Sytel Calls on FCC to Modernize TCPA Dialing Rules

April, 2025

The dialing rules in the Telephone Consumer Protection Act (TCPA) have created a two-tier market for calls to non-consenting numbers, largely due to regulatory ambiguity and the mistaken focus on system capability over real-world use.

Aylesbury, UK – 04 April 2025

Sytel, a global leader in responsible dialing technology, has submitted two formal Comments to the Federal Communications Commission (FCC) under Docket 02-278, urging a fundamental rethink of dialing regulations under the Telephone Consumer Protection Act (TCPA).

At the heart of Sytel’s message: regulate how dialing is done, not what a system is technically capable of.

The Problem: A Broken, Two-Tier Market

Under current interpretations of the TCPA, any system capable of automated dialing is treated as if it’s always being used irresponsibly — even when it’s not. The result?

  • Confusion and fear: Many businesses avoid automation entirely, sacrificing productivity.
  • Legal ambiguity: Risk-averse firms rely on inefficient manual or hybrid processes, while others take a more aggressive stance — creating a fragmented, two-tier marketplace.

This patchwork of compliance and non-compliance serves neither consumers nor legitimate businesses.

Sytel’s Proposal: Clarity for Consumers and Businesses

Sytel advocates for an execution-based model, where compliance is judged by what a dialer does in practice, not by what it could hypothetically do.

This model is inspired by the FTC’s Telemarketing Sales Rule (TSR), a proven, enforceable framework that:

  • Allows automation but holds users accountable for real-world behavior
  • Limits nuisance calls through clear standards — like defined thresholds for abandoned calls
  • Provides clarity, so businesses can operate efficiently and legally

Why This Works

  • Modern dialers can self-regulate: Advanced pacing engines can tightly manage call flow, protecting consumers.
  • The technology is proven: Vendors like Sytel already support TSR-style compliance globally.
  • A transition path exists: Sytel urges the FCC to allow a rollout window, giving vendors time to adapt responsibly.

From the CEO

“We’ve spent 25 years building compliant dialing systems that deliver performance and protect consumers. It’s time for regulators to appreciate that the technology has caught up with the intent of the law.”
— Michael McKinlay, CEO, Sytel Limited

More Information

Sytel’s two formal Comments (Feb and Apr 2025) are publicly available in the ECFS database of the FCC, Docket 02-278 and outline a clear path to reform. We encourage regulators, vendors, advocates, and businesses to support a model that promotes fairness, innovation, and accountability.

Q&A: Sytel’s Call for a Modern TCPA Approach

Q1: Why now?
A: The current rules are outdated and vague, focused on capability instead of behavior. This stifles responsible innovation and leaves businesses in legal limbo. It’s time to align regulation with how outbound dialing actually works in 2025.

Q2: What does an “execution-based model” really mean?
A: It means judging dialers by actual behavior — like minimizing abandoned and silent calls — rather than technical features. The FTC’s TSR already does this, and has done so effectively for two decades.

Q3: Will this open the door to more robocalls?
A: No. In fact, execution-based standards put real guardrails around behavior. With modern systems, there’s no incentive to game the system — and bad actors are easier to detect and penalize.

Q4: Can vendors comply with these standards?
A: We’re not sure of the extent of compliance. That’s why we’re calling for a transition window so all vendors can meet the bar without cutting corners.

Q5: Isn’t predictive dialing always annoying for consumers?
A: Only when used irresponsibly. With the right pacing controls, predictive dialing connects agents and consumers smoothly, without nuisance calls.

Learn more about the performance boost available with Sytel’s compliant predictive dialing.