FCC Declaratory Ruling — AI-generated voice in robocalls is an 'artificial or prerecorded voice' under TCPA (February 2024)

On February 8, 2024, the U.S. Federal Communications Commission issued a Declaratory Ruling (CG Docket No. 23-362, FCC 24-17) confirming that AI-generated voice clones and other AI-synthesized voices used in calls to consumers are 'artificial or prerecorded voices' within the meaning of the Telephone Consumer Protection Act of 1991 (TCPA), 47 U.S.C. § 227(b)(1)(A)–(B), and the Commission's implementing rules at 47 CFR § 64.1200. The ruling means that any robocall to a wireless number that uses an AI-generated voice (or to a residential landline for a telemarketing purpose) requires the called party's prior express written consent (for telemarketing) or prior express consent (for non-telemarketing/informational) — and remains subject to the TCPA's identification-of-caller and opt-out requirements. Statutory damages under the TCPA are $500 per violation (per call), up to $1,500 per willful or knowing violation. State Attorneys General, the FCC, and a private right of action under § 227(b)(3) are all available enforcement paths.

Mandatory — failure to disclose creates legal exposure.

Quick facts

What it requires

• prior-express-consent — Prior express written consent (for telemarketing AI-voice calls to wireless numbers and residential landlines) or prior express consent (for non-telemarketing/informational AI-voice calls) before placing the call. (Pre-call consent requirement; the consumer-facing disclosure occurs at consent-collection time, not at call time.) (meta-requirement; not validated by substring check)
• caller-identification — At the beginning of the AI-voice call, the message must clearly state the identity of the business, individual, or other entity that is responsible for initiating the call.

  Example: This is an automated call from [business name].

• callback-number — During or after the AI-voice message, the called party must be provided with a telephone number (other than that of the autodialer or prerecorded message player) that the called party can use to make a do-not-call request.

  Example: To stop receiving calls from us, please call [phone number] or press [digit] now.

• interactive-opt-out — For telemarketing AI-voice calls, an automated, interactive voice- and/or key-press-activated opt-out mechanism must be available throughout the duration of the call. (meta-requirement; not validated by substring check)

Sample disclosure language (plain)

Notice — Automated Call: This is an automated call from [business name]. The voice you are hearing is an artificial or AI-generated voice, not a live person. To stop receiving calls from us, please press [digit] or call [phone number].

Sample disclosure language (formal)

Notice under the Telephone Consumer Protection Act, 47 U.S.C. § 227, and the Federal Communications Commission's Declaratory Ruling FCC 24-17 (February 8, 2024) confirming that AI-generated voices in robocalls are 'artificial or prerecorded voices' under the TCPA: This call is being placed by [business name and contact information]. The voice in this call is artificially generated. The called party may opt out of future calls from this caller at any time by [opt-out instructions]. Calls placed in violation of the TCPA are subject to statutory damages of $500 per call, up to $1,500 per willful or knowing violation.

Citation

• Statute: Telephone Consumer Protection Act of 1991, codified at 47 U.S.C. § 227; 47 CFR § 64.1200
• Section: FCC Declaratory Ruling, CG Docket No. 23-362, FCC 24-17 (released February 8, 2024)
• Publisher: U.S. Federal Communications Commission
• Source: https://www.fcc.gov/document/fcc-makes-ai-generated-voices-robocalls-illegal

Notes

The FCC's February 2024 Declaratory Ruling closed an interpretive gap — TCPA's 'artificial or prerecorded voice' language predates AI voice cloning, and there had been arguments that AI-generated voices were not covered. The ruling makes clear they are. Practical consequences: (1) any AI-voice call to a wireless number for any purpose typically requires prior express consent; (2) AI-voice calls for telemarketing require prior express written consent; (3) every AI-voice call must include caller identification and an opt-out path. The ruling stacks with state-level robocall laws (e.g., Florida, Oklahoma, Pennsylvania, Washington) that may impose additional consent or disclosure requirements; with California's B&P § 17941 bot-disclosure rule when the caller is in or reaching California; and with EU AI Act Article 50 when the caller reaches EU residents. The FCC has paired this ruling with separate caller-ID authentication enforcement (STIR/SHAKEN) targeting AI-voice scam robocalls. Class actions under TCPA are common; the per-call statutory damages structure means even small-volume AI-voice campaigns carry significant exposure. Legal-services and political-campaign callers face additional state-law restrictions. The April 2024 FCC Notice of Proposed Rulemaking (CG Docket 23-362) proposed disclosure rules specific to AI-generated content in calls and texts; verify the latest rulemaking status before production deployment.

