Compliance Guide (Not Legal Advice)
Nearshore & offshore call-center teams that protect your brand — PCI DSS and HIPAA-compliant, and ready to scale with your volume.
No federal law requires a business to tell a caller that they are talking to an AI. A growing number of states do, or will, and their rules differ in who is covered, what counts as a disclosure, and when disclosure is required. This page summarizes the five states most relevant to a business considering an AI front desk, with primary sources listed at the end. It is not legal advice; it reflects the position verified on October 12, 2026, and effective dates should be confirmed with counsel.
The Five States at a Glance
| State | Rule | Who it applies to | Status (verify with counsel) |
| Maine | No AI chatbot or similar technology in trade and commerce in a manner that may mislead a reasonable consumer into thinking they are engaging with a human, unless clearly and conspicuously notified; covers textual or aural communications 1 | Businesses generally | In effect |
| Utah | Disclose on request when a consumer asks whether they are interacting with AI; up-front disclosure for regulated occupations 2 | Businesses generally; stricter for regulated occupations | In effect |
| Colorado | HB 26-1263: operators of conversational AI services must disclose that the service is AI, with exclusions for certain transactional and narrow-purpose tools 3 | Operators of conversational AI, subject to exclusions | Signed May 29, 2026; effective January 1, 2027 |
| Texas | Responsible AI Governance Act disclosure duties apply to health care providers and government agencies 4 | Health care providers and government agencies | Effective January 1, 2026 |
| California | AB 1609: no presenting a chatbot as human; disclosure in the medium of interaction; good-faith effort to connect a requesting customer with an agent within 15 minutes or offer an appointment within one business day 5 | Businesses with more than USD 500 million national gross annual revenue | Signed September 28, 2026; operative date to be confirmed with counsel |
Maine
Maine’s statute, 10 M.R.S. §1500-DD, is the broadest of the five for a voice AI. It prohibits using an AI chatbot or other computer technology in trade and commerce in a manner that may mislead a reasonable consumer into believing they are engaging with a human, unless the consumer is clearly and conspicuously notified that they are not interacting with a human. Its definition expressly covers “textual or aural communications,” so a voice agent is within scope, and violations are treated under Maine’s Unfair Trade Practices Act 1. A clear statement at the start of the call that the caller is speaking with an AI assistant is the straightforward way to comply.
Utah
Utah’s Artificial Intelligence Policy Act (Utah Code Title 13, Chapter 77) takes a lighter approach for most businesses: if a consumer asks whether they are interacting with AI, the business must disclose it clearly. For regulated occupations, such as licensed health and certain professional services, disclosure must be made up front, before the interaction 2. A business that discloses at the start of every call satisfies both tiers without needing to track which caller asked.
Colorado
Colorado’s position changed substantially in 2026. Its comprehensive AI law, SB 24-205, was stayed by a federal court on April 27, 2026, and on May 14, 2026 the state enacted SB 26-189, effective January 1, 2027, which replaced it with a narrower framework that does not impose a general duty to disclose AI interactions 6. Separately, HB 26-1263, signed May 29, 2026 and also effective January 1, 2027, requires operators of conversational AI services to disclose that the service is AI, with exclusions that law-firm analyses describe as covering certain transactional and narrow-purpose tools 3. Whether an AI front desk falls within the exclusions is a question for counsel; disclosing at the start of every call makes the question moot.
Texas
The Texas Responsible AI Governance Act took effect January 1, 2026. Its duties to disclose AI interactions apply to health care providers and government agencies rather than to businesses generally 4. A Texas dental or medical practice using an AI front desk should treat the disclosure duty as applying to it; a Texas HVAC company is outside this particular rule but, in Redial’s view, should disclose anyway.
California
AB 1609, signed September 28, 2026, is the most detailed and the most narrowly targeted. It applies only to businesses with more than USD 500 million in national gross annual revenue. For those businesses it prohibits presenting a chatbot as a human, requires disclosure in the medium in which the interaction takes place, and requires a good-faith effort to connect a customer who asks for a person with an agent within 15 minutes or to offer an appointment within one business day; it also limits hold times, exempts hospitals, PUC-regulated entities, consumer reporting agencies, business-only lines, and email, web, and voicemail channels, and provides civil penalties of up to USD 5,000 and USD 10,000 with no private right of action 5 7. Almost every growing business is below the threshold. The law matters anyway: it defines the service standard large companies must meet, and customers will expect smaller companies to meet it too.
New Jersey and Other States
Some vendor summaries list New Jersey among states with AI customer service disclosure laws. Redial could not verify an enacted New Jersey statute of that kind as of October 12, 2026 and has not included it. States introduce and amend AI bills continuously; this page will be updated at each review, and counsel should confirm the position in each state where your callers are located.
