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25. Which recent US calling-rule changes should buyers check before launching?

Trace Margin research deskSection 01Page 25 of 33Last updated

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.