AI voice and disclosure rules for calls

See also

Sources

1. 1
   A contact centre that streams live calls with California parties to a third-party AI vendor for transcription or agent assist faces CIPA exposure unless all parties are told and consent, particularly where the vendor can use the data for its own model improvement.inferred

   Ambriz v. Google LLC, order denying motion to dismiss (N.D. Cal.) · Order (Dkt. 56, filed 02/10/25), pp.4-7: capability test and Section 631(a) all-party consent clause · Checked 2026-09-30
2. 2
   On February 10, 2025, the US District Court for the Northern District of California denied Google's motion to dismiss in Ambriz v. Google, applying the 'capability' test: plaintiffs adequately alleged that Google Cloud Contact Center AI acted as a third-party eavesdropper under California Penal Code § 631(a) because it was capable of using call data for its own purposes, whether or not it actually did.

   Ambriz v. Google LLC, order denying motion to dismiss (N.D. Cal.) · Order (Dkt. 56, filed 02/10/25), p.1 disposition; pp.4-6 section on Google as a third party and the capability test · Checked 2026-09-30
3. 3
   California Public Utilities Code § 2874 allows an automatic dialing-announcing device to be operated only after an unrecorded, natural-voice announcement by the caller that states the nature of the call and identifies the calling party, and after the called person consents to hear the prerecorded message.

   AB-2905 Telecommunications: automatic dialing-announcing devices: artificial voices (Chapter 316, Statutes of 2024) · PUC § 2874(a) as shown in AB 2905 bill text · Checked 2026-09-30
4. 4
   California AB 2905 (Chapter 316, Statutes of 2024, chaptered September 20, 2024) amended Public Utilities Code § 2874 to require that an automatic dialing-announcing device inform the called person when the prerecorded message uses an artificial voice.

   AB-2905 Telecommunications: automatic dialing-announcing devices: artificial voices (Chapter 316, Statutes of 2024) · Bill section amending PUC § 2874(a)(3) · Checked 2026-09-30
5. 5
   As amended by AB 2905, California Public Utilities Code § 2874 defines 'artificial voice' as a voice that is generated or significantly altered using artificial intelligence.

   AB-2905 Telecommunications: automatic dialing-announcing devices: artificial voices (Chapter 316, Statutes of 2024) · PUC § 2874, definitions subdivision added by AB 2905 · Checked 2026-09-30
6. 6
   California Business and Professions Code § 17940 defines a bot as an automated online account where all or substantially all of the actions or posts are not the result of a person.

   California Business and Professions Code, Division 7, Part 3, Chapter 6 (Bots), §§ 17940-17943 · § 17940(a) · Checked 2026-09-30
7. 7
   California Business and Professions Code § 17941 makes it unlawful to use a bot to communicate or interact online with a person in California with intent to mislead them about its artificial identity in order to incentivize a purchase or sale of goods or services or influence an election vote, and a clear, conspicuous disclosure that it is a bot avoids liability.

   California Business and Professions Code, Division 7, Part 3, Chapter 6 (Bots), §§ 17940-17943 · § 17941(a)-(b) · Checked 2026-09-30
8. 8
   Because the California bot law is framed around automated online accounts on online platforms, whether it reaches an AI voice agent on an ordinary PSTN phone call is uncertain.inferred

   California Business and Professions Code, Division 7, Part 3, Chapter 6 (Bots), §§ 17940-17943 · § 17940 definitions of bot, online and online platform · Checked 2026-09-30
9. 9
   47 CFR 64.1200(a)(3) requires prior express written consent for artificial or prerecorded voice telemarketing calls to residential lines, with limited exemptions for emergency, some non-commercial, non-advertising commercial, tax-exempt nonprofit and health care calls, several of them capped by call frequency.

   47 CFR § 64.1200 - Delivery restrictions · § 64.1200(a)(3) and (a)(3)(i)-(v) · Checked 2026-09-30
10. 10
    47 CFR 64.1200(b)(1) requires every artificial or prerecorded voice message to state clearly, at the beginning of the message, the identity of the business, individual or other entity responsible for initiating the call.

    47 CFR § 64.1200 - Delivery restrictions · § 64.1200(b)(1) · Checked 2026-09-30
11. 11
    47 CFR 64.1200(b)(2) requires an artificial or prerecorded voice message to state, during or after the message, a telephone number of the responsible entity other than that of the autodialer or prerecorded message player that placed the call.

    47 CFR § 64.1200 - Delivery restrictions · § 64.1200(b)(2) · Checked 2026-09-30
12. 12
    47 CFR 64.1200(b)(3) requires artificial or prerecorded voice telemarketing messages to offer an automated interactive voice- or key-press-activated opt-out mechanism within two seconds after the identification.

