Research for the five-part rules series. What someone starting out needs to know before building an AI receptionist or an outbound AI caller, by country, with sources. Researched 29 Oct 2026.
Rules 5 of 5 · All four compared
What changes when the same AI receptionist or outbound caller works in each country. Each country's tab has the sources, the inbound and outbound split, industry rules, and what Perplexity got wrong.
| UK | US | Canada | Australia | |
|---|---|---|---|---|
| Do-not-call list | TPS (consumers) and CTPS (companies); live marketing calls must screen, registrations take effect after 28 days | National Do Not Call Registry (FTC), scrub every 31 days, plus internal list kept 5 years and some state lists | National DNCL; register and use a copy no more than 31 days old; internal list: add within 14 days, keep 3 years and 14 days | Do Not Call Register (ACMA); wash within 30 days before calling; registration permanent; business numbers ineligible |
| AI disclosure | No statute; CMA guidance (March 2026) says consider labeling AI agents so customers are not misled | No federal rule yet (FCC proposal pending); required in some states: California for autodialed artificial voice, Utah when asked, Maine if it could mislead | Not required by law; impersonation is deceptive telemarketing; CRTC consulting (2026-132) on a not-a-live-person disclosure | Not required by law; misleading conduct ban (ACL s 18, s 29) covers pretending to be human |
| Calling hours | No statutory calling hours | 8am to 9pm called party's local time (8am to 8pm in Florida, Oklahoma, Maryland) | 9:00 a.m. to 9:30 p.m. weekdays, 10:00 a.m. to 6:00 p.m. weekends, recipient's local time | Weekdays 9am to 8pm, Saturday 9am to 5pm, no Sundays or national public holidays (recipient's local time) |
| Consent for automated calls | Automated (AI) marketing calls need specific prior consent covering automated calls, B2C and B2B (PECR reg 19) | Prior express consent for any AI-voice call to cell phones; prior express written consent for telemarketing | Prior express consent for any ADAD (pre-recorded or synthesized voice) sales call; DNCL exemption for existing business relationship (18 months purchase, 6 months inquiry); CASL consent for follow-up texts | Consent needed to call registered numbers and for every marketing SMS or email (Spam Act); unregistered numbers can be called but hours and ID rules still apply |
| Call recording | Notice-based: tell callers you record and why; lawful basis under UK GDPR, not necessarily consent | One-party federally; all-party in about a dozen states incl. California, Florida, Illinois, Pennsylvania, Washington | One-party under Criminal Code s. 184, plus a PIPEDA notice and purpose (implied consent if the caller continues) | State by state: all-party in NSW, WA, SA, Tas, ACT; party may record in Vic, Qld, NT |
| Regulator | ICO (PECR, UK GDPR), Ofcom (silent calls, CLI), CMA (misleading practices) | FCC (TCPA) and FTC (TSR, DNC), plus state attorneys general and private lawsuits | CRTC (calls, texts), OPC and provincial commissioners (privacy), Competition Bureau (deception) | ACMA (calls, SMS), OAIC (privacy), ACCC (misleading conduct) |
| Top penalty | £17.5 million or 4% of global turnover (ICO); 10% of global turnover (CMA) | $500 to $1,500 per call in private TCPA suits with no cap; FTC up to $53,088 per violation; FCC fined one AI robocaller $6 million | Calls: $15,000 per violation (corporation); texts under CASL: $10 million per violation; Quebec Law 25: $25 million or 4% of worldwide turnover (penal) | A$2.22 million per day (DNCR); A$50 million or 30% of turnover (privacy and consumer law) |
For an outbound AI caller, the US is the strictest of the four in practice: any AI-voice call to a mobile needs prior consent (written consent if it sells), there is no cap on private TCPA lawsuits at $500 to $1,500 a call, and three states already demand AI disclosure. The UK has the biggest regulator fine (£17.5 million or 4% of turnover) and is the only one that needs consent before robocalling a business. Australia has the tightest calling hours (no Sundays) and needs everyone's consent to record in most states. For an inbound AI receptionist the gap is much smaller: in all four it comes down to a recording notice, handling the data properly, and not pretending to be human.
This is research for scripts, not legal advice, and the videos should say so. Rules marked Secondary or Unverified need a primary source before they go on screen.
Rules 1 of 5 · United Kingdom
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An outbound AI that calls people to market something is an automated call: you need prior consent that specifically covers automated calls from you. Not being on the TPS is not enough, and this applies to business numbers too.
Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), regulation 19
A marketing call with a live human speaking cannot go to a number on the TPS or CTPS unless that person or business told you they are happy to get your calls. A new registration takes effect after 28 days, so screen lists at least every 28 days and keep your own do-not-call list.
PECR regulation 21
Marketing calls must display a number the person can call back on, never withheld or spoofed. An automated call must also give your name and an address or freephone number.
PECR regulation 19(2) (caller line identity) and regulation 24 (information to be provided)
Abandoned calls must stay under 3% of live calls per campaign per 24 hours, and if no agent is ready a short recorded message identifying the caller must play within 2 seconds of the person answering. An AI that pauses or drops calls under load creates the same problem.
Communications Act 2003 ss.128 to 131; Ofcom Persistent Misuse Statement (December 2016)
PECR fines used to stop at £500,000. Since 5 February 2026 the ICO can fine up to £17.5 million or 4% of global annual turnover, whichever is higher, the same as UK GDPR.
