Do I have to disclose an AI receptionist?

Start with the structural point, because it clears up most of the confusion. GreetKeeper answers calls that come to you. The TCPA and the FCC's February 2024 ruling on artificial voices govern calls that go out. Those are different bodies of law.

That does not mean inbound is a free-for-all. Two live state rules reach it, and both are about honesty rather than about the technology.

Maine's is the broad one. It sits in consumer-protection law, applies to trade or commerce, and covers textual or aural AI interaction.

Utah's AI Policy Act, as amended by SB 226, took effect on May 7 2025. Ordinary consumer dealings require disclosure when a person asks for it. Regulated occupations must disclose prominently and out loud at the start. The act lists those as medicine, law, accounting, nursing and psychology.

California AB 2905 gets cited over and over as governing inbound AI receptionists, often with a "$500 a call" penalty attached. Read the statute. It applies to outbound automatic dialing. If a vendor page quotes it at you for an inbound line, that page is wrong.

The FCC's one-to-one consent rule is also still quoted as live. It was vacated by the Eleventh Circuit on January 24 2025 in Insurance Marketing Coalition v. FCC and has since been repealed.

The FCC's September 2024 proposal on AI disclosure at call start remains a proposal. Texas and Colorado are both moving, and neither should be quoted without re-checking the current text.

Take an accounting firm in Salt Lake City. Accounting is one of the state-licensed occupations Utah's AI Policy Act names, so the firm has to disclose prominently and verbally at the start. A greeting that does the job: "Thanks for calling Wasatch Tax. I'm the firm's AI assistant. Are you calling about a return we're preparing, or something new?" The notice comes before the first question, and that ordering is the point.

Now a lawn care company in Portland, Maine. It isn't a licensed profession, but Maine's Title 10 §1500-DD covers any trade or commerce and any spoken AI conversation. The company needs a clear and conspicuous notice too, and the same style of opening line handles it.

Third, a bakery in Ohio. As of September 2026 there's no general inbound disclosure requirement that reaches it. The bakery could skip the notice. We'd still switch it on, because callers who know they're talking to an assistant give cleaner details, and because the rules are moving in one direction.

Start with where your callers are and what you do for them. A Utah dentist and a Utah florist sit under the same act with different duties: the florist must disclose when a consumer asks, while the dentist must say it up front without being asked.

Test the asked-directly case on a demo. Ring in and say, "Is this a real person?" The answer should be an immediate yes-it's-an-AI, in words you wrote, with no dodging.

Listen to your greeting with a stopwatch as well. If the notice lands after a 20-second welcome message and two questions, it's hard to call that the start. Put it in the first or second sentence.

Two cautions about what you'll read elsewhere. California AB 2905 covers outbound automated calls and doesn't govern a line that answers your phone, whatever a vendor blog says. Texas and Colorado are both in motion, so check the current text or ask your lawyer before relying on any summary, including this one. We aren't giving legal advice here.

Disclosure is a setting, not a workaround. You can have the assistant identify itself in the first line on every call, and you write the wording so it fits how your business speaks.

For a dental practice or a law firm, the Utah rule is the one to design around: put the notice at the start, verbally, before anything else happens.

Our disclosure and recording page carries the dated detail, and we update it when a statute changes rather than leaving a stale claim on a lander.