Contact Center Pipeline May 2026 | Page 43

WHY“ HIGHEST COMMON DENOMINATOR” IS SAFER

Brands operating across multiple states and countries wrestle a messy patchwork of rules around refunds, chatbot transparency, agent location, and escalation rights.

A California-only AB 578 workflow, a different one for New York’ s chatbot rules, and yet another for Canadian and also for European jurisdictions with their own consumer protections, language, and privacy laws might look efficient on paper, but it becomes fragile in practice.

Agents could get confused, including not knowing where the customer is located. There is also the risk of documentation fractures. And proving compliance in a cross border complaint or class action gets harder, not easier.

An alternative play is to treat AB 578 and its peers as a preview of where the floor is headed and build a higher internal standard that can travel. That might mean:

• Adopting clear, consistent bot and AI disclosures everywhere, mandated or not.

• Making a human escalation path obvious in every high stakes flow, regardless of state( or country).

• Defaulting refunds to the original card when you ' re at fault with narrow, evidence-based exceptions.

• Logging automated interactions and escalation decisions so that Governance, Risk and Compliance( GRC) and Legal can actually find what they need.

Viewed through a GRC lens, these are not just user experience( UX) preferences; they are controls. They define how the organization treats consumer harm, complaint handling, and regulatory exposure in real time.

A PRACTICAL PLAYBOOK FOR CONTACT CENTERS

Here ' s what leaders can do right now:

1. Inventory automation. Map where bots, IVRs, and automated emails or texts are making decisions about money, access, or legal outcomes. Prioritize flows that deny refunds, close tickets, or impose fees.

2. Nail down“ human required” scenarios. Use AB 578 as a template: non-delivery, botched service, fraud claims, security events, and any situation that reasonably implicates consumer harm should have guaranteed human handling.

3. Build in disclosure and easy exit. Make it explicit when a customer is interacting with AI or automation( spell out“ you’ re talking to AI” upfront) and make the human button impossible to miss: especially after one or two failed automated attempts.

4. Align outbound and inbound rules. Ensure the same consent, disclosure, and escalation standards apply to both inbound and outbound when you’ re calling or texting customers about the outcomes of those disputes.

5. Make it GRC, not a one time UX tweak. Monitor where automation breaks, track complaints about“ I can’ t reach a human,” and feed that data back into both product design and compliance oversight.

WHERE LEGISLATION IS HEADED

AB 578 won’ t be the last word on how refunds are processed or when humans must step in. It is, however, an unusually clear example of legislators codifying what many consumers already assume: automation may be the front door, but it cannot be the only door.

STATE REGULATIONS

FIGURE 2

As more states experiment with refund and CX rules- and as federal lawmakers probe AI and offshoring in contact centers- brands that build around transparency, consent, and human fallback now will be in a far better position than those that cling to opaque, automation-only models.

For contact center leaders, that’ s not just a compliance story. It’ s an opportunity to get ahead: craft outreach and service that lean into automation ' s speed while honoring AB 578 ' s core truth: when something goes sideways- especially with money- the consumer deserves a real person who can fix it.

Melody Morehouse, MBA directs Regulatory Compliance at Gryphon AI, driving federal & state regulatory intelligence including TCPA / TSR / FDCPA / CAN-SPAM, plus contact strategy. With deep expertise in telecommunications, consumer privacy, and marketing, she turns complex regulations into practical controls for compliant outbound reach.

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