Compliance · State rules
AI disclosure laws, state by state.
Federal TCPA rules apply everywhere — but a growing list of states adds its own layer: AI-voice disclosure duties, mini-TCPAs with stricter consent, telemarketer registration. Here's the honest map for agents, without the fear-mongering.
- Primary sources cited
- Checked July 2026
- Not legal advice
Start with the federal floor
Before any state rule applies, the federal TCPA already governs AI voice calls everywhere: the FCC's February 2024 ruling confirmed AI-generated voices are 'artificial voices,' so marketing calls to cell phones need prior express written consent, and the National Do-Not-Call Registry applies to prospecting. The FCC has also proposed — but not yet adopted — rules requiring calls to disclose AI use explicitly.
States add three kinds of layers on top: AI-specific disclosure duties (California, Utah), 'mini-TCPAs' with their own consent standards and private lawsuits (Florida, Oklahoma, Washington, Maryland, Georgia, Texas), and telemarketer registration regimes (Texas, Arizona, New Jersey).
The table
State layers on top of the TCPA.
| State | Law | What it requires | Status |
|---|---|---|---|
| California | AB 2905 (2024); B.O.T. Act (SB 1001) | Automated-dialer announcement calls must disclose that the message uses an AI-generated ('artificial') voice. The older B.O.T. Act requires bot disclosure in online sales chats. | AB 2905 in effect Jan 1, 2025 |
| Utah | AI Policy Act (SB 149, 2024; amended SB 226, 2025) | Businesses using generative AI with consumers must admit it when clearly asked; upfront disclosure earns a safe harbor (and is required in some regulated, high-risk interactions). | In effect (sunset review 2027) |
| Colorado | SB 26-189 (replaced the 2024 Colorado AI Act) | Transparency duties for AI used in consequential decisions (notices, adverse-decision explanations). Sales calls generally aren't the target; broad AI-interaction disclosure was narrowed in the rewrite. | Effective Jan 1, 2027 |
| Florida | Telephone Solicitation Act (2021, amended 2023) | Written consent for sales calls made with an automated system that both selects and dials numbers; 8am–8pm window; max 3 calls per 24h per matter; private lawsuits ($500–$1,500/call). | In effect |
| Oklahoma | Telephone Solicitation Act (2022) | Written consent for automated/recorded sales calls; 8am–8pm; 3-call/24h cap; caller-ID rules; private right of action. | In effect since Nov 2022 |
| Washington | HB 1497 (2022) + robocall laws; CEMA for texts | Caller, company, and purpose identified within the first 30 seconds; strengthened do-not-call honoring; separate ban on unsolicited commercial texts. | In effect |
| Texas | Bus. & Com. Code ch. 302 + SB 140 (2025) | Telemarketer registration with the Secretary of State ($200 fee + $10,000 bond) unless exempt; 2025 amendments extend the regime to texts and add a private right of action with treble damages. | SB 140 in effect Sept 1, 2025 |
| Maryland | Stop the Spam Calls Act (2023) | Written consent for solicitations using automated selection-or-dialing systems or recorded/artificial voices; 8am–8pm; 3-call/24h cap. | In effect since Jan 1, 2024 |
| Georgia | SB 73 (2024) | Private right of action ($1,000/violation, class actions allowed) under the state telemarketing law; liability reaches businesses whose vendors place the calls. | In effect since July 1, 2024 |
| Arizona / New Jersey | Telemarketer registration regimes | Sellers making telephone solicitations must register with the state (AZ: bond required; NJ: annual registration, in-call identification within 30 seconds, no calls 9pm–8am). | In effect |
| New York | GBL § 399-p (auto-dial announcements) | Automated announcement calls must state the call's nature and on whose behalf it's made at the start. No enacted NY statute specifically requires disclosing an AI voice on sales calls as of July 2026 (bills pending). | § 399-p long-standing |
| Tennessee | ELVIS Act (2024) — different scope | A right-of-publicity law: cloning a real person's voice without permission is actionable. It doesn't mandate AI disclosure on calls — but it's why Marshal's assistant uses a synthetic voice, not a clone of anyone. | In effect since July 1, 2024 |
Statute texts, Federal Register, and firm alerts as of July 2026 — see primary sources under the TCPA guide. Statuses change; verify before relying on a row.
What this means in practice
You could track twelve statutes — or adopt the posture that satisfies the strictest of them and the direction of every pending bill:
- Disclose up front, every call. An AI assistant that introduces itself satisfies California's rule, earns Utah's safe harbor, and costs nothing anywhere else.
- Collect written consent when you capture the lead — it's the federal floor for marketing calls and the mini-TCPA standard too.
- Respect quiet hours and frequency: 8am–8pm and no hammering. The state caps (3 calls/24h) are a sane ceiling everywhere.
- Call the leads who asked to hear from you. Most of this body of law exists because of cold-call volume; working your own book keeps you out of its blast radius.
How Marshal fits
Marshal's calling assistant takes the strict-state posture by default: it introduces itself as an AI assistant on every call, uses a synthetic voice (no cloning), only dials leads you provided, follows a talk track you approved, records every call, and stays inside your budget caps. Consent capture and list hygiene stay on your side of the desk — as they should.
FAQ
Common questions
Do I have to tell people the call uses AI?
In California, yes — automated announcement calls must disclose an AI-generated voice. In Utah, you must admit it when clearly asked, and upfront disclosure earns a safe harbor. Federally, the FCC has proposed (not yet adopted) an explicit AI-disclosure rule. Marshal discloses on every call regardless, which satisfies the strictest current rule.
My state isn't on the table — am I in the clear?
The federal TCPA and Do-Not-Call rules apply in every state, and this table only covers the states with notable extra layers. Absence from the table means no extra state statute we know of as of July 2026 — not 'anything goes.'
Do these laws apply to calls to my past clients?
Mostly yes. An existing relationship helps with Do-Not-Call registry rules (18 months after a transaction), but written-consent requirements for artificial-voice marketing calls don't carve out past clients. Get the consent line into your intake and closing paperwork.
What about Canada?
CRTC rules treat synthesized-voice calls as automatic dialing-announcing devices: solicitation calls need prior express consent, and brokerages are responsible for their agents' calls under the national Do-Not-Call regime. CASL, despite its fame, covers email and texts — not voice calls.
This page is general information, not legal advice, and summarizes a fast-moving area as of July 2026. Statutes are paraphrased; several rows rely on firm summaries pending primary-source review. Confirm current law with your own counsel before running calling campaigns.
The strict-state posture, everywhere, by default.
Self-disclosing AI, synthetic voice, your approved talk track, full recordings, budget caps. Marshal does the busywork. You close.
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