Can an AI legally make phone calls for you?

First, a line that matters: this is not legal advice

We build this product and we are not your lawyer. What follows is how we understand the landscape in the United States and how we have built for it. If you are doing anything at scale, or in a regulated field, ask someone qualified.

The rules were written about robocalls, not assistants

Telephone rules in the US grew up around automated marketing: dialling thousands of numbers, playing a recording, and hoping. That is what the law is aimed at, and it is aimed hard. Sending an artificial voice to people who did not ask for it, at scale, is the part that gets companies fined.

An assistant ringing a restaurant to book your table, or answering your own line when you cannot, is a different thing in kind. One person, one call, at your instruction, for a purpose the person on the other end is in business to handle.

Where the bright lines are

Whatever product you use, these are the ones worth holding.

• Say what it is. Our line introduces itself as an assistant and confirms it is an AI whenever anyone asks. Never let a voice claim to be a person.
• Do not do marketing with it. Calling strangers to sell is where the rules bite, and consent requirements apply whether or not a human is dialling.
• One call at a time, for a reason. An assistant handling your errands is not a dialler.
• Mind recording law. Some states require every party to consent before a call is recorded. We keep the written call and the transcript rather than the audio, which sidesteps most of it, but if your product records, find out which rule applies where you and your callers live.
• Keep a person reachable. If a caller wants a human, they should be able to get one.

What changes if you are a business answering your own line

Answering calls made to you is the easiest case: the caller dialled you. The main duties are disclosure and honesty about what the assistant can do.

Outbound is where care is needed. Calling your own customers back about their own job is ordinary business. Calling a list of people who never contacted you is marketing, and the rules for that are strict, expensive, and not worth testing.

Texting has its own rules, and they are stricter

Business texts in the US only get delivered from numbers registered under a carrier programme, and consent rules are enforced by the carriers themselves as well as by law. On CosVoice, texts to your line always arrive; texts from your line are limited until our registration clears, and STOP, START and HELP are handled for you.

How we have built for this

Concretely, because principles are cheap.

• The line says it is an assistant when asked, and never claims to be a person.
• It will not read out a card number or agree to a charge, so the most it commits you to is a booking.
• We keep transcripts and written notes, not call audio.
• What your line hears is sealed to your line; our staff cannot read it.
• One line, one assistant, no bulk dialling built in.

Common questions