Data (Use and Access) Act 2025, commenced by SI 2026/82 (Commencement No. 6 Regulations)
No UK statute makes an AI say it is an AI. But the CMA says to consider labeling your agent so customers do not think a real person is serving them, and the business is responsible for what its AI says, just like an employee.
Digital Markets, Competition and Consumers Act 2024, Part 4 Chapter 1 (unfair commercial practices); CMA guidance on AI agents, 9 March 2026
The UK is notice-based, not one-party or all-party consent: you must tell callers the call is recorded (or transcribed) and why, at the start. A recorded message is good practice, and the full privacy details can follow elsewhere.
UK GDPR Articles 5, 6 and 13; Investigatory Powers Act 2016 s.46 and the Investigatory Powers (Interception by Businesses etc. for Monitoring and Record-keeping Purposes) Regulations 2018, reg 3
Health details are special category data. Keep a clinic's AI to admin (booking, directions, messages), send red-flag symptoms to 999 or NHS 111 and a human, and know that an AI that triages or suggests diagnoses can become a regulated medical device.
UK GDPR Article 9; Medical Devices Regulations 2002 (MHRA); Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, reg 17 (CQC)
Sending call audio or transcripts to a US vendor is a restricted transfer: use the UK-US data bridge (only if that vendor is certified) or the UK IDTA or Addendum, and sign an Article 28 processing agreement.
UK GDPR Chapter V (Articles 45 and 46) and Article 28; Data Protection (Adequacy) (United States of America) Regulations 2023
Required: no
No UK statute requires an AI voice agent to announce it is an AI. It is still risky to hide it: under the DMCC Act 2024 (in force 6 April 2025) a misleading action or omission is unlawful, and the CMA's 9 March 2026 guidance on AI agents tells businesses to consider labeling an AI agent so customers are not misled into thinking a real person is serving them, and not to overstate what the AI can do. For outbound marketing, the automated-call consent itself must specifically cover automated calls, so the person has in effect agreed to robocalls in advance.
notice-based
The UK has no simple one-party or all-party rule. A business recording calls on its own system is authorized under Investigatory Powers Act 2016 s.46 and the 2018 Interception by Businesses Regulations (which replaced the Telecommunications (Lawful Business Practice) Regulations 2000) only if it has made all reasonable efforts to inform users that calls may be intercepted, and under UK GDPR it needs a lawful basis (often legitimate interests or contract, not necessarily consent) plus transparency. The ICO says you must tell people you are recording and why; a recorded message is good practice. Transcripts and AI summaries are personal data too. If callers are abroad (for example a US all-party state), that place's rules may also apply.
| Sector | Law or regulator | The agent must not | Safeguards | Checked |
|---|---|---|---|---|
| healthcare | UK GDPR Article 9 (ICO); CQC under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (reg 12 safe care, reg 17 governance); MHRA under the Medical Devices Regulations 2002; NHS Data Security and Protection Toolkit (DSPT) for anyone with access to NHS patient data or systems | Diagnose, give treatment advice, claim to be a clinician, dismiss red-flag symptoms, or leave clinical details in voicemail. AI that assesses symptoms, signals urgency or suggests diagnoses may be a medical device needing MHRA compliance. | Keep the AI to admin (booking, directions, messages); hard-coded emergency branch telling callers to ring 999 for emergencies and NHS 111 for urgent advice, plus transfer to staff; DPIA before handling patient data; Article 28 agreement; DSPT completed annually (by 30 June) where NHS data is involved; CQC expects AI to support, not replace, human decisions and patients to be told AI's role. | Verified |
| financial services | FCA under FSMA 2000 (s.21 financial promotions), Consumer Duty (PRIN 2A), COBS, ICOBS, MCOB, CONC | Give unauthorized advice, make unapproved financial promotions, call about pensions cold (banned in most cases under PECR reg 21B), or let the AI alone decline credit or insurance. | Approved scripts only, a qualified human for advice and complaints, full call records, vulnerability escalation. | Secondary source |
| debt collection | FCA CONC 7 (arrears, default and recovery), Consumer Credit Act 1974, Protection from Harassment Act 1997 | Harass, call excessively or at unreasonable times, mislead about legal consequences, or reveal the debt to a third party. | Verify identity before discussing the debt, frequency limits, immediate human escalation for vulnerability, disputes or Breathing Space. | Secondary source |
| legal | SRA Standards and Regulations; Legal Services Act 2007; claims management marketing calls need specific consent under PECR reg 21A | Hold itself out as a solicitor, give legal advice, promise outcomes, or cold call about claims without consent. | Intake and booking only, conflict and limitation checks by humans, confidentiality controls. | Secondary source |
| real estate | Estate Agents Act 1979 and National Trading Standards Estate and Letting Agency Team; DMCC Act 2024 (material information); Equality Act 2010 | Invent property facts (price, tenure, lease length, charges), invent competing interest, or steer callers based on protected characteristics. | Connect the AI to a live listing database, send offers and negotiations to a human, screen outbound campaigns against TPS. | Secondary source |
| home services | Consumer Rights Act 2015; Consumer Contracts Regulations 2013 (cancellation rights); DMCC Act 2024; Gas Safe register and HSE for gas work | Quote an estimate as a fixed price, claim accreditations the trader lacks, use fake urgency, or talk a caller through dangerous repairs. | A price list that marks estimates and call-out fees, written booking confirmation with cancellation info, safety branch: suspected gas leak goes to the National Gas Emergency number 0800 111 999, danger to life goes to 999. | Secondary source |
Rules 2 of 5 · United States
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The FCC ruled that AI-generated and cloned voices are an 'artificial or prerecorded voice' under the TCPA. So every outbound AI call to a cell phone or home line needs the called person's prior express consent, unless it is an emergency or exempt call.