    47 CFR § 64.1200 - Delivery restrictions · § 64.1200(b)(3) · Checked 2026-09-30
13. 13
    The Cornell LII rendition of 47 CFR 64.1200 accessed on 2026-09-30 lists 90 FR 42138 (August 29, 2025) as its most recent amendment.

    47 CFR § 64.1200 - Delivery restrictions · source/history note at end of section · Checked 2026-09-30
14. 14
    The original text of EU AI Act Article 113 makes the Regulation generally applicable from 2 August 2026, with Chapters I and II applying from 2 February 2025 and Article 6(1) from 2 August 2027.

    Article 113: Entry into force and application · Article 113, second and third paragraphs · Checked 2026-09-30
15. 15
    EU AI Act Article 50(1) requires providers to design AI systems intended to interact directly with natural persons so that those persons are informed they are interacting with an AI system, unless this is obvious to a reasonably well-informed, observant and circumspect person given the circumstances.

    Article 50: Transparency obligations for providers and deployers of certain AI systems · Article 50(1), first subparagraph · Checked 2026-09-30
16. 16
    EU AI Act Article 50(2) requires providers of AI systems that generate synthetic audio, image, video or text to mark the outputs in a machine-readable format as artificially generated or manipulated, with exceptions such as assistive editing functions.

    Article 50: Transparency obligations for providers and deployers of certain AI systems · Article 50(2) · Checked 2026-09-30
17. 17
    EU AI Act Article 50(4) requires deployers of AI systems that generate or manipulate audio, image or video content constituting a deep fake to disclose that the content has been artificially generated or manipulated.

    Article 50: Transparency obligations for providers and deployers of certain AI systems · Article 50(4), first subparagraph · Checked 2026-09-30
18. 18
    EU AI Act Article 50(5) requires the Article 50 information to be given in a clear and distinguishable manner at the latest at the time of the first interaction or exposure, and to meet applicable accessibility requirements.

    Article 50: Transparency obligations for providers and deployers of certain AI systems · Article 50(5) · Checked 2026-09-30
19. 19
    The European Commission states that Article 50 applies from 2 August 2026, with a limited grace period only for AI systems placed on the market before that date, which must meet the marking obligations by 2 December 2026.

    Transparency obligations under Article 50 of the AI Act (FAQ) · FAQ question 'When does Article 50 of the AI Act start to apply and is there a grace period?' · Checked 2026-09-30
20. 20
    Breaches of the EU AI Act Article 50 transparency obligations can draw administrative fines of up to EUR 15 million or 3% of worldwide annual turnover, whichever is higher.

    Regulation (EU) 2024/1689 of the European Parliament and of the Council laying down harmonised rules on artificial intelligence (Artificial Intelligence Act) · Article 99(4)(g); SME cap in Article 99(6) · Checked 2026-09-30
21. 21
    The Commission's Article 50 FAQ says providers assess whether AI interaction is obvious from the standpoint of an average person who is reasonably well-informed, circumspect and observant, and that otherwise the information must be given from the start of the first interaction in a clear and distinguishable manner.

    Transparency obligations under Article 50 of the AI Act (FAQ) · FAQ question 'When do providers of AI systems have to inform people they are interacting with an AI system?' · Checked 2026-09-30
22. 22
    Article 50(1) places the interaction-notice obligation on the provider of the AI system rather than on the deployer, so a contact centre running a vendor's AI agent depends on the vendor's design, but the deployer controls configuration such as whether a vendor's disclosure is left enabled.inferred

    Transparency obligations under Article 50 of the AI Act (FAQ) · FAQ questions 'Who is a provider...' and 'Who is a deployer...' · Checked 2026-09-30
23. 23
    A natural-sounding AI voice agent answering a phone call is unlikely to count as 'obvious' AI under Article 50(1), so an EU contact centre voice agent should announce itself at the start of the call.inferred

    Transparency obligations under Article 50 of the AI Act (FAQ) · FAQ question 'When do providers of AI systems have to inform people they are interacting with an AI system?' · Checked 2026-09-30
24. 24
    FCC 24-17 is a Declaratory Ruling in CG Docket No. 23-362, adopted February 2, 2024 and released February 8, 2024.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Declaratory Ruling (FCC 24-17) · caption block (FCC number, docket, Adopted/Released lines) · Checked 2026-09-30
25. 25
    The FCC ruled that the TCPA's restrictions on use of an 'artificial or prerecorded voice' cover current AI technologies that generate human voices.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Declaratory Ruling (FCC 24-17) · para. 5 (paragraph number from text extraction; confirm) · Checked 2026-09-30
26. 26
    Under FCC 24-17, calls that use AI-generated voices need the called party's prior express consent unless the call has an emergency purpose or falls under an exemption.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Declaratory Ruling (FCC 24-17) · para. 9 (paragraph number from text extraction; confirm) · Checked 2026-09-30
27. 27
    FCC 24-17 states that AI-voice calls are subject to the identification rules for artificial or prerecorded voice messages in 47 CFR 64.1200(b), which require identifying the entity responsible for initiating the call.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Declaratory Ruling (FCC 24-17) · para. 9, citing 47 CFR 64.1200(b)(1)-(3) · Checked 2026-09-30
28. 28
    The reasoning in FCC 24-17 reaches AI voice technologies that interact with consumers on outbound calls, not only fully pre-rendered messages, so a conversational AI voice agent on an outbound call is likely an 'artificial voice' for TCPA purposes.inferred

