Outbound AI Voice Call Compliance Requirements
Effective Date: April 1, 2026 | Last Updated: April 1, 2026
This AI Calling Policy governs the use of the outbound AI voice calling functionality of the MyLife-Simplified Platform (the "Services"), under which an artificial-intelligence agent places telephone calls to recipients on a Customer's behalf, holds a live conversation, and may transfer the call to a human representative. This policy supplements and is incorporated into the MyLife-Simplified Platform Terms of Service, the Acceptable Use Policy, and the Messaging Policy.
AI voice calls are regulated more strictly than text messages. Under the FCC's February 2024 Declaratory Ruling, a call using an AI-generated or cloned voice is an "artificial or prerecorded voice" within the meaning of the Telephone Consumer Protection Act ("TCPA"), 47 U.S.C. § 227. Every AI call placed through the Services is therefore subject to the TCPA's artificial and prerecorded voice rules, regardless of whether the recipient perceives the call as automated.
This policy is a compliance resource and does not constitute legal advice. Statutory damages under the TCPA run from $500 to $1,500 per call, and are not capped. You should consult qualified counsel regarding your specific obligations before running any AI calling campaign.
Before placing any AI call to a residential or wireless number for a marketing or telemarketing purpose, you must obtain prior express written consent from the recipient, satisfying the requirements of 47 C.F.R. § 64.1200(f)(9). The consent disclosure must state that the recipient may receive calls delivered by an artificial or prerecorded voice, must identify the specific business that will be calling, must include the telephone number to be called, and must state that consent is not a condition of purchase.
Non-marketing AI calls placed to a wireless number — for example, an appointment confirmation or a service notification — require at minimum prior express consent. Providing a telephone number in the course of a transaction generally constitutes prior express consent for calls closely related to that transaction. It does not constitute consent for marketing.
An established business relationship does not, on its own, permit an AI call for a marketing purpose to a residential or wireless number. It affects the application of certain do-not-call registry provisions but does not substitute for the consent required under the artificial and prerecorded voice rules.
You are responsible for retaining evidence of consent for each number you call, for no less than five years, and for producing it in the event of a complaint or claim. MyLife-Simplified Platform records the consent status carried on each contact record and refuses to dial any contact marked as opted out, but MyLife-Simplified Platform does not collect, validate, or warehouse your underlying consent documentation on your behalf.
Under 47 C.F.R. § 64.1200(b), a call delivered by an artificial or prerecorded voice must state, at the beginning of the message, the identity of the business or entity responsible for initiating the call, and must state the telephone number of that business during or after the message. The Services enforce this by requiring a business name on every voice campaign and by composing the agent's opening line so that the identification is always present.
A growing number of jurisdictions require affirmative disclosure that a caller is an artificial intelligence rather than a person, and require that a recipient be able to reach a human being on request. The Services disclose that the caller is an AI assistant in the opening line by default. Disabling that disclosure is available only as a configuration option for use cases where a Customer has determined, on advice of counsel, that no disclosure obligation applies. Disabling it does not shift responsibility to MyLife-Simplified Platform.
You may not configure an AI agent to claim to be a natural person, to deny being an artificial intelligence when asked, to impersonate a government agency, or to impersonate any business other than the Customer or a business the Customer is authorized to represent. You may not use a voice that clones or imitates the voice of a real identifiable individual without that individual's written authorization.
AI calls placed through the Services are recorded and transcribed so that outcomes can be reported and audited. Recording consent is governed by state law. Eleven states — including California, Florida, Illinois, Massachusetts, Pennsylvania, and Washington — require the consent of all parties to the recording of a telephone call. Because an outbound campaign frequently reaches recipients in multiple states, the Services state that the call is recorded as part of the opening line by default, and you should keep that disclosure enabled for any campaign that may reach an all-party-consent jurisdiction.