47 USC 227(b)(1); FCC Declaratory Ruling FCC 24-17, CG Docket 23-362
If the AI call is telemarketing or an ad, you need prior express WRITTEN consent: a signed (e-signature is fine) agreement that names the seller and says it covers calls with an artificial or prerecorded voice, and that buying is not conditional on it. A bought lead list is not consent.
47 CFR 64.1200(a)(2), (a)(3) and definition at 64.1200(f)(9)
An artificial-voice message must state the business's name at the start and give a callback number. A telemarketing one must offer an automated voice or keypress opt-out within two seconds of that identification.
47 CFR 64.1200(b)(1) to (b)(3)
People can revoke consent and the caller must honor it within a reasonable time, no more than 10 business days. Internal do-not-call requests also have to be honored within 10 business days and kept for 5 years. From 25 November 2026 callers may name ONE official opt-out method (keypress, a reply word, or a website or number) and say it clearly on each call.
47 CFR 64.1200(a)(10) and (d)(3); FCC 26-67
Before any sales call, remove numbers on the National Do Not Call Registry using a copy downloaded no more than 31 days ago, plus your own internal list. A number on the Registry can only be called with written permission or an established business relationship.
16 CFR 310.4(b)(3)(iv) (TSR safe harbor); 47 CFR 64.1200(c)(2)
Federal law bans telemarketing calls before 8am or after 9pm in the CALLED person's local time. Florida, Oklahoma and Maryland cut it off at 8pm and cap sales calls at 3 per person per 24 hours on the same subject.
47 CFR 64.1200(c)(1); 16 CFR 310.4(c); Fla. Stat. 501.616(6); Md. Code Com. Law 14-4502(c)
Federal law lets one party consent to recording, but about a dozen states, including California, Florida, Illinois, Pennsylvania and Washington, need every party to consent. Because an AI receptionist rarely knows where the caller is, announce recording and transcription at the start of every call.
18 USC 2511(2)(d); Cal. Penal Code 632; Fla. Stat. 934.03(2)(d); 18 Pa.C.S. 5704(4); RCW 9.73.030; 720 ILCS 5/14-2
There is still no federal rule forcing every AI agent to announce it is AI (the FCC's 2024 proposal is pending). But California requires an artificial-voice notice on autodialed prerecorded calls, Utah requires disclosure when the caller asks, and Maine bans chatbots (including voice) that could mislead people into thinking they are human unless disclosed.
FCC NPRM FCC 24-84 (proposed); Cal. Pub. Util. Code 2874 (AB 2905); Utah Code 13-75-103 (SB 226); Maine 10 MRSA 1500-DD (LD 1727)
If the AI receptionist answers for a clinic or other HIPAA covered entity and handles patient information, every vendor in the chain that touches it (voice platform, transcription, LLM, phone carrier storing recordings) is a business associate and needs a signed business associate agreement.
45 CFR 164.502(e), 164.504(e), 164.308(b) (HIPAA)
Required: depends
Federal: no rule yet that every AI call must say 'I am an AI'. The FCC proposed one in August 2024 (FCC 24-84: disclose AI when getting consent and at the start of each AI call) and, as of October 2026, has not adopted it. But the TCPA already requires naming the business on any artificial-voice call, and the FTC can act on material deception. States: California (Pub. Util. Code 2874 as amended by AB 2905, since 1 January 2025) requires autodialed prerecorded calls to say if the message uses an artificial voice; Utah (Code 13-75-103) requires disclosure if a consumer clearly asks, and up front for high-risk interactions in licensed occupations, with a safe harbor if the AI discloses at the outset; Maine (LD 1727, since 16 September 2025) makes it an unfair trade practice to use an AI chatbot, including aural ones, in a way that may mislead consumers into thinking it is human without clear disclosure; Texas TRAIGA (since 1 January 2026) requires healthcare providers to disclose AI use to patients; California's older BOT law (Bus. and Prof. Code 17940) covers online bots. Colorado's AI Act never took effect: it was repealed and re-enacted as SB 26-189 (signed 14 May 2026, applies from 1 January 2027). Best practice for beginners: always disclose at the start, inbound and outbound.
one-party federally, all-party in about a dozen states
The federal Wiretap Act (18 USC 2511(2)(d)) allows recording with one party's consent. States that require consent of all parties include California (Penal Code 632), Florida (934.03), Illinois (720 ILCS 5/14-2), Maryland, Massachusetts, Montana, New Hampshire, Pennsylvania (18 Pa.C.S. 5704), Washington (RCW 9.73.030), plus Connecticut (civil), Nevada (phone calls, by case law) and others with qualifications. Washington accepts an announcement 'in any reasonably effective manner' as consent, but the announcement must itself be recorded. Interstate calls are unsettled, so the safe default is to announce recording and transcription at the start of every call and offer a way to continue unrecorded. California's 2026 CIPA reform (SB 690, signed 30 September 2026) left Penal Code 632 untouched, so call recording claims still carry $5,000 per violation.
