As we approach 2025, significant legislative and regulatory changes are on the horizon, particularly in the realm of contact compliance. Gryphon’s Mark McKinney, Vice President of Market Intelligence, and Stefan Dunigan, Vice President of Field Operations have provided valuable insights into what we can expect in 2025 and how companies can prepare.  

A Look Back at 2024 

Several important changes happened this year surrounding the Telephone Consumer Protections Act, Telemarketing Sales Rule, Do Not Contact regulations, and class action rights and remedies. 

Telephone Consumer Protection Act (TCPA) 

Significant changes were made in 2024 around the TCPA, most notably regarding enhanced consent requirements, stricter caller ID regulations, and expanded definitions: 

  • Enhanced Consent Requirements: Several bills, such as Illinois HB 4990 and California AB 2512, emphasize the need for clear and explicit consent before making automated calls or using artificial voices. This aligns with TCPA’s requirement for prior express written consent for telemarketing calls. 
  • Stricter Caller ID Regulations: Tennessee HB 2504 and Illinois HB 4990 address the transmission of misleading caller ID information, reinforcing TCPA’s provisions against spoofing and ensuring accurate caller identification. 
  • Expanded Definitions: Bills like California AB 2512 expand the definition of automatic dialing-announcing devices, which could lead to broader enforcement under TCPA for new technologies used in telemarketing. 

Telemarketing Sales Rule (TSR) 

The TSR also made headlines in 2024, especially concerning disclosure requirements, call frequency limits, and registration and compliance: 

  • Disclosure Requirements: New York SB 8182 mandates that telemarketers provide specific information within the first 30 seconds of a call, which enhances transparency and aligns with TSR’s requirements for clear and conspicuous disclosures. 
  • Call Frequency Limits: Illinois HB 5566 limits the number of calls a telemarketer can make to the same person within a 24-hour period, supporting TSR’s rules on call frequency and preventing harassment. 
  • Registration and Compliance: Illinois HB 5593 requires telemarketers to register with the Secretary of State, ensuring that only compliant entities engage in telemarketing activities, which is in line with TSR’s registration requirements. 

Do Not Contact (DNC) Regulations 

Notable changes were also made around DNC regulations this year, including the use of the Reassigned Numbers Database, internal DNC lists, and federal enhancements: 

  • Use of Reassigned Numbers Database: Maine LD 2234 requires telephone solicitors to use the reassigned numbers database, which helps prevent calls to numbers that have been reassigned, thereby reducing DNC violations. 
  • Internal DNC Lists: Legislation like Connecticut SB 121 emphasizes the need for businesses to maintain and respect internal DNC lists, ensuring that consumer preferences are honored promptly. 
  • Federal Enhancements: United States S 3991 aims to protect consumers from robocalls, reinforcing the importance of adhering to the National Do Not Call Registry and implementing effective opt-out mechanisms.  

Class Action Rights and Civil Remedies  

States like Georgia and Maryland introduced bills allowing consumers to take legal action for violations, thus empowering consumers to sue companies that disregard telemarketing regulations and seek damages. This shift towards class action rights aims to provide stronger deterrents against unlawful telemarketing practices. 

What to expect in 2025 

Regulatory Developments to Watch 

  1. TCPA One-to-One Consent Rule (Effective January 27, 2025): This rule will require explicit, individualized consent for each seller, impacting how businesses handle lead generation and marketing. 
  2. FCC’s New Rules on Robocalls and Robotexts (Effective April 11, 2025): These rules will make it easier for consumers to revoke consent for unwanted calls and texts, and companies will need to promptly honor these requests. 
  3. State-Level Regulations: Look for new state-specific laws, particularly in active states like California, Florida, and Texas, which may continue strengthening consumer protections as well as a concentrated focus on state specific AI legislation. State privacy laws, such as California’s CCPA and Virginia’s VCDPA, will also impact data collection and usage. 
  4. AI and Automated Calling: Increased regulatory scrutiny is highly anticipated as AI becomes more prevalent in telemarketing. Compliance will require careful consideration of transparency and ethical standards. 

