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TCPA — AI-generated voices are 'artificial or prerecorded' calls

United States (federal) · 47 U.S.C. § 227; FCC Declaratory Ruling (Feb 8, 2024); pending FCC AI-disclosure NPRM · effective 2024-02-08

Summary

The FCC ruled that calls using AI-generated or AI-modified voices are 'artificial or prerecorded voice' calls under the TCPA. Prior express consent is required for most such calls, calling-hour limits apply, and a pending rule would require a plain-language AI disclosure at the start of every call.

Who must comply

Any business placing AI voice-agent calls to U.S. residential or mobile numbers.

What you must disclose

Identify the business at the start of the call; a specific 'this call uses an AI-generated voice' disclosure is proposed federally and already required by some states.

When: At the opening of the call.

Other duties

  • Obtain and log prior express (written, for marketing) consent.
  • Call only 8am–9pm local time.
  • Honor opt-outs immediately.

Exemptions

  • Calls with valid prior express consent still require identification but are lawful.

Penalties

$500 per call, up to $1,500 per willful call, with no cap; frequent class actions.

Enforced by: FCC, state attorneys general, and private plaintiffs.

Triggered by

AI phone / voice agent

Sources

Last reviewed 2026-09-09. Not legal advice.

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TCPA — AI-generated voices are 'artificial or prerecorded' calls — what businesses must disclose · BotNotice