| Sector | Law or regulator | The agent must not | Safeguards | Checked |
|---|---|---|---|---|
| healthcare | HIPAA (45 CFR Parts 160 and 164), HHS Office for Civil Rights; Texas TRAIGA for Texas providers; Washington My Health My Data Act | Handle patient information without a BAA with every vendor in the chain; give diagnosis, triage or medication advice; disclose appointment or test details to an unverified caller; queue a caller describing an emergency | Signed BAAs (voice platform, LLM, transcription, carrier), scheduling and admin only, identity checks before discussing records, an emergency script that says call 911, human escalation for anything clinical. HHS says a cloud vendor storing even encrypted patient data is a business associate. | Verified |
| debt collection | FDCPA and Regulation F (12 CFR Part 1006), CFPB and FTC; state collection licensing | Call more than 7 times in 7 days about a debt, or within 7 days after a phone conversation; call before 8am or after 9pm; reveal the debt to third parties or in a voicemail beyond the 'limited-content message'; threaten action that is not lawful or intended | Hard-code the 7-in-7 cap and quiet hours in the dialer, use the Reg F limited-content voicemail, route disputes, attorney representation and bankruptcy straight to a human. Statutory damages up to $1,000 per individual suit. | Verified |
| financial services | Gramm-Leach-Bliley Act and FTC Safeguards Rule (16 CFR Part 314); CFPB; state insurance regulators; TCPA (FCC 26-67 eases fraud alerts from 25 November 2026) | Collect PINs, passcodes or full account credentials by voice; make or imply credit, coverage or underwriting decisions; quote rates the business has not approved | Appointment setting and document checklists only, human handoff for money movement and disputes, written vendor security contracts, do not use voice as the only authentication factor | Secondary source |
| legal | State rules of professional conduct (ABA Model Rules 1.6, 5.3, 5.5), state bars; Utah AIPA treats licensed occupations as high-risk interactions | Give legal advice, imply an attorney-client relationship has formed, or promise outcomes or deadlines | Say up front it is an automated intake assistant and that no attorney-client relationship exists until the firm confirms; escalate urgent matters (custody, deadlines, domestic violence) to a lawyer; confidentiality terms with vendors | Secondary source |
| real estate | Fair Housing Act (42 USC 3601 and following), HUD and DOJ; state licensing; TCPA and DNC for lead calls | Steer callers by race, religion, family status, disability or other protected traits, or answer 'what kind of people live there'; cold-call DNC-listed numbers from bought lists | Neutral property-only scripts, refusal of steering questions, licensed human for offers and negotiation, written consent for AI lead follow-up | Secondary source |
| home services | FTC Act section 5 and the TSR, TCPA, state contractor licensing and home-improvement laws | Tell a caller a gas smell, sparks, flooding near electrics or a CO alarm is safe; quote binding prices or claim licensing or insurance the business has not confirmed; run outbound AI sales calls to bought lists | Hazard keyword detection that tells the caller to leave and call 911 or the utility, then alerts the owner; human approval for quotes; consent records for any outbound follow-up | Secondary source |
Rules 3 of 5 · Canada
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Using an automatic dialing-announcing device (ADAD) for a sales call is banned unless the person gave prior express consent that names the caller and the specific number. The ADAD definition already covers a pre-recorded or synthesized voice, and an existing business relationship does not replace this consent.
CRTC Unsolicited Telecommunications Rules, Part IV (ADAD Rules), made under Telecommunications Act s. 41
Register with the National DNCL operator, subscribe for the area codes you call, and use a copy of the list no more than 31 days old. Calls to numbers on it are banned unless you have express consent or an exemption applies.
Unsolicited Telecommunications Rules, Part II (National DNCL Rules); Telecommunications Act s. 41.1 to 41.6
Sales calls only 9:00 a.m. to 9:30 p.m. on weekdays and 10:00 a.m. to 6:00 p.m. on weekends, in the called person's time zone. Non-sales robocalls (reminders, collections, surveys) must keep the same hours.
Unsolicited Telecommunications Rules, Part III (Telemarketing Rules) and Part IV (ADAD Rules)
The call must open by naming who it is for and its purpose, with a callback number and an email or postal address, and must display a caller ID number that can actually be called back. Exempt callers must still identify themselves at the start.
Unsolicited Telecommunications Rules, Parts III and IV; Telecommunications Act s. 41.7(3)
When someone says stop, add them to your internal list within 14 days and keep them there for 3 years and 14 days. This applies even to callers exempt from the National DNCL, and to B2B calls.
Unsolicited Telecommunications Rules, Part III; Telecommunications Act s. 41.7(3)
A DNCL exemption covers people who bought from you in the last 18 months or made an inquiry in the last 6 months. It lifts the DNCL only: hours, identification, internal lists and the ADAD consent rule still apply.
Telecommunications Act s. 41.7(1)(e) and (2)
No federal or provincial statute requires a voice agent to say it is an AI. Pretending to be a person, a bank or an official in a sales call can be deceptive telemarketing, a criminal offence. The CRTC is consulting on whether robocalls must say they are not a live person.