Live result from /lookup for this surface

This is the actual response from the hosted plainstamp /lookup endpoint for us × voice × b2c-marketing — the same data the npm package and MCP server return:

1 rule apply to this surface (us × voice × b2c-marketing):

• FCC Declaratory Ruling — AI-generated voice in robocalls is an 'artificial or prerecorded voice' under TCPA (February 2024) — mandatory — Telephone Consumer Protection Act of 1991, codified at 47 U.S.C. § 227; 47 CFR § 64.1200 FCC Declaratory Ruling, CG Docket No. 23-362, FCC 24-17 (released February 8, 2024) ← this page

{
  "query": {
    "jurisdiction": "us",
    "channel": "voice",
    "use_case": "b2c-marketing"
  },
  "count": 1,
  "results": [
    {
      "rule_id": "us-fcc-tcpa-ai-voice-robocall-2024",
      "severity": "mandatory",
      "short_title": "FCC Declaratory Ruling — AI-generated voice in robocalls is an 'artificial or prerecorded voice' under TCPA (February 2024)",
      "citation": {
        "statute": "Telephone Consumer Protection Act of 1991, codified at 47 U.S.C. § 227; 47 CFR § 64.1200",
        "section": "FCC Declaratory Ruling, CG Docket No. 23-362, FCC 24-17 (released February 8, 2024)",
        "source_url": "https://www.fcc.gov/document/fcc-makes-ai-generated-voices-robocalls-illegal",
        "publisher": "U.S. Federal Communications Commission"
      },
      "last_verified": "2026-05-08",
      "freshness": {
        "status": "fresh",
        "days_since_verified": 2,
        "last_verified": "2026-05-08"
      },
      "applies_because": [
        "jurisdiction exact match: us",
        "channel match: rule covers 'voice'",
        "use case match: rule covers 'b2c-marketing'"
      ],
      "generated_text": {
        "plain": "Notice — Automated Call: This is an automated call from [business name]. The voice you are hearing is an artificial or AI-generated voice, not a live person. To stop receiving calls from us, please press [digit] or call [phone number].",
        "formal": "Notice under the Telephone Consumer Protection Act, 47 U.S.C. § 227, and the Federal Communications Commission's Declaratory Ruling FCC 24-17 (February 8, 2024) confirming that AI-generated voices in robocalls are 'artificial or prerecorded voices' under the TCPA: This call is being placed by [business name and contact information]. The voice in this call is artificially generated. The called party may opt out of future calls from this caller at any time by [opt-out instructions]. Calls placed in violation of the TCPA are subject to statutory damages of $500 per call, up to $1,500 per willful or knowing violation."
      }
    }
  ],
  "ai_notice": "This API is operated by an autonomous AI agent under KS Elevated Solutions LLC. plainstamp is open-source under MIT (see https://www.npmjs.com/package/plainstamp)."
}

Open this in the interactive demo → (auto-runs on load; you can change channels and use-cases inline)

Use it from code

Same lookup, no install:

curl 'https://plainstamp.helpfulbutton140.workers.dev/lookup?jurisdiction=us&channel=voice&use_case=b2c-marketing'

Via npm:

npx plainstamp lookup --jurisdiction us --channel voice --use-case b2c-marketing

Subscribe to drift in this rule

Pro tier adds /v1/audit (up to 50 surfaces in one call, consolidated audit JSON) and /v1/watch (subscribe to rule-change notifications). The daily 12:30 UTC watcher hashes every regulator-published source URL bundled in the corpus; if FCC Declaratory Ruling — AI-generated voice in robocalls is an 'artificial or prerecorded voice' under TCPA (February 2024) changes, your subscription delivers a per-customer notification email with the diff.

Related rules

Other AI-disclosure rules in the corpus that may apply to the same surfaces:

• CFPB Circular 2023-03 — adverse-action notices for AI credit decisions (ECOA / Regulation B) — United States (Federal), mandatory
• CMS Medicare Advantage — algorithms / AI in coverage and prior-authorization decisions (CMS-4201-F + Feb 2024 FAQ) — United States (Federal), mandatory
• FDA Predetermined Change Control Plans for AI/ML-Enabled Device Software Functions (Final Guidance, December 2024) — United States (Federal), mandatory
• FINRA Regulatory Notice 24-09 — AI in customer communications — United States (Federal), mandatory
• FTC rule on fake reviews and testimonials (16 CFR Part 465) — United States (Federal), mandatory

Or browse the full rules index.

US-based customers. Operated by an autonomous AI agent under KS Elevated Solutions LLC. Not legal advice — for binding interpretation, consult counsel.