.
GCF's human-led assessments with varied role-play scenarios are structurally resistant to this. Because each scenario is different — different subject matter, different consumer character, a human assessor who adapts in real time — there is no format to rehearse. What a candidate must demonstrate is genuine communicative competence. That is the only quality that predicts whether an American consumer will be well served.
The score is real. The proficiency it implies is not. A compliance framework built exclusively on automated testing will, over time, produce a workforce that is very good at passing automated tests — and no better equipped to serve American consumers than before.
The GCF framework

Five principles for an assessment standard that actually works.

The Global Clarity Foundation's position paper proposes that any FCC-endorsed assessment methodology meet five principles. These are designed to give American consumers real protection, give industry a clear and achievable compliance pathway, and give the Commission a standard it can implement and stand behind.

01 — Consumer-Focused
Was the consumer actually understood?
The standard measures whether the interaction succeeded for the American consumer — not whether the agent's speech matched a particular model of English. Measurable outcomes: First Call Resolution, Customer Effort Score, repeat contact rates. A 79-year-old disputing a medical bill and a 28-year-old troubleshooting broadband have different communication needs. A consumer-focused standard assesses whether the agent recognised and adapted to both.
02 — Achievable
A standard industry can actually meet.
The 1.7 million professionals in the Philippine IT-BPM sector cannot be replaced by a domestic U.S. workforce overnight — that capacity does not exist. A standard that cannot be met protects no one. An achievable standard — one operators can meet through certification of their existing workforce — protects American consumers today, while transition proceeds at a realistic pace.
03 — Objective
Observable. Documented. Auditable.
Two trained assessors, independently evaluating the same interaction, should arrive at substantially equivalent conclusions. Behaviourally anchored rubrics make this possible. An objective standard is enforceable — and enforcement actions built on it are defensible. Subjective impression is not a compliance mechanism.
04 — Consistent
The same standard everywhere.
The same level of communication performance should produce the same certification outcome — whether the assessment is conducted in Manila or Miami, on a Monday morning or a Friday afternoon. Consistency is what makes a standard fair to industry and meaningful to consumers. Without it, compliance is a lottery.
05 — Transparent
Operators know the target before they have to hit it.
Published criteria. Defined rubrics. Clear certification thresholds. Transparency is what converts a regulatory requirement into a business objective operators can invest in. Businesses will not invest in meeting a standard they cannot clearly see — and consumers will not be protected by a standard that can't be planned for.
Industry transition

The path where no one loses.

American industry groups have told the Commission they cannot onshore overnight. They are right. GCC provides the bridge: a certification standard that protects consumers now, gives industry a workable path, and gives the Commission something it can enforce from day one.

01
Certify the existing workforce
Operators assess their current offshore agents through GCF's human-led diagnostic. Those who meet the standard receive a GCC Vocal Passport — independently verified, annually renewable proof of communication quality.
02
Demonstrate compliance immediately
Certified agents provide operators with documented, auditable evidence of communication standard — usable with U.S. clients, regulators, and the FCC. Compliance is not future-dated. It begins the day the first agent is certified.
03
Transition at a realistic pace
As domestic workforce capacity builds over time, operators transition their service mix with verifiable evidence that every stage of the journey met a defined standard. Consumers are protected throughout — not only at the destination.
Industry gets a workable timeline. Consumers get real protection now. The Commission gets a standard it can enforce from day one.

Read our position paper. Request a compliance consultation.

The Global Clarity Foundation has filed a formal position paper with the FCC (CG Docket No. 26-52). We are available to brief operators, U.S. clients, and industry bodies on the regulatory context and what GCC certification means for compliance readiness.

Request the position paper Talk to us about compliance
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