Competition Act s. 52.1 (deceptive telemarketing) and s. 74.01; CRTC Notice of Consultation 2026-132
Criminal law lets a participant record a call. Privacy law still says tell the caller you are recording, say why, and offer an alternative if the recording is not essential. Voiceprints need express consent.
Criminal Code s. 184(2)(a); PIPEDA Schedule 1 Principle 4.3; OPC guidance updated 8 October 2026
Before sending call data outside Quebec (for example to a US AI vendor), do a privacy impact assessment. If the agent makes a decision based exclusively on automated processing, tell the person and let them have it reviewed by a staff member. Serve Quebec consumers in French.
Quebec Act respecting the protection of personal information in the private sector, ss. 12.1 and 17 (Law 25); Charter of the French Language s. 50.2 (Bill 96)
Required: no
As of 29 October 2026 no Canadian statute or CRTC rule requires an AI voice agent to announce that it is AI, inbound or outbound. The risk is deception: Competition Act s. 52.1 makes materially false or misleading telemarketing claims a criminal offence, and the Canadian Digital Regulators Forum (CRTC, Competition Bureau, OPC) has flagged AI voice impersonation in robocalls. CRTC Notice of Consultation 2026-132 asks whether telemarketers must tell consumers a call uses synthesized or AI voice (not a live person); interventions closed 27 July 2026 and replies 11 August 2026, with no decision yet. In Quebec, Law 25 s. 8.1 (identify, locate or profile technology) and s. 12.1 (exclusively automated decisions) can create disclosure duties in specific situations.
one-party (criminal law) plus notice-based (privacy law)
Criminal Code s. 184(2)(a) lets a person who is a party to the call (or has one party's consent) record it, so interception is not a crime. Separately, PIPEDA (and Alberta PIPA, BC PIPA, Quebec's private sector act) requires telling the caller the call is recorded, stating the purpose, and obtaining consent: implied if they carry on after the notice, express for voiceprints or sensitive data. OPC updated its recording guidance on 8 October 2026 to treat voiceprints as sensitive biometric information. The rules apply whether the customer or the business placed the call, and a business must make sure its call centre or AI vendor follows them.
| Sector | Law or regulator | The agent must not | Safeguards | Checked |
|---|---|---|---|---|
| healthcare | Ontario PHIPA (IPC Ontario); Alberta Health Information Act; Quebec health information act; PIPEDA or PIPA elsewhere | Give diagnoses, treatment or triage advice, confirm health details without verifying identity, or let a vendor use health data for anything beyond the service | Book, cancel and route only; emergency phrases go straight to 911 and a human; written service provider agreement (PHIPA limits electronic service providers to what the service needs); short retention; no model training on patient calls. PHIPA AMPs up to $50,000 (individual) and $500,000 (organization) since 1 January 2024 | Verified |
| financial services | FCAC and OSFI (federal banks and insurers), AMF in Quebec, FSRA in Ontario, provincial securities regulators | Give personalized advice or suitability recommendations, bind coverage, approve credit, or ask for full passwords, PINs or one-time codes | Pre-approved factual scripts only, licensed human for advice and complaints, authenticate through approved channels, keep full transcripts | Unverified |
| debt collection | Provincial collection acts (e.g. Ontario Collection and Debt Settlement Services Act; Quebec Consumer Protection Act and OPC Quebec); CRTC ADAD rules for non-sales robocalls | Threaten, harass, imply it is a court, lawyer or police, disclose the debt to third parties, or call outside the ADAD hours | Identify the creditor at the start, honor cease-contact requests, provincial contact-frequency limits, human for disputes | Unverified |
| legal | Provincial law societies (e.g. Law Society of Ontario, Barreau du Quebec) | Give legal advice, promise outcomes, or create a lawyer-client relationship by accident | Intake and booking only, conflict check before collecting facts, clear statement that it is not a lawyer | Unverified |
| real estate | Provincial regulators (RECO in Ontario under TRESA, OACIQ in Quebec) | Hold itself out as a registered agent, negotiate offers, or make value or zoning claims | Showing bookings and lead capture only; outbound prospecting follows DNCL and ADAD rules | Unverified |
| home services | Provincial consumer protection acts; Competition Act (Competition Bureau); provincial trade licensing | Misstate licensing or insurance, quote a final price that is only an estimate, or give gas, electrical or structural safety instructions | Gas smell, CO alarm or flooding: tell the caller to leave and call 911 or the utility; human confirms prices and contracts; outbound sales calls follow DNCL, hours and ADAD consent | Secondary source |
Rules 4 of 5 · Australia
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A telemarketing call to a number on the Do Not Call Register needs the account holder's consent. A recorded or synthetic voice call counts as a voice call, so AI dialers get no exemption. Wash your list within the 30 days before calling; registration is permanent and business numbers cannot be registered.
Do Not Call Register Act 2006 (Cth) s 11 (unsolicited telemarketing calls), s 4 (voice call includes a recorded or synthetic voice)
Sales calls only 9am to 8pm on weekdays and 9am to 5pm on Saturdays, never on Sundays or national public holidays (New Year's Day, Australia Day, Good Friday, Easter Monday, Anzac Day, Christmas Day, Boxing Day). The clock is the recipient's usual home address, not yours. These hours apply to business numbers too.
