AI phone disclosure: telling callers it's an AI

This article is general information, not legal advice. Rules differ by country and change, and your situation may be different. If it matters, ask a lawyer.

What does the EU AI Act say?

Article 50 of the EU's AI Act (Regulation (EU) 2024/1689) sets transparency obligations for certain AI systems. The part relevant to phone answering is Article 50(1): providers must design AI systems that interact directly with people so that those people are informed they are interacting with an AI system. The exception is where that is obvious from the point of view of a reasonably well-informed, observant and circumspect person, given the circumstances and context of use (EU AI Act Service Desk, Article 50).

Article 50(5) adds that the information must be given in a clear and distinguishable way, at the latest at the time of the first interaction.

The general date of application is 2 August 2026, set in Article 113. That date has now passed.

Two practical points follow:

• A natural-sounding voice on an AI phone line is exactly the kind of case where "it's obvious" is hard to rely on. A caller cannot see anything. Saying so up front removes the doubt.
• The obligation is described in terms of providers and, for some parts of Article 50, deployers. If you are a business using an AI phone or AI receptionist in the EU, you are likely a deployer. Check with your adviser which parts apply to you.

What did the FCC rule in 2024?

On 8 February 2024 the US Federal Communications Commission announced a unanimous declaratory ruling that calls made with AI-generated voices are "artificial" under the Telephone Consumer Protection Act (FCC announcement). The ruling took effect immediately. It means the TCPA's existing restrictions on artificial or prerecorded voices apply to AI-generated voices, including voice cloning (FCC, "FCC Makes AI-Generated Voices in Robocalls Illegal").

In practice, the FCC said telemarketers already need prior express written consent before robocalling, and the ruling applies that to calls using AI-generated voices.

What this means for an AI phone (or AI receptionist):

• Inbound calls, where a customer rings you, are not the target of this ruling. The ruling is about calls placed to people.
• Outbound calls by an AI voice are where the risk is. Placing them without the right consent exposes a business to TCPA liability.
• Even for inbound calls, telling the caller it is an AI keeps you in line with where regulators are heading.

What about the UK, Canada, Australia and New Zealand?

Rules on call recording, consent and automated calling differ by country, and each has its own regulator. We do not summarise them here, because a summary that is slightly out of date is worse than none. If you operate in one of those countries, check with a local adviser, and see our trust page for how we handle calls.

What should the disclosure on an AI phone line say?

Keep it short, clear and at the start. A good disclosure:

1. Comes first. Before the caller has said anything important.
2. Names the business. "Thanks for calling Harbour Plumbing."
3. Says it is an AI. "I'm the AI assistant."
4. Says what it can do. "I can take a message, book you in, or put you through."

For example: "Thanks for calling Harbour Plumbing. I'm the AI assistant. I can book you in, take a message or put you through to someone. How can I help?"

Avoid trying to make the AI sound human to the point of confusion. Callers who feel tricked hang up, and that is a worse outcome than any rule.

How does a prepaid AI phone plan handle it?

• The AI says it is an AI at the start of every call.
• The wording is set per country, so a caller in New Zealand hears wording suited to New Zealand, and a caller in the United States hears wording suited to the United States.
• Every call is recorded and transcribed in your dashboard, so you can see exactly what was said to each caller.

Local numbers for your AI phone line are available in New Zealand, Australia, the United States, the United Kingdom and Canada. See the numbers page. The trust page has more about how we handle this.

Do I need to do anything myself?

A few things are worth doing:

1. Keep the disclosure on. Do not remove it from your greeting.
2. Tell your callers on your website or privacy notice that calls are answered by an AI and may be recorded and transcribed.
3. Keep recordings no longer than you need.
4. Check local rules if you record calls, since recording-consent laws differ by place.
5. If you ever make AI calls out, get proper consent first and ask a lawyer.

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