Does the TCPA apply to inbound calls?
- The short answer
- The TCPA mostly governs calls and texts a business places, not calls a customer makes to you. An AI receptionist answering your inbound line sits outside its core consent rules. The TCPA comes back into view once you text or call that person afterwards. Inbound AI calls also carry their own disclosure duties under state laws in Maine and Utah.
The longer answer
Congress aimed the Telephone Consumer Protection Act, 47 U.S.C. § 227, at outbound contact. Its rules cover autodialed calls, artificial or prerecorded voices, telemarketing and the Do Not Call registry. Every one of those is about a business reaching out.
Most of the confusion starts with the FCC's February 2024 ruling. It said an AI-generated voice counts as an artificial voice under the TCPA. That matters for calls you place with an AI voice. A customer who dials your number has placed the call themselves.
Two rules often quoted as current aren't. The FCC's one-to-one consent rule was vacated by the Eleventh Circuit in Insurance Marketing Coalition v. FCC on January 24, 2025. And the FCC's September 2024 proposal on AI-generated calls is still a proposal.
Inbound calls aren't free of rules, though. Maine's Title 10 §1500-DD bars an AI from leading a consumer to think they're talking to a person without clear notice. It covers spoken conversation too. Utah requires regulated occupations, such as medical, legal and accounting, to disclose AI out loud at the start of the call.
Where the TCPA does touch an inbound phone line
Texts back to the caller. A follow-up text is contact you send, so treat it with the TCPA in mind. Keep it to what the caller asked for, like a booking link or a confirmation, and honor every opt-out.
Marketing follow-ups. Adding a caller to a sales campaign is outbound telemarketing. That needs its own consent, separate from the fact that they once called you.
Callbacks placed by software. If your team uses a dialer or a recorded voice to call people back, the TCPA's rules on those calls apply in full.
Recording. Call-recording consent sits under federal and state wiretap laws, not the TCPA. Handle it with a disclosure at the start of the call.
How GreetKeeper handles it
GreetKeeper answers inbound calls on a dedicated local number you forward to. You write the opening line, so your AI disclosure and any recording notice play before the caller says a word. That puts the Maine and Utah notice in the first line of every call.
After a call, the caller receives one text with the booking link or the booking confirmation. A reply with the opt-out word stops any further texts, and your team's texts go only to the on-call person you name.
Every call arrives as a transcript and a short summary, so you have a record of what each caller heard. Plans start at $49 a month for 200 answered calls, with a 14-day free trial and no card needed.
TCPA and inbound call questions
Is an AI receptionist a robocall under the TCPA?
An AI voice counts as an artificial voice under the FCC's February 2024 ruling, but that rule is about calls a business places. When a customer calls you and GreetKeeper answers, your business hasn't placed a call. Disclosure duties in Maine and Utah still apply to inbound AI calls.
Do I need consent to text someone who called my business?
Treat any text as outbound contact. A text that delivers what the caller asked for, like a booking confirmation, sits in a different class from a marketing text. Marketing texts need written consent under FCC rules. GreetKeeper sends one post-call text and honors the opt-out word.
Is the FCC one-to-one consent rule in effect?
No. The Eleventh Circuit vacated it in Insurance Marketing Coalition v. FCC on January 24, 2025. Pages that still quote it as current are out of date.
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