What should you focus on in 2025? 

  • Call Analytics and Monitoring: Utilize advanced analytics tools to monitor call activity and identify potential compliance risks. 
  • Employee Training: Provide ongoing training to employees on TCPA regulations, best practices, and the importance of compliance. 
  • Stay Informed: Keep up to date with the latest regulatory developments and industry best practices. 
  • Legal Counsel: Consult with experienced legal counsel to stay updated on the latest regulatory developments, address any compliance issues, and review material changes to the contact compliance ecosystem. 
  • Routine Audits: Regularly conduct audits of processes, documentation, and training to ensure ongoing compliance. 
  • Proactive Risk Management: Implement a comprehensive risk management program to identify and mitigate potential compliance risks. 

Top 10 Predictions for 2025 in the Contact Center and Compliance Space 

  1. Centralized Governance and Controls: All-channel contact compliance can no longer be a series of disparate, siloed processes. Organizations performing outreach, especially at scale, must centralize their governance and controls due to the rise in enforcement actions and class action suits. 
  2. Leveraging AI and ML: Companies must leverage emerging technologies such as Artificial Intelligence and Machine Learning to extend contact compliance through the totality of their outreach, especially during calls. Real-time, in-call remediation of potential compliance matters is crucial. 
  3. Quality Assurance Across All Calls: There is no reason companies cannot perform quality assurance across 100% of their phone calls using existing tools to analyze all interactions, rather than sampling a small percentage. 
  4. Cloud Computing and Automation: Real-time risk management with a full audit trail is now possible through cloud computing and automation. These technologies offer scalability, redundancy, speed, reliability, accuracy, and logging, making them ideal for managing risk in a highly regulated and litigious environment. 
  5. Accelerating Lead Recovery Efforts: Organizations can legally accelerate their lead recovery efforts by utilizing hygiene services, managing consumer preferences, and expanding established business relationship (EBR) exemption efforts to promote proper consent capture. 
  6. Increased Federal Involvement: The FCC and FTC are likely to continue advancing rules, particularly around enforcing caller ID authentication and imposing broader restrictions on AI use in telemarketing. Congress may push for unified national standards, making compliance easier across states. 
  7. Technological Enforcement Mechanisms: Expect the FCC and states to promote or mandate advanced call-blocking technologies. More telephony providers may be required to implement systems like STIR/SHAKEN for caller ID authentication, and new rules may standardize caller ID information across networks to curb spoofing. 
  8. Expanded Private Right of Action and Class Actions: If consumer rights to sue continue to expand, more consumers may file lawsuits against telemarketers, potentially driving class action lawsuits. This trend could lead to higher legal costs for companies, prompting them to proactively ensure compliance. 
  9. AI and Consent-Based Marketing Regulations: As AI technology advances, more regulations specifically targeting AI-driven outreach could emerge. Rules requiring explicit, informed consumer consent for any AI-driven calls or messages could help mitigate fraud. We might also see new guidelines around transparency and opt-out procedures for AI-generated marketing. 
  10. Tightening DNC Registry Rules for Text Messages: With a focus on including text messages in DNC registries, 2025 could see updated national or state rules that explicitly apply DNC protections to both calls and texts, reflecting the shift in consumer communication preferences. 

As we move into 2025, the landscape for call centers and contact compliance is set to evolve significantly. With new regulations and technological advancements on the horizon, companies must stay proactive in adapting to these changes. By leveraging AI, cloud computing, and robust compliance strategies, businesses can not only meet regulatory requirements but also enhance their operational efficiency and customer satisfaction. Staying informed and prepared will be key to navigating the complexities of the coming year and beyond. 

Let Gryphon take the guesswork out of contact compliance in 2025. Gryphon is the only automated, real-time, intelligent contact compliance solution on the market that enables enterprise-level organizations to mitigate risk while maximizing reach. 

If you need help preparing for 2025, reach out to us today. 

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