Most AI receptionist compliance writing is about the wrong activity

The TCPA robocall framework governs calls a business places out to consumers. A receptionist answers calls that people dial to you. Those are different activities, and the citation usually does not get checked.

The short version

  • The FCC's February 2024 ruling treats an AI-generated voice as an artificial or prerecorded voice for calls a business places to consumers. It addresses outbound calling.
  • That is not a blanket exemption for inbound. Maine and Utah both reach an inbound AI receptionist, and recording law reaches it everywhere.
  • The FCC one-to-one consent rule was vacated by the Eleventh Circuit in January 2025 and subsequently repealed. It still circulates as current.
  • The September 2024 FCC proposal on AI disclosure and a two-second opt-out is a proposal, not law.

What the outbound framework actually covers

Read the February 2024 FCC ruling and it covers calls a business places to a consumer. It asks for consent, for the caller to be named, and for an opt-out. Damages run from $500 to $1,500 a call with no cap. Those numbers are why the ruling gets quoted so often, and why it gets pinned to products it does not cover.

A receptionist answering a call the customer dialed is not making that call. Consent sits at the center of the robocall rules, and it does not arise the same way when the customer called you. This is not a clever reading. It is what the rules are for.

We are not lawyers and this is not legal advice. What we will say is that a page citing outbound robocall law at an inbound product has not checked its own source. A lot of pages here have not.

The rules that do reach you

Maine's Title 10 §1500-DD has applied since October 2025. A business may not use an AI chatbot in trade in a way that could mislead a shopper into thinking they are dealing with a person, unless they are told clearly. The wording covers spoken talk as well as text, so it reaches a receptionist on the phone. This is the clearest inbound duty we found.

Utah's AI Policy Act, SB 149 as amended by SB 226, has applied since May 2025. Most business calls need a disclosure only when the caller asks. But a state-licensed trade, such as medicine, law, accounting or nursing, must say so out loud at the start. If you run a dental, medical or legal practice in Utah, that is a product need rather than a footnote.

Recording law reaches inbound calls everywhere, and an AI receptionist writes a transcript by default. Some states want every party to agree rather than one. That holds whether or not you keep audio. It is worth a thought before you decide transcripts are the safe option.

Two things that circulate as current and are not

The FCC one-to-one consent rule was struck down by the Eleventh Circuit in January 2025, in Insurance Marketing Coalition v. FCC, and later repealed. Vendor pages still describe it as live, and so does a fair amount of marketing.

The September 2024 FCC proposal on AI disclosure and a two-second opt-out is still a proposal. It has not become law. Calling a proposed rule a requirement is a common error here.

California AB 2905 is the third. It says you must tell the person called that a recorded message uses an artificial voice. It covers calls placed through an automatic dialing-announcing device, so it is outbound only. Several vendor pages treat it as an inbound rule, sometimes with a $500-per-call figure attached.

What we are not telling you

Hear it handle one of your own calls

Your scenario, your greeting, a couple of minutes.