AI outbound voice compliance checklist (2026)
An AI voice agent that dials outbound answers to two rulebooks on every call: the TCPA side (the federal 8 AM to 9 PM recipient-local window, state overlays, DNC, and consent) and the AI-disclosure side (the EU, California, Utah, and Korea notice regimes). This page is the configuration pass that joins the two. Use it with the companion reads: the companion blog checklist for the procurement framing, and the reference pages linked below for each control. Nothing here is legal advice; confirm which rules bind your traffic with qualified counsel.Every control on this page is tenant-owned: you set it, and it defaults
open if you set nothing. The single exception is the federal dialing
window guard, which is platform-level and accepts no tenant toggle —
see control 1.
1. Verify the federal dialing-window guard is platform-level
The federal 8 AM to 9 PM recipient-local window (47 C.F.R. § 64.1200(c)(1)) is enforced platform-wide on Orbit and fails closed: if a recipient’s timezone cannot be resolved, the dial is blocked. You cannot relax it, and no vendor should let you. Treat this as a vendor qualification question, not a configuration step.2. Enable the state overlays you dial into
Seven states (FL, OK, MS, LA, AL, AR, WV) close earlier than the federal floor or ban days outright, and federal law does not preempt stricter state law. Orbit resolves the recipient’s state from the area code and intersects the overlay with the federal window per send; a send outside the intersected window defers with its next allowed moment shown to the operator. State overlays are tenant-configurable and default open, so enabling the ones that bind your traffic is your act. Read state calling windows for the statute table and deferral mechanics, and the quiet-hours vs state-windows post for worked examples.3. Set your quiet hours
Configure your stricter layer (brand-safe hours, weekend policy, campaign blackout windows) under Settings → Campaigns, quiet hours start and end. Leave it open and only the legal floor applies. The most restrictive of federal window, state overlay, and your quiet hours wins per send. See quiet-hours FAQ.4. Set the AI-disclosure toggles for the regimes you reach
Under Settings → Compliance → AI Disclosure (orGET/PUT /api/v1/compliance/ai-disclosure), the master switch activates
the notice and one toggle per regime marks which of the four regimes
(EU AI Act, Korea AI Basic Act, California SB 243 minor-contact reminder,
Utah AI Policy Act) your workspace applies. The notice text is yours to
write, and every AI voice and chat agent in the workspace reads the same
row. Configure it before any agent dials; see
AI disclosure settings and the
toggle walkthrough.
5. Enable DNC and the known-litigator scrub
Federal DNC and internal do-not-call handling run through your suppression configuration under Settings → Message Suppression; see DNC scrub. The known-litigator scrub gates sends against roughly 36 months of TCPA lawsuit history, refreshed daily. It is a tenant opt-in, off by default; US outbound operators should enable it per organization. Its verification surface and behavior are described in known-litigator scrub and the companion post.6. Capture consent with an auditable record
Prior express written consent for autodialed or prerecorded-voice telemarketing remains the federal baseline. Configure capture where the consent actually happens, keep the receipt (source, timestamp, scope) in the audit trail, and set a refuse-by-default posture for marketing sends to contacts with no recorded consent. See consent management and consent receipt integrity.7. Read the pre-carrier signals weekly
The compliance health score rolls the four signals carriers act on (consent coverage, opt-out velocity, STOP-reply rate, carrier rejections) into a 0 to 100 read per organization, sending number, and campaign. It never blocks a send; put it on a weekly review so a degrading campaign is your discovery, not a carrier’s. See the pre-carrier read.8. Run a 30-60-90 cadence
- First 30 days: enable controls 2 through 6 for the states and regimes you dial.
- 30 to 60 days: backfill consent records and true-up existing contacts; attach an owner to the weekly health-score review.
- 60 to 90 days: export the audit evidence your counsel wants (window evaluations, disclosure settings in effect, consent receipts) and set the quarterly true-up cadence; watch the state-overlay calendar so a newly enacted overlay lands as a configuration change.