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Illinois

Telecom Compliance Reference — Updated January 2024

Mini-TCPA State — High Risk

Calling Hours

8:00 AM–9:00 PM

Min Penalty

$50,000

Registration

Required

Overview Calling Hours Consent Registration DNC Enforcement Case Law Legislation

Insurance Telemarketing Compliance in Illinois

Insurance agency telemarketing and lead generation compliance in Illinois

Guide last reviewed: January 2025

⚠

Mini-TCPA State — 815 ILCS 413/ (Restricted Call Registry Act)

Illinois imposes stricter consent and calling requirements than federal TCPA.Insurance companies operating here face $50,000 per-violation penalties.

Illinois Insurance Overview

Insurance telemarketing in Illinois requires triple compliance: ITSA/RCRA/ICFA telemarketing laws (registration + bond + dual DNC + consent), Illinois Department of Insurance regulations, and BIPA if any AI or biometric technology is used. The RCRA private right of action makes even DNC violations expensive ($500/call). BIPA exposure for AI voice is potentially catastrophic. Licensed agents with existing policyholders have limited EBR protection for manual calls. Illinois is the highest-risk state for insurance telemarketing compliance.

Penalty/Violation

$50,000

Willful

$50,000

Calling Hours

8:00 AM–9:00 PM

Private Suit

Allowed

Compliance Checklist

✓Licensed insurance producers must register as telephone solicitors with IL AG if making outbound sales calls to non-policyholders,Post $25,000 bond if registration required,Scrub both Illinois Restricted Call Registry and federal DNC,Manual dialing for cold outreach — 8 AM to 9 PM,Identify yourself as a licensed agent, state company, and disclose sales purpose,Do not misrepresent policy terms, coverage, or pricing — ICFA applies ($50,000/violation),EBR exemption for current policyholders (manual calls only, still must scrub RCRA),Provide 3-day cancellation right on phone contracts,If using AI voice: BIPA consent required separately from telemarketing consent,Honor opt-out immediately and maintain internal DNC,Medicare and health insurance calls subject to additional federal CMS requirements,Illinois Department of Insurance has independent enforcement authority

What Gets Companies Sued

✗Common insurance violations: (1) Auto-dialing Medicare-eligible consumers; (2) Not registering with IL AG; (3) Misrepresenting coverage or premiums; (4) Not scrubbing Illinois Restricted Call Registry; (5) Spoofing caller ID; (6) Using AI voice systems without BIPA consent.

Special Exemptions

Licensed insurance producers with existing policyholders have an EBR exemption for manual calls. Must still scrub RCRA even for EBR calls. BIPA applies if AI voice technology is used in calls.

Key State Rules

Mini-TCPAYes

RegistrationRequired

Class ActionsAllowed

Consent Requirements→Registration Details→DNC List→

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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 →