Recordings, transcripts, and AI-generated call summaries constitute personal information about the recipient. You are responsible for handling them in accordance with our Privacy Policy and with any applicable state privacy statute, including honoring access and deletion requests.
Under 47 C.F.R. § 64.1200(c)(1), a telemarketing call may not be placed before 8:00 AM or after 9:00 PM in the recipient's local time. The Services enforce this outer bound and it cannot be configured away: a campaign window is always intersected with the federal window, and eligibility is evaluated separately for each recipient in that recipient's own time zone, taken from the contact record where available and otherwise inferred from the area code. Where an area code spans more than one time zone, the permitted window is narrowed by one hour at each end so that the call remains inside the federal bound under either interpretation.
Numerous states impose narrower windows, and several restrict calling on Sundays or legal holidays. You are responsible for identifying and complying with the most restrictive requirement applicable to the recipients you are calling, and for configuring the campaign window accordingly.
A request not to be called again must be honored promptly and must be recorded within a reasonable time, not to exceed thirty days. When an AI agent is told during a call that the recipient does not wish to be contacted again, the Services record that request immediately — while the call is still in progress — to the Customer's internal do-not-call list, and additionally re-check the post-call analysis as a second safeguard. A suppressed number is thereafter excluded from every campaign on that account, across voice, SMS, and email.
You are required to maintain an internal do-not-call list and to honor entries on it for a minimum of five years. The Services provide that list, retain entries indefinitely, and enforce it as an absolute bar to dialing that cannot be overridden by a campaign setting. Removal of an entry is restricted to administrators, requires explicit confirmation, and is logged. You should not remove an entry unless you hold documented consent to contact that person again.
The Services do not screen numbers against the National Do-Not-Call Registry or against state registries. Enforcement of the internal list described above is not a substitute for registry scrubbing. Where you are placing telemarketing calls to numbers for which you do not hold prior express written consent and with which you have no established business relationship, you must obtain registry access or engage a compliant scrubbing provider and screen your list before launching a campaign. Failure to do so is a violation of this policy and of the Acceptable Use Policy.
Under the Truth in Caller ID Act, 47 U.S.C. § 227(e), you may not transmit misleading or inaccurate caller identification information with the intent to defraud, cause harm, or wrongfully obtain anything of value. The outbound number configured for a campaign must be a number that the Customer or the business on whose behalf the call is placed lawfully controls, and must be capable of receiving return calls. You may not use a number you do not control, a spoofed number, or a rotating pool of numbers intended to evade call-blocking or analytics.
Where a campaign is configured to transfer calls to a live representative, the transfer destination must be staffed during the campaign's calling window and must be able to identify the business on whose behalf the original call was placed. Recording and disclosure obligations continue to apply after a transfer. Transferring a call does not cure a defect in the consent, disclosure, or calling-hours basis of the original call.
You may not use the AI calling functionality of the Services to:
MyLife-Simplified Platform provides tooling that enforces the technical controls described in this policy — per-recipient calling-hours evaluation, opt-out and suppression enforcement, mandatory caller identification, disclosure composition, in-call do-not-call capture, attempt limits, and a complete auditable record of every call. Those controls reduce risk; they do not establish a lawful basis for a call.
As between the parties, the Customer is the initiator of every call placed through its account and is solely responsible for the lawfulness of that call, including obtaining and retaining consent, performing registry scrubbing, determining which state-law requirements apply, and honoring recipient requests. The Customer's indemnification obligations under the Terms of Service apply to any claim arising from calls placed through its account.
MyLife-Simplified Platform may suspend or terminate access to AI calling functionality, with or without notice, where it has a reasonable basis to believe that a Customer is operating in violation of this policy, where complaint volume or carrier signals indicate a compliance problem, or where continued operation presents legal or reputational risk to MyLife-Simplified Platform or to other Customers.
Questions about this policy, and reports of suspected violations, may be directed to MyLife-Simplified Platform through the contact information provided in the Terms of Service.