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Washington

Telecom Compliance Reference — Updated January 2023

Mini-TCPA State — High Risk

Calling Hours

8:00 AM–9:00 PM

Min Penalty

$1,000

Registration

Required

Overview Calling Hours Consent Registration DNC Enforcement Case Law Legislation

Insurance Telemarketing Compliance in Washington

Insurance agency telemarketing and lead generation compliance in Washington

Guide last reviewed: January 2025

⚠

Mini-TCPA State — RCW 80.36 (Automatic Dialing & Announcing Devices); RCW 19.190 (CEMA)

Washington imposes stricter consent and calling requirements than federal TCPA.Insurance companies operating here face $1,000 per-violation penalties.

Washington Insurance Overview

Insurance telemarketing in Washington has a critical trap that catches out-of-state operations: the two-party consent law. Most insurance companies record all sales calls for compliance and quality assurance — in Washington, that is a criminal violation without affirmative consent from the called party. The fix is simple (disclosure at call start + verbal consent), but the number of insurance operations that miss this is staggering. Beyond recording, the compliance stack is CEMA for texts, ADAD for automated calls, CPA for deceptive practices, and CMS rules for Medicare/ACA products. Manual dialing with recording consent disclosure is the viable prospecting method. First-party opt-in lists for automated follow-up.

Penalty/Violation

$1,000

Willful

$2,000

Calling Hours

8:00 AM–9:00 PM

Private Suit

Allowed

Compliance Checklist

✓Register with Department of Agriculture as commercial telephone solicitor ($55 + $10,000 bond) — WA insurance license does NOT substitute for telemarketing registration,Two-party consent: disclose and get consent before recording any call (RCW 9.73.030) — many insurance compliance recording programs violate this,Obtain prior consent before automated text or voice outreach to WA consumers,CEMA compliance for any text/email marketing: prior consent or EBR required,Scrub federal National DNC Registry before every campaign,Medicare/Medicaid enrollment: follow CMS marketing rules in addition to state requirements,Do not purchase health insurance leads with bundled/shared consent — FCC one-to-one rule (Jan 2025) makes these unusable for automated outreach in WA,Honor opt-out requests immediately,Licensed agents calling existing policyholders about current policy matters have EBR coverage for manual calls only,Calling hours: 8:00 AM to 9:00 PM Pacific time,Maintain consent records and call recordings (with consent) for compliance

What Gets Companies Sued

✗Top violations for insurance companies in Washington: (1) Recording sales calls without two-party consent — extremely common for insurance companies with mandatory call recording policies designed for other states; (2) Automated text campaigns to Medicare/ACA leads without express consent; (3) Using purchased health insurance leads for automated outreach without verifying one-to-one consent; (4) Misrepresenting coverage terms or premium costs during phone solicitation — WA AG + OIC dual enforcement; (5) Failing to register as telemarketer while relying solely on insurance license.

Special Exemptions

Licensed insurance agents calling existing policyholders about their current policy — renewals, claims, policy service — have EBR exemption coverage for manual calls. This does NOT extend to prospecting new products to existing clients or cold calling new leads. The exemption is for servicing existing relationships only.

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 →