2025 CX Compliance Checklist: What US Operators Must Prove

The US regulatory picture for customer experience is shifting fast in 2025. At the federal level, the FTC’s Rule on Unfair or Deceptive Fees (“junk fees”) took effect May 12, 2025, with FAQs clarifying expectations for accurate, upfront pricing and bans on drip-fee tactics—implications for support scripts, refunds, and billing flows.

Meanwhile, the FTC’s “Click-to-Cancel” Negative Option Rule - finalized in late 2024 - was vacated by the Eighth Circuit on July 8, 2025 on procedural grounds. Even so, many subscription businesses are keeping “one-click cancel” and clear renewal terms because state AGs and plaintiffs’ bars still scrutinize friction in cancellation and retention flows. 

States stepped in, too. Eight new state privacy laws take effect across 2025 - including Delaware (Jan 1) and New Jersey (Jan 15) - expanding rights and obligations around data access, deletion, sensitive data, and processing disclosures. Support teams must ensure identity verification, data access handoffs, and redaction workflows are operational (and reportable). 

Finally, Congress floated the Keep Call Centers in America Act of 2025, which - if enacted - would require disclosing agent location and add penalties around offshoring without notice. Even before passage, some brands are proactively labeling agent geography and offering “request a US agent” options to reduce risk.

What auditors will ask for:

• Time-to-human access policies and SLA evidence (timestamps, queues, escalation ladders).
  
  

• Transparent billing and refund/credit rules that avoid prohibited fees.
  
  

• Subscription flows: plain-language autorenewal terms; easy cancellation proof (even if “click-to-cancel” is in flux).
  
  

• Data rights handling: identity checks, export timelines, redaction/retention rules, and a ticket audit trail.
  
  

Playbook for CX leaders:

1. Instrument the last 20% (complex tickets where loyalty and exposure live). Tag “time-to-human,” measure escalations, and capture transcript evidence.
   
   

2. Unify billing + support: remove price surprises; pre-authorize courtesy credits where junk-fee risk exists.
   
   

3. Upgrade privacy macros for 2025 state laws - especially Delaware and New Jersey.
   
   

4. Location transparency: be ready to disclose agent location and provide alternatives if the bill advances.

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