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Telecom Compliance Reference — Updated January 2025

Mini-TCPA State — High Risk

Calling Hours

8:00 AM9:00 PM

Min Penalty

$5,000

Registration

Required

California AI Voice Compliance

AI-generated voice agent compliance rules in California

Mini-TCPA State — Cal. Pub. Util. Code §§ 2871-2876; Cal. Penal Code § 632

California has enacted a state-level TCPA that goes beyond federal requirements. Federal compliance alone is not enough for AI Voice operations here.

Consent Requirements

Consent LevelWritten Consent Required

One-to-One Consent Required

Shared consent from lead generators is NOT valid. Consent must specifically name your company.

ATDS DefinitionBroader than federal
Checkbox ConsentValid
StatuteCal. Pub. Util. Code § 2874 (as amended by AB 2905); Cal. Penal Code § 632; 47 U.S.C. § 227

Highest complexity channel in California. AI voice agents trigger at least four overlapping regulatory frameworks: (1) ADAD — live intro required, consent to hear message, 9AM-9PM hours; (2) AB 2905 — must disclose AI voice at call start, $5,000/violation/day; (3) CIPA — if the call is recorded or monitored, all-party consent required, $5,000 per violation; (4) Federal TCPA — prior express written consent for marketing calls using automated systems. FTC impersonation rules add additional liability if AI voice mimics a real person without disclosure. California is the most hostile jurisdiction in the US for AI voice telemarketing deployment.

Calling Rules

Calling Hours8:00 AM9:00 PM
RegistrationRequired
Penalty / Violation$5,000
Willful Violation$10,000
Private Right of ActionYES

AI Voice Compliance Checklist

01Disclose AI nature at start of call — many states require this
02Obtain prior express consent before using AI voice
03Honor opt-out during the call immediately
04Check if state's ATDS definition covers AI voice dialers
05Apply same calling-hours rules as live agents
06Scrub DNC lists before each campaign
07Maintain call records and consent documentation
08Register as telemarketer if state requires
09Ensure AI cannot misrepresent itself as human
10Check for state-specific AI disclosure mandates
This checklist covers common requirements. State-specific rules may vary. Confirm with legal counsel for high-volume campaigns.

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This is a compliance reference tool, not legal advice. Data compiled from public statutes, LegiScan, CourtListener, state AG offices, and AI-assisted analysis. Verify all information with qualified counsel before relying on it. Full terms & data sources →