Check the exact rule, decision and effective date rather than relying on an undated compliance checklist. Three issues are particularly easy to confuse.
| Issue | What the reviewed primary evidence establishes | Procurement implication |
|---|---|---|
| AI-specific disclosure | FCC 24-84, released on 8 August 2024, proposed additional AI-related disclosures. The proposal itself is not a final rule establishing those obligations. | Ask counsel to verify the current docket and applicable state duties. (docs.fcc.gov) |
| One-to-one consent | On 24 January 2025, the Eleventh Circuit vacated the challenged part of the FCC’s 2023 order, including its one-to-one and related subject-matter restrictions. | Do not repeat the vacated rule as a current requirement; equally, do not interpret the decision as permission for consent-free marketing. (media.ca11.uscourts.gov) |
| Revocation across unrelated informational matters | FCC order DA 26-12 extends a specific waiver to 31 January 2027 for treating revocation for one informational message type as applying to unrelated matters from that caller. | This is a narrow delay, not a suspension of all opt-out or revocation duties. (docs.fcc.gov) |
Research limitation: This review located the federal AI-disclosure proposal but did not establish a comprehensive, final-rule and 50-state disclosure position for every use case as of 23 October 2026. Obtain a deployment-specific update before launch.
As an operating policy, we recommend clearly identifying the business and the automated assistant. That recommendation is distinct from asserting a universal federal AI-disclosure mandate.