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Declaratory Ruling (FCC 24-17) · para. 5 (discussion of technologies that emulate human voices to interact with consumers) · Checked 2026-09-30
29. 29
    FCC 24-17 treats AI voices as artificial voices under existing rules and does not by itself impose a separate federal duty to announce that a call uses AI; that AI-specific in-call disclosure appears only as a proposal in FCC 24-84.inferred

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Notice of Proposed Rulemaking and Notice of Inquiry (FCC 24-84) · paras. 10-14 (proposed definition and disclosure rules) · Checked 2026-09-30
30. 30
    FCC 24-17 notes that its ruling gives State Attorneys General an additional tool to pursue callers who use AI-generated voices in unlawful robocalls.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Declaratory Ruling (FCC 24-17) · para. 6 (from text extraction; confirm) · Checked 2026-09-30
31. 31
    FCC 24-17 names voice cloning as an AI technology that falls within the TCPA's existing prohibition on artificial or prerecorded voice messages.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Declaratory Ruling (FCC 24-17) · para. 5 · Checked 2026-09-30
32. 32
    FCC 24-84 is a Notice of Proposed Rulemaking and Notice of Inquiry in CG Docket No. 23-362, adopted August 7, 2024 and released August 8, 2024.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Notice of Proposed Rulemaking and Notice of Inquiry (FCC 24-84) · caption block · Checked 2026-09-30
33. 33
    FCC 24-84 proposes to define an 'AI-generated call' as a call that uses any technology or tool to generate an artificial or prerecorded voice or text using computational technology or other machine learning, including predictive algorithms and large language models, to communicate with a called party over an outbound telephone call.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Notice of Proposed Rulemaking and Notice of Inquiry (FCC 24-84) · para. 10 · Checked 2026-09-30
34. 34
    FCC 24-84 proposes that when callers obtain prior express consent they must clearly and conspicuously disclose that the consent may include consent to receive AI-generated calls.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Notice of Proposed Rulemaking and Notice of Inquiry (FCC 24-84) · para. 14 · Checked 2026-09-30
35. 35
    FCC 24-84 seeks comment on technologies that detect incoming calls that may be fraudulent or AI-generated, based on real-time analysis of voice call content, and alert consumers.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Notice of Proposed Rulemaking and Notice of Inquiry (FCC 24-84) · para. 35 (Notice of Inquiry portion) · Checked 2026-09-30
36. 36
    FCC 24-84 proposes exempting artificial or prerecorded voice calls made by an individual with a speech or hearing disability who uses AI or other technology to communicate over the telephone.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Notice of Proposed Rulemaking and Notice of Inquiry (FCC 24-84) · para. 19 · Checked 2026-09-30
37. 37
    FCC 24-84 proposes that a caller using an AI-generated voice must, at the beginning of each call, clearly disclose to the called party that the call uses AI-generated technology.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Notice of Proposed Rulemaking and Notice of Inquiry (FCC 24-84) · para. 14 · Checked 2026-09-30
38. 38
    The AI-generated call definition and disclosure requirements in FCC 24-84 are proposals and bind callers only if the FCC adopts them in a later order; this packet found no primary source showing such an order.inferred

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Notice of Proposed Rulemaking and Notice of Inquiry (FCC 24-84) · document type in caption (Notice of Proposed Rulemaking) · Checked 2026-09-30
39. 39
    FCC 24-84 explains that its proposed definition is limited to outbound calls because TCPA requirements extend only to calls 'made' or 'initiated' by the caller, avoiding AI uses consumers never interact with.

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Notice of Proposed Rulemaking and Notice of Inquiry (FCC 24-84) · para. 11 · Checked 2026-09-30
40. 40
    Because the TCPA artificial-voice rules attach to calls a caller makes or initiates, an AI virtual agent answering inbound customer calls is generally outside the FCC's AI-voice consent and disclosure framework; inbound AI disclosure duties come from other laws such as EU AI Act Article 50 or state statutes.inferred

    Implications of Artificial Intelligence Technologies on Protecting Consumers from Unwanted Robocalls and Robotexts, Notice of Proposed Rulemaking and Notice of Inquiry (FCC 24-84) · para. 11 · Checked 2026-09-30
41. 41
    47 U.S.C. 227(b)(1)(A) prohibits calls using an automatic telephone dialing system or an artificial or prerecorded voice to cellular numbers and certain other lines without the called party's prior express consent, except for emergency purposes.