Telecommunications (Telemarketing and Research Calls) Industry Standard 2017, s 8(1), 8(3), 8(4)
At the start of every sales call give the business name, the name of whoever caused the call (your client), and the purpose. A call made solely with a recorded or synthetic voice is excused from giving a person's first name, but nothing else. On request, give contact details including an Australian phone number.
Telemarketing and Research Calls Industry Standard 2017, s 9(2), 9(4), s 11
If a call uses a recorded or synthetic voice, the caller must provide a mechanism during the call for the recipient to request the caller's contact and complaint details, for example pressing a button for an operator.
Telemarketing and Research Calls Industry Standard 2017, s 12
End the call immediately if the person asks or otherwise shows they do not want it to continue. Caller ID must be switched on, and the number shown must reach someone who can explain the call, and keep working for at least 30 days.
Telemarketing and Research Calls Industry Standard 2017, s 13 (terminating a call), s 14 (calling line identification)
NSW, WA, SA, Tasmania and the ACT generally make it an offense to record a private conversation without every party's consent (narrow exceptions). Victoria, Queensland and the NT let a party record but restrict sharing the recording. Callers cross borders, so announce recording at the start everywhere.
Surveillance Devices Act 2007 (NSW) s 7; Surveillance Devices Act 1999 (Vic) ss 6, 11; Invasion of Privacy Act 1971 (Qld) s 43; Surveillance Devices Act 1998 (WA) s 5; Surveillance Devices Act 2016 (SA) s 4; Listening Devices Act 1991 (Tas) s 5; Listening Devices Act 1992 (ACT) s 4; Surveillance Devices Act 2007 (NT) s 11
No law makes an AI agent announce itself, but conduct in trade that is misleading or likely to mislead is banned, and false representations carry penalties up to the greater of A$50 million, 3 times the benefit, or 30% of turnover. Claiming to be a named human, or implying it, is the risk.
Competition and Consumer Act 2010 (Cth) Sch 2 (Australian Consumer Law) s 18 (misleading conduct, no fine but injunctions and damages) and s 29 (false representations, civil penalty), penalties s 224
The Privacy Act covers businesses over A$3 million turnover, but also any health service provider of any size (every dentist, physio and GP), anyone who trades in personal information, and AML/CTF reporting entities such as real estate agents and lawyers from 1 July 2026 (for that work). Recordings and transcripts of identifiable callers are personal information.
Privacy Act 1988 (Cth) s 6D (small business operator), s 6E; Australian Privacy Principles 1, 3, 5, 6, 8, 11
A marketing SMS after a call needs consent, must identify the business, and must carry an unsubscribe honored within 5 working days. From 1 July 2026 an unregistered branded sender ID shows as 'Unverified'.
Spam Act 2003 (Cth) ss 16, 17, 18; Telecommunications Amendment (SMS Sender ID Register) Act 2024 and the SMS Sender ID Register Industry Standard 2025
Required: no
No Commonwealth or state law requires a voice agent to announce it is AI. The Telemarketing Standard expressly contemplates calls made 'solely using a recorded or synthetic voice' and only relaxes the given name requirement for them (s 9(2)(a)); it still requires the business name, the client's name and purpose. The Australian Consumer Law bans misleading conduct, so an agent that claims or implies it is a human, or a named staff member, is exposed even though silence alone has never been tested in court. The government dropped its proposed mandatory AI guardrails in the National AI Plan (2 December 2025) in favor of existing technology-neutral laws and voluntary guidance. Ahpra expects health practitioners to be transparent with patients when they use AI.
mixed by state: all-party in most states, one-party in Victoria, Queensland and the NT
There is no national recording rule; each state and territory has its own surveillance or listening devices act. NSW (SDA 2007 s 7), WA (SDA 1998 s 5), SA (SDA 2016 s 4, which replaced the 1972 Act), Tasmania (Listening Devices Act 1991 s 5) and the ACT (Listening Devices Act 1992 s 4) generally require the consent of all principal parties, with narrow exceptions such as protecting lawful interests. Victoria (SDA 1999 s 6), Queensland (Invasion of Privacy Act 1971 s 43) and the NT (SDA 2007 s 11) let a party to the conversation record, but restrict publishing or communicating the recording. Secondary sources disagree on how to class SA and the ACT, so treat both as all-party. The Privacy Act separately treats an identifiable recording or transcript as personal information needing an APP 5 notice. Safe practice: announce 'this call is recorded and transcribed' before anything is captured, and offer a human or unrecorded option.
