This page is not legal advice. It is a plain-language summary of the US rules that apply when a business uses an AI voice to call leads, written on October 8, 2026, with links to primary sources. Rules change and states add to them. Bring your counsel; we will answer their questions straight.
Is it legal to call leads with an AI voice?
Yes, with consent. The Telephone Consumer Protection Act (47 U.S.C. 227, 1991) restricts calls made with an "artificial or prerecorded voice." On February 8, 2024, the FCC issued a unanimous Declaratory Ruling confirming that AI-generated voices, including voice cloning and AI-generated call content, are "artificial" voices under the TCPA (FCC 24-17, CG Docket No. 23-362, February 8, 2024).
The ruling created no new rule; it confirmed that the rules for prerecorded calls apply to AI voices. The question is never "is AI calling allowed" but "do you have the consent the TCPA requires for an artificial-voice call of this type, to this number."
- Prior express consent covers non-marketing artificial-voice calls to a cell phone (an appointment reminder, a service confirmation).
- Prior express written consent is required for any artificial-voice call to a cell phone or residential line that introduces an advertisement or constitutes telemarketing (47 CFR 64.1200(a)(2) and (a)(3)).
A call to a new solar lead to qualify them for a site visit, or to an existing pest control customer to offer an add-on, is a marketing call. Plan on prior express written consent for AI-voice calls to the mobile numbers on those lists.
What counts as prior express written consent?
The FCC's definition (47 CFR 64.1200(f)) is a written agreement, signed by the consumer (an electronic signature or checkbox under the E-SIGN Act counts), that clearly and conspicuously discloses the consumer authorizes the seller to deliver telemarketing calls using an autodialer or an artificial or prerecorded voice, identifies the number, and states that consent is not a condition of purchase.
In practice: a disclosure on your lead form, next to the submit button, that names your company, says calls may use an automated or AI voice, and makes clear the lead can buy without agreeing. Keep the record: form text, timestamp, number, and ideally the IP address.
The "one-to-one" rule is gone. The FCC's December 2023 rule requiring consent one seller at a time was vacated by the Eleventh Circuit on January 24, 2025, in Insurance Marketing Coalition v. FCC (Reed Smith summary, January 2025). The underlying requirement stands: the consumer must have authorized calls from the seller who calls. If you buy leads, confirm the vendor's consent language covers your company and an AI voice.
What about the Do Not Call registry?
Telemarketing calls to numbers on the National Do Not Call Registry are prohibited unless an exemption applies: a signed written agreement to receive the calls, or an established business relationship (a purchase within the prior 18 months, or an inquiry within the prior 3 months) (47 CFR 64.1200(c)(2) and (f)).
The trap for pest control and insurance teams: an established business relationship keeps you clear of the national registry. It does not satisfy the written-consent requirement for an artificial-voice marketing call to a cell phone. Your own company-specific do-not-call list must be honored regardless.
What are the TCPA calling hours?
Federal rules prohibit telephone solicitations before 8 a.m. or after 9 p.m., local time at the called party's location (47 CFR 64.1200(c)(1)). "Local time" means the lead's time zone, not yours. Some states narrow the window; Florida's Telephone Solicitation Act, for example, ends commercial solicitation calls at 8 p.m. (Fla. Stat. 501.059).
What changed with the 2025 revocation rule?
The FCC's consent-revocation order (FCC 24-24) took effect April 11, 2025 (FCC, 2024; effective-date notice, Federal Register, October 11, 2024). Now at 47 CFR 64.1200(a)(10): consumers can revoke consent in any reasonable manner, callers cannot limit them to one method, and revocation and do-not-call requests must be honored within no more than 10 business days. For an AI voice agent, an opt-out said out loud on the call must be captured and honored. RevStrike does it on the call.
Which states require AI disclosure on a call?
The TCPA does not require you to say the voice is an AI. Some states do.
California. AB 2905 (2024), effective January 1, 2025, amended Public Utilities Code section 2874: a call placed by an automatic dialing-announcing device must announce, in a natural voice, if the message uses an artificial voice, meaning one generated or significantly altered using AI (Cal. Pub. Util. Code 2874; AB 2905). Whether a conversational agent is such a device is a question for counsel; the safe setting is to disclose.
Utah. The Artificial Intelligence Policy Act (SB 149, 2024) requires clear and conspicuous disclosure that a person is interacting with generative AI when the person asks. SB 226 (2025, effective May 7, 2025) narrowed the trigger to a clear and unambiguous request and added a safe harbor for AI that discloses at the outset that it is not human (SB 226 enrolled, Utah Legislature, 2025).
Other states have AI-disclosure and "mini-TCPA" laws with their own hours and consent rules. If you call into a state, check it.
Do I need consent to record the call?
Federal law and most states allow recording with one party's consent, which the calling business supplies. Eleven states require all parties to consent: California, Delaware, Florida, Illinois, Maryland, Massachusetts, Montana, Nevada, New Hampshire, Pennsylvania and Washington (Reporters Committee for Freedom of the Press, Reporter's Recording Guide). A recording notice at the top of the call is standard practice when calling into those states.
What does "consent on file" mean for your own inbound leads?
This is the case RevStrike is built for. A lead fills out your form. If the form carries the written-consent disclosure above, naming your company and covering AI-voice calls, you have consent to call that number with an AI voice, and the inquiry also gives you an established business relationship for do-not-call purposes. You keep the record and call within seconds, while consent and interest are both fresh. See speed to lead.
Three cases need more care. Purchased leads: consent must cover your company, not just the vendor. Aged leads: written consent does not expire on its own, but counsel should set a lookback. Existing customers: you have the relationship; you still need written consent for AI-voice marketing calls to cell phones. Medicare Advantage and Part D are off the table entirely: CMS marketing rules do not allow automated or AI-voice outreach even with permission to contact.
What does RevStrike do about all of this?
Guardrails are on by default; the choices that depend on your business are yours, and onboarding covers both before the first campaign. From the trust page:
- Calling windows, on by default. Campaigns dial inside permitted local calling hours. A per-session override exists for cases like testing your own numbers; it never lifts do-not-call.
- Do-not-call, always. DNC numbers are never dialed, under any setting. Opt-outs, including one spoken on the call, are honored immediately and permanently.
- AI disclosure, your toggle. Per agent: identify as an AI on every call, or disclose when asked. It never claims to be human.
- Consent-first design. Where written consent is required, we tell you before launch.
- Recording notice. The agent can state the call is recorded at the top; two-party handling is a per-account setting.
- Every call recorded, transcribed and logged. Erase removes transcript and recording and adds the number to your do-not-call list.
- Registered numbers, branded caller ID. SHAKEN/STIR attestation under your business identity, your name on caller ID, per-number reputation monitoring.
- Phone calls only. No SMS. Medicare not supported.