    47 U.S. Code § 227 - Restrictions on use of telephone equipment · § 227(b)(1)(A) · Checked 2026-09-30
42. 42
    47 U.S.C. 227(d)(3) requires artificial or prerecorded voice systems to state the caller's identity at the beginning of the message, give the caller's telephone number or address during or after it, and release the called line within 5 seconds of hang-up notification.

    47 U.S. Code § 227 - Restrictions on use of telephone equipment · § 227(d)(3)(A)-(B) · Checked 2026-09-30
43. 43
    47 U.S.C. 227(b)(3) gives a private right of action for the greater of actual loss or $500 per violation, which a court may increase up to three times for willful or knowing violations.

    47 U.S. Code § 227 - Restrictions on use of telephone equipment · § 227(b)(3) · Checked 2026-09-30
44. 44
    47 U.S.C. 227(g) lets state attorneys general bring civil actions on behalf of residents for TCPA violations, seeking injunctions or damages of up to $500 per violation, trebled for willful or knowing violations.

    47 U.S. Code § 227 - Restrictions on use of telephone equipment · § 227(g)(1) · Checked 2026-09-30
45. 45
    Under Utah SB 226, high-risk AI interactions, such as those collecting sensitive health, financial or biometric information or giving financial, legal, medical or mental health advice, require proactive disclosure of generative AI use.

    Chatbots in Check: Utah's Latest AI Legislation · section on SB 226 · Checked 2026-09-30
46. 46
    Utah SB 226 provides a safe harbor from enforcement for suppliers whose generative AI clearly discloses its use at the outset of and throughout a consumer interaction.

    Chatbots in Check: Utah's Latest AI Legislation · section on SB 226 · Checked 2026-09-30
47. 47
    Utah SB 226 (2025) narrowed the Utah Artificial Intelligence Policy Act so that a supplier must disclose generative AI use in a consumer transaction only when the consumer clearly and unambiguously asks, or during a high-risk interaction.

    Chatbots in Check: Utah's Latest AI Legislation · section on SB 226 · Checked 2026-09-30
48. 48
    Utah SB 332 (2025) extended the sunset of the Utah Artificial Intelligence Policy Act to July 2027.

    Chatbots in Check: Utah's Latest AI Legislation · section on SB 332 · Checked 2026-09-30
49. 49
    The Webex AI Agent transparency disclosure is configured at the AI agent level and applies to both scripted and autonomous AI agents.

    What's new for administrators in Webex Contact Center · What's New entry 'AI Transparency Compliance: Disclosure Notice for Webex AI Agent' (July 31, 2026) · Checked 2026-09-30
50. 50
    On digital channels, the Webex AI Agent transparency note is shown once at the start of the AI-agent session with the first AI-generated response.

    Webex AI Agent Studio Administration guide · section 'Update autonomous AI agent profile', AI transparency settings · Checked 2026-09-30
51. 51
    In European regions the Webex AI Agent transparency disclosure is enabled by default, and administrators who disable it must acknowledge the risks and add audit comments before opting out.

    What's new for administrators in Webex Contact Center · What's New entry 'AI Transparency Compliance: Disclosure Notice for Webex AI Agent' (July 31, 2026) · Checked 2026-09-30
52. 52
    Outside European regions, Webex AI Agent administrators choose whether to enable the AI transparency disclosure and can configure its message; Cisco recommends enabling it as a best practice.

    Webex AI Agent Studio Administration guide · section 'Update autonomous AI agent profile', AI transparency settings · Checked 2026-09-30
53. 53
    Webex AI Agent can play an AI transparency disclosure on voice channels that callers cannot interrupt and that plays before the welcome message.

    What's new for administrators in Webex Contact Center · What's New entry 'AI Transparency Compliance: Disclosure Notice for Webex AI Agent' (July 31, 2026) · Checked 2026-09-30

Documents

Cite this page

WarmTransfer. (2026, September 30). AI voice and disclosure rules for calls. WarmTransfer. https://warmtransfer.net/knowledge/ai-voice-disclosure-rules

@misc{warmtransfer-ai-voice-disclosure-rules,
  title  = {AI voice and disclosure rules for calls},
  author = {{WarmTransfer}},
  year   = {2026},
  url    = {https://warmtransfer.net/knowledge/ai-voice-disclosure-rules},
  note   = {Verified 2026-09-30}
}