| Sector | Law or regulator | The agent must not | Safeguards | Checked |
|---|---|---|---|---|
| healthcare | Privacy Act 1988 (health service providers covered at any size; health information is sensitive), OAIC; My Health Records Act 2012 (Cth); state acts: Health Records and Information Privacy Act 2002 (NSW), Health Records Act 2001 (Vic), Health Records (Privacy and Access) Act 1997 (ACT); Ahpra and National Boards (National Law s 133 advertising, AI guidance of 22 August 2024); TGA if software diagnoses or recommends treatment | Diagnose, triage symptoms, advise on medication, imply it is a doctor or nurse, disclose a patient's details to an unverified caller, touch My Health Record without authorized access, or use patient calls to train models. Any marketing it says must not use testimonials or be misleading (s 133). | Keep the agent to bookings and admin; open with 'I am an automated assistant and cannot give medical advice'; detect emergency words and tell the caller to hang up and dial 000; verify identity before discussing appointments; keep health details out of voicemails; written contract with each AI vendor covering no training, location and breach notice. | Verified |
| financial services | Corporations Act 2001 (financial product advice needs an AFS license), National Consumer Credit Protection Act 2009, ASIC; AML/CTF Act 2006, AUSTRAC | Give personal financial advice, approve or decline credit, quote a definitive insurance cover decision, or collect passwords, one-time codes or full card numbers in open conversation. | Approved scripts only, route anything advice-like, hardship or complaints to licensed staff, the licensee signs off the use case, keep recordings and prompt versions. | Unverified |
| debt collection | Australian Consumer Law ss 18, 20 to 22, 29 and s 50 (harassment and coercion), ACCC and ASIC Debt Collection Guideline, Privacy Act APP 6 | Threaten consequences that are not legally available, impersonate a lawyer, court or human collector, disclose the debt to whoever answers, or call excessively or at unreasonable times. | Verify identity before mentioning the debt, leave neutral messages, cap contact frequency, route disputes and hardship to a human. | Unverified |
| legal | Legal Profession Uniform Law (NSW, Vic, WA) and other state legal profession acts, Australian Solicitors' Conduct Rules, state legal regulators; AML/CTF tranche 2 brings lawyers under the Privacy Act for AML work from 1 July 2026 | Give legal advice, assess a case, accept instructions, or hold itself out as a lawyer. | Open with 'automated intake assistant, not a lawyer'; collect contact details only until a conflict check; escalate urgent matters (court dates, violence, arrest) to a person immediately. | Unverified |
| real estate | State agent licensing acts (for example Property and Stock Agents Act 2002 (NSW), Estate Agents Act 1980 (Vic)), Australian Consumer Law, residential tenancy acts; real estate agents become AML/CTF reporting entities and are covered by the Privacy Act for that work from 1 July 2026 | Invent prices, availability or vendor instructions, accept offers, or reveal an applicant's details to another caller. | Live listing data only, human approval for offers and applications, route urgent repairs and safety issues to the property manager. | Secondary source |
| home services | Australian Consumer Law (consumer guarantees ss 60 to 62, misleading representations), state trade licensing and gas and electrical safety regulators; outbound promotion is telemarketing (DNCR Act and the 2017 Standard) | Quote a binding price the business has not authorized, give safety instructions on gas, electrical or structural faults, or describe unlicensed work as licensed. | Intake and booking only, approved price ranges, screen for gas leaks, fire or flooding and direct the caller to 000 or the gas or electricity emergency line, written booking confirmation. | Unverified |
Brainstorm
Raw material for your scripts, built on the surprising facts in each country's tab. Mark each one: your marks save and I can read them back.
Get this sales call wrong in the UK and the fine can hit £17.5 million.
On screen: One call, a £17.5 million fine?
Opening shot: A phone screen mid-dial, an outbound call to a UK number.
The PECR maximum went from £500,000 to £17.5 million or 4% of turnover on 5 Feb 2026. Leads with the stake.
Two energy firms got fined £550,000 for calls real people were making.
On screen: Real people, fined as robocalls
Opening shot: A call center desk with a soundboard of voice clips.
The ICO's 2025 avatar call fines: agents clicking recorded clips still counted as automated calls. A surprise that maps straight onto AI voices.
I wouldn't let a voice agent cold call a single UK business, and here's why.
On screen: Why I won't cold call UK businesses
Opening shot: A list of UK business numbers on screen.
First person take, the shape that won on the review replies piece. Automated marketing calls need consent even to businesses (PECR reg 19). Says 'voice agent' in the first 3 seconds.
The UK has no legal calling hours, and that's not the loophole it sounds like.
On screen: No calling hours in the UK?
Opening shot: A clock reading 10:40pm beside a phone.
A claim a viewer can argue with. No statutory hours, but the consent rule does the work instead.
If your agent runs from a server abroad, UK carriers might be blocking every call.
On screen: Your calls might never ring
Opening shot: A call log full of failed calls.
Since Jan 2025 Ofcom has blocked calls from abroad that show a UK landline number. Practical, and very few people know it.
Comment UK and I'll send you the checklist I'd run before switching one on.
A give. The checklist gets made when the first person asks.
Next up is the US, where one bad call can turn into a lawsuit.
A series bridge, not an ask, and it sets up episode 2's hook.
There's no cap on what one bad batch of US robocalls can cost you.
On screen: No cap on robocall damages
Opening shot: A spreadsheet of 1,000 dialed numbers.
$500 to $1,500 per call in private TCPA suits, uncapped: 1,000 calls can mean a $1.5 million claim.
A fake Biden phone call is the reason your voice agent needs consent.
On screen: Why a fake Biden call changed everything
Opening shot: A 2024 news headline about the New Hampshire robocalls.
The FCC classed AI voices as artificial voices in Feb 2024, weeks after the deepfake calls. A story hook with a famous name.
In Utah your voice agent has to admit what it is if someone asks.
On screen: Utah makes it confess
Opening shot: A phone on speaker, someone asking 'am I talking to a robot?'