The Greeting That Satisfies All Five
Every rule above is satisfied, or made irrelevant, by the same design: at the start of every call, the AI identifies itself as an AI assistant, and a person is reachable on request. That is also what callers want: 85% say it should be clearly indicated when they are interacting with AI (AnswerConnect/OnePoll, 6,000 adults, 2026, vendor-commissioned) 8.
How Redial Fits
The AI front desk Redial is previewing, IzzyOps (working name), is designed to disclose that it is an AI at the start of every call regardless of the caller’s state, and to hand off to a person on request with the conversation attached. Redial describes its programs as aligned with applicable state disclosure laws and documents the basis for that statement; it does not describe any platform as “certified.” Disclosure compliance is scored on every call as one of the nine pilot measures.
Frequently Asked Questions
Which states require businesses to disclose AI on phone calls?
Maine requires clear and conspicuous notice for AI that could mislead consumers, including by voice 1; Utah requires disclosure on request and up front for regulated occupations 2; Colorado’s HB 26-1263 requires conversational AI disclosure from January 1, 2027, with exclusions 3; Texas covers health care providers and government agencies 4; California’s AB 1609 covers businesses above USD 500 million in revenue 5. Confirm with counsel.
Does California’s AB 1609 apply to my small business?
Not directly, if your national gross annual revenue is USD 500 million or less 5. Its service standard (disclose AI, connect a requesting customer with a person promptly) is the standard customers will come to expect regardless.
Does Colorado require AI disclosure?
From January 1, 2027, HB 26-1263 requires operators of conversational AI services to disclose that the service is AI, subject to exclusions counsel should confirm 3 .Colorado’s broader AI law was stayed and replaced with a narrower framework in 2026 6.
What should the AI say at the start of a call?
A short statement that the caller is speaking with an AI assistant for your business, that the call is recorded, and that they can ask for a person at any time. Your counsel should approve the exact wording.
Related Pages
- AI on the Phone: A Plain-English Compliance Guide for Growing Businesses
- Does the TCPA Apply to Inbound AI Answering?
- Recording Consent When an AI Answers the Phone
- HIPAA and PCI DSS When AI Answers the Phone
- Why Customers Still Want a Person: What the 2025 and 2026 Surveys Show
References
- Maine Revised Statutes, 10 M.R.S. §1500-DD — Prohibits using an AI chatbot or other computer technology in trade and commerce in a manner that may mislead a reasonable consumer into believing they are engaging with a human unless clearly and conspicuously notified; expressly covers textual or aural communications.
- Utah Code Title 13, Chapter 77, Artificial Intelligence Policy Act — Requires disclosure when a consumer asks whether they are interacting with AI, and up-front disclosure for regulated occupations.
- Colorado General Assembly, HB26-1263 (signed May 29, 2026; effective January 1, 2027) — Requires operators of conversational AI services to disclose that the service is AI; law-firm analyses report exclusions for transactional and narrow-purpose tools that counsel should confirm.
- Covington, Global Policy Watch, Texas enacts AI consumer protection law (July 2025) — Summary of the Texas Responsible AI Governance Act, effective January 1, 2026, whose AI-interaction disclosure duties apply to health care providers and government agencies rather than businesses generally.
- California AB 1609, enrolled text (signed September 28, 2026) — Applies to businesses with more than USD 500 million in national gross annual revenue; bars presenting a chatbot as human, requires disclosure in the medium of interaction, and requires a good-faith effort to connect a requesting customer with an agent within 15 minutes or offer an appointment within one business day; civil penalties up to USD 5,000 and USD 10,000, no private right of action.
- McDermott Will & Emery, Colorado AI law in flux (2026) — Analysis of the April 27, 2026 stay of SB 24-205 and the May 14, 2026 signing of SB 26-189, effective January 1, 2027, which replaced it with a narrower framework and no general duty to disclose AI interactions.
- Office of the Governor of California, AB 1609 signing announcement (September 28, 2026) — Announcement of the signing of AB 1609 among consumer-protection measures.
- AnswerConnect, AI customer experience statistics (OnePoll, May 2026) — Vendor-commissioned OnePoll survey of 6,000 adults in the US, UK, and Canada: 85% would rather speak to a real person, 57% would trust a business less if it relied mainly on AI, 85% want it clearly indicated when they are interacting with AI, and 31% would hang up if connected to AI.
Hear a Greeting Built for Every State
Book a demo of IzzyOps (working name), the AI front desk Redial is previewing, and hear the disclosure at the start of a sample call, then a caller asking for a person and getting one with the conversation already in hand. Commercial availability is planned for late 2026 to early 2027.