AI Voice Compliance: Disclosure and Calling Hours

Outbound voice compliance depends on more than whether a system uses AI. The call’s purpose, the number called, the message format and the caller’s location can change which rules apply. Build those details into the campaign before the dialer starts.

This guide focuses on United States rules and practical system controls. It is not a substitute for advice on a specific campaign. Have counsel classify the calls you plan to make.

Classify the call before setting its disclosure

The FCC has clarified that AI-generated human voices fall within the TCPA’s restrictions on artificial or prerecorded voices. Depending on the call and the number reached, those restrictions may require prior express consent, subject to statutory and regulatory exemptions. The FCC’s 2024 declaratory ruling explains that the existing rules cover AI-generated voices.

California’s AB 2905 took effect on January 1, 2025 and amended Public Utilities Code section 2874. For calls made with an automatic dialing-announcing device, the law requires an unrecorded, natural-voice announcement before the prerecorded message. That announcement must identify the nature of the call and the business, ask whether the person consents to hear the message, and disclose if the prerecorded message uses an artificial voice. Read the current California Public Utilities Code section 2874.

That California provision addresses an automatic dialing-announcing device and a prerecorded message. It should not be described as a blanket disclosure rule for every live, interactive AI conversation. The FCC’s TCPA ruling and California’s device-specific statute address related issues, but they do not have identical scope.

Apply calling windows to the calls they cover

Under 47 CFR section 64.1200(c)(1), a telephone solicitation to a residential telephone subscriber may not start before 8 a.m. or after 9 p.m., using the local time at the called party’s location. Paragraph (e) applies the calling-hour rules to wireless numbers to the extent described there.

That rule does not turn every business call into a telephone solicitation. Call purpose and line type matter, and states can set stricter requirements. For a campaign that reaches people in different regions, use the recipient’s current local time as a scheduling input. Do not rely on the caller’s office timezone or assume an area code still matches someone’s location.

Do not treat statutory damages as an automatic disclosure fine

The TCPA’s private-action provision, 47 U.S.C. section 227(b)(3), allows a person bringing an eligible action to seek actual loss or $500 for each violation, whichever is greater. A court may increase the award up to three times that amount for a willful or knowing violation.

Those figures are possible remedies in a TCPA action. They are not an automatic $500 fine for every undisclosed AI interaction under California AB 2905. Keep the statute, the call category and the enforcement route clear when estimating risk.

Put the rules into the dialer

A written policy cannot catch a call that starts outside its allowed window. Store the information the system needs with each contact and campaign:

• Permission: record who consented, when, how, and for which type of call. Check opt-outs before dialing.
• Call category: mark whether the campaign is a solicitation, uses a prerecorded message, or uses a live conversational agent.
• Disclosure: select the approved opening for the applicable call type and jurisdiction. Keep it before any prerecorded message where the rule requires it.
• Local time: store the recipient’s location and calculate the permitted window at dial time, including daylight-saving changes and stricter local rules.
• Evidence: retain the consent record, policy version, opening played, call time and outcome so a reviewer can reconstruct the call.

Test boundary cases before launch: a contact with no verified timezone, a changed number location, an opt-out received minutes before a scheduled call, and a campaign that crosses into a state with a shorter window. The dialer should hold the call when it lacks the information needed to apply the policy.

Review rules when the campaign changes

A new voice model can change a prerecorded message. A new lead source can change what consent covers. A new country can introduce requirements the U.S. checklist does not address. Route those changes through a compliance review, then update the campaign configuration and test the calling windows again.

For the operational side of voice systems, read how to measure call quality and how to design human handoffs. Find LeadOro’s AI voice series on YouTube.