Utah Code 13-75-103. Opens on a question the viewer has probably asked themselves.
Call a Florida number at 8:30pm and you've broken the law.
On screen: 8:30pm in Florida is too late
Opening shot: A map with Florida lit up and a clock.
The federal window is 8am to 9pm, but Florida, Oklahoma and Maryland stop at 8pm. Concrete and easy to check.
In Washington state, your recording has to record itself saying it's recording.
On screen: The recording has to be on the recording
Opening shot: A waveform with the recording notice highlighted.
RCW 9.73.030(3). A small oddity that opens up the all-party recording states.
Comment your state and I'll tell you whether it's an all-party recording state.
A give that gets comments, and it can be answered from this research.
Canada's next, and its rules for synthetic voices were written before anyone had a good one.
Series bridge.
Canada wrote its rules for synthetic voices years before anyone had a good one.
On screen: Canada saw this coming
Opening shot: The CRTC rule text with 'synthesized voice' highlighted.
The ADAD definition in the Unsolicited Telecommunications Rules already covers a synthesized voice message.
Call a Canadian at 6:30 on a Saturday and you're breaking the rules.
On screen: 6:30 on Saturday is too late
Opening shot: A phone showing Saturday 6:30pm.
Weekends stop at 6pm, three and a half hours earlier than weekdays (9:30pm).
Your best customer still can't get a call from your voice agent in Canada without saying yes first.
On screen: Even existing customers need a yes
Opening shot: A CRM record marked 'repeat customer'.
The existing relationship exemption gets you past the DNCL but not past the ADAD consent rule. A little long: trim to fit 3 seconds.
In Canada, calling a customer and texting them run on two different clocks.
On screen: 18 months to call, 2 years to text
Opening shot: Two timers side by side on screen.
18 months after a purchase for the call exemption, 2 years for a CASL follow-up text.
If your agent can't speak French, Quebec is going to be a problem.
On screen: Does your agent speak French?
Opening shot: A Quebec area code on an incoming call.
Law 25 plus the Charter of the French Language for consumer service. Leads with a stake every builder can picture.
Comment CANADA and I'll send the one-page version of this.
A give, made when someone asks.
Australia's next, and the number your agent calls from has to keep working for a month after it hangs up.
Series bridge using an Australian surprise.
A one-person physio clinic has stricter privacy rules than most plumbing companies.
On screen: Why the physio has stricter rules
Opening shot: A physio clinic's front desk phone ringing.
Health providers get no small business exemption from the Privacy Act; businesses under A$3 million turnover usually do. The opening shot is the business.
In Australia a sales call on a Sunday is illegal, but a survey call isn't.
On screen: Sunday sales calls: banned
Opening shot: A calendar with Sunday crossed out.
Industry Standard 2017 s 8: research calls can run 9am to 5pm on Sundays, sales calls never.
The number your voice agent calls from has to work for 30 days after the call.
On screen: Your number has to keep working
Opening shot: A missed call notification, then a callback.
Standard s 14(3). A practical trap for anyone rotating numbers.
TAB was fined $2.7 million, partly for calls that never said who was calling.
On screen: $2.7 million for skipping one line
Opening shot: The ACMA headline on screen.
ACMA, July 2026. Names a public enforcement case, not a client.
Australian law already has a rule for robot voices, and it lets them skip one thing.
On screen: The one thing robot voices can skip
Opening shot: The Standard's text with s 9(2)(a) highlighted.
A call made solely with a synthetic voice doesn't have to give a first name, but still has to name the business and why it's calling.
Comment your state and I'll tell you whether you need everyone's consent to record.
A give. Recording consent differs by state: all-party in NSW, WA, SA, Tas and the ACT.
Last one's all four side by side, and the strictest one might surprise you.
Series bridge into episode 5.
The same call at 8:30pm is legal in Canada and illegal in Australia.
On screen: Same call, same time, different law
Opening shot: Four flags and a clock at 8:30pm.
A weekday sales call: Canada runs to 9:30pm, Australia stops at 8pm. Concrete and visual.
Of these four countries, only one bans sales calls on a Sunday.
On screen: Which country bans Sunday sales calls?
Opening shot: The four flags, then a calendar on Sunday.
A spot-it question about the thing in shot. Australia bans them all day; the UK has no statutory hours, the US allows 8am to 9pm and Canada 10am to 6pm on weekends.
I'd launch an outbound voice agent in the US last, and the reason isn't the fines.
On screen: Why I'd launch in the US last
Opening shot: The comparison table.
First person take. The reason is uncapped private lawsuits plus a state patchwork, not the regulator's fine.
None of these countries makes your agent say it's AI, except three US states.
On screen: Do you have to say it's AI?
Opening shot: The comparison table with the AI disclosure row lit.
California, Utah and Maine (Maine is secondary only). Says 'AI' in the line, near the end.
Comment RULES and I'll send you the whole table.
A give: the comparison table as an image or a one-pager, made when someone asks.
Save this before you switch on your first outbound agent.
A save prompt, no destination. The lightest option.
Sources
Twenty Perplexity (sonar-pro) answers, five per country, asked 29 Oct 2026, then each country checked against regulator and legislation sites. The raw answers are in the repo under docs/marketing/voice-agent-rules/research.