TCPA compliance · US
TCPA compliance for AI voice calls, in plain words.
The Telephone Consumer Protection Act (TCPA) is a United States law, enforced by the Federal Communications Commission (FCC) and through private lawsuits. If your AI voice agent calls people in the US, this is the rulebook. Other countries have their own; India’s is on our DLT registration page.
Since February 2024 the FCC has treated AI-generated voices as “artificial” voices under the Act, so the robocall rules apply to AI calls: consent, calling hours, do-not-call lists, identification and opt-outs. This page sets them out with the sources. It is general information, not legal advice.
FCC 24-17 · 47 CFR § 64.1200 · 47 U.S.C. § 227 · Sources linked below · Not legal advice
- System00:00
Pre-dial · consent on file · registry and suppression list checked · 10:40 a.m. local time
- AI agent00:00
Hi, this is Nora, an AI assistant calling for Brightline Solar about the quote you requested on our website. To stop these calls, say “stop” or press 9 at any time.
- Caller00:09
We went with someone else, actually. Please take me off your list.
- AI agent00:13
Done. This number is on Brightline Solar’s do-not-call list now, so we will not call again. Goodbye.
- System00:19
Do-not-call request recorded · number suppressed for future campaigns
What the FCC decided about AI voices in February 2024.
The ruling is four pages long before the commissioners’ statements. It wrote no new rule: it confirmed how the existing TCPA rules apply to AI-generated voices, and took effect the day it was released.
| FCC 24-17, Declaratory Ruling | |
|---|---|
| Document | CG Docket No. 23-362. Adopted 2 February 2024; released and effective 8 February 2024. |
| What it decided | The TCPA’s restrictions on “artificial or prerecorded voice” cover current AI technologies that generate human voices. Voice cloning is included. |
| Why | The voice is artificial because no person is speaking it. The FCC found no carve-out for technology that claims to be the equivalent of a live agent. |
| Consent | Calls using an AI voice need the called party’s prior express consent, unless made for an emergency purpose or exempt. Telemarketing calls need prior express written consent. |
| On the call | Every artificial-voice message must identify who is responsible for the call. Telemarketing calls must also offer a way to opt out. |
| Scope | Any AI technology that places an outbound call using an artificial or prerecorded voice. |
Summary of FCC 24-17. The written-consent point for telemarketing is the ruling’s footnote 13, citing 47 CFR § 64.1200(a)(2) and (a)(3). General information, not legal advice. · Source: FCC 24-17, Declaratory Ruling
The TCPA rules an AI voice call has to meet.
Most of the detail sits in the FCC’s rule, 47 CFR § 64.1200. These are the parts that touch an AI voice agent placing calls. State laws can be stricter; check the states you call into.
| What the rule says | Where | |
|---|---|---|
| Informational calls to mobiles | Artificial-voice calls to mobile numbers need prior express consent. Some free-to-end-user messages are exempt, such as package delivery notices, bank fraud and security alerts, and healthcare reminders. | (a)(1), (a)(9) |
| Telemarketing | Telemarketing or advertising calls with an artificial voice, to mobile numbers or residential lines, need prior express written consent: a signed written agreement that names the number and clearly authorises the seller to call it this way. | (a)(2), (a)(3), (f)(9) |
| Emergencies | Calls made necessary by a situation affecting consumers’ health and safety are exempt from the consent requirement. | (a)(1), (f)(4) |
| Calling hours | No telephone solicitation to a residential subscriber before 8 a.m. or after 9 p.m., local time where the called person is. The FCC applies this to mobile numbers too. | (c)(1), (e) |
| National Do Not Call Registry | No telephone solicitation to registered numbers, which stay registered until the consumer cancels. The safe harbour requires a copy of the registry no more than 31 days old. Calls with the person’s permission or within an established business relationship are not telephone solicitations. | (c)(2), (f)(15) |
| Company do-not-call list | Honour a do-not-call request within ten business days and keep it for five years. | (d) |
| Identification | Every artificial or prerecorded voice message must name the business responsible at the start, and give a telephone number. | (b)(1), (b)(2) |
| Automated opt-out | Telemarketing messages with an artificial voice must offer a voice or keypress opt-out within two seconds of the identification. Using it adds the number to the caller’s do-not-call list and ends the call. | (b)(3) |
| Revoking consent | People may revoke consent by any reasonable means. Honour it within a reasonable time, no more than ten business days. | (a)(10) |
Summary of 47 CFR § 64.1200 as of Nov 2026. General information, not legal advice. · Source: eCFR, 47 CFR § 64.1200
What a violation can cost.
The TCPA lets the people called sue. Damages are counted per violation, and on a calling list that usually means per call, so a small mistake repeated across a campaign adds up quickly.
- Per violation
- $500
Statutory damages a person can sue for over an unlawful artificial-voice call, or their actual loss if greater.
- Willful or knowing
- $1,500
A court may treble the award, to up to $1,500 per violation.
- FCC, intentional violations
- $10,000
An additional penalty of up to $10,000 per intentional violation, on top of the FCC’s base forfeiture.
47 U.S.C. § 227(b)(3) and (b)(4)(B). Do-not-call violations: a person called more than once in 12 months by the same entity may sue for up to $500 per violation, also trebled (§ 227(c)(5)). State attorneys general can bring actions too. Not legal advice. · Source: 47 U.S.C. § 227 (Cornell LII)
Before an AI agent dials a US number.
- 01
Classify every call
Is it telemarketing or advertising? Then prior express written consent applies to any AI-voice call to a mobile or residential line. Purely informational calls still need prior express consent unless an exemption applies.
- 02
Hold consent you can show
For telemarketing, a written agreement signed by the person, naming the number and clearly authorising your company to call it with an artificial voice. Keep the record with the contact.
- 03
Scrub the list
Against the National Do Not Call Registry, using a copy no older than 31 days, and against your own do-not-call list.
- 04
Set the calling window
8 a.m. to 9 p.m. in the called person’s local time, not yours. Check whether the states you call into set tighter limits.
- 05
Script the opening
Name the business at the start and give a callback number. On telemarketing calls, offer the automated opt-out within two seconds of that identification.
- 06
Honour every no
Act on revoked consent, by whatever reasonable means it arrives, within ten business days. Keep company do-not-call requests for five years.
Controls that help you stay inside the rules.
No platform makes a campaign compliant on its own: the consent is yours to collect and keep, and the script is yours to approve. These are the controls VocalLabs gives you to run inside the rules you are bound by.
- 01Pre-dial
Checks before the dial
Numbers are checked against your suppression list and the national registry before dialling.
- 02Hours
Calling windows
Calling windows are enforced per region, in the called person’s local time.
- 03Identify
Disclosure in the first line
The agent names itself and your company in its opening line and says it is an AI. You control the wording, and the disclosure is logged on every call.
- 04Opt-out
Spoken opt-outs
An opt-out said on the call is written back immediately and honoured in every future campaign.
- 05Record
Recordings and transcripts
Each voice session keeps its recording, transcript and tool calls.
- 06Data
Consent tones and PII redaction
VocalStack Voice adds consent tones and real-time PII redaction to calls.
Questions buyers ask first.
Rules first. Then the dial.
Tell us who you call, why, and what consent you hold. We will show you how pre-dial checks, calling windows and opt-outs are set up for your campaign, on a test call before any customer hears it.
