Cold Calling Laws by Country for AI Voice Agents

Cold calling laws decide whether you may call a person at all, what consent you need when the voice is automated or synthetic, which hours are allowed, and what the caller must say. Most of these rules were written for recorded-message robocalls. The US FCC has said its rules cover AI-generated voices, and other regulators define automated calls broadly enough that they may cover an AI voice agent too. Plan each country's rollout as if the agent counts as an automated caller unless local counsel tells you otherwise.

This guide covers the United States, Canada, the United Kingdom, the European Union, Australia, India and Brazil, as of October 2026. It is not legal advice. It summarizes primary sources for each market, and rules in several of them changed in 2025 and 2026, so confirm the current position before you launch.

How do the major markets compare?

The table gives the short version for marketing calls. The sections that follow add calling hours, disclosures and the sources.

• United States: Automated or AI marketing calls: Prior express written consent; FCC says AI voices count as artificial. Do-not-call or opt-out list: National Do Not Call Registry.
• Canada: Automated or AI marketing calls: Express consent for calls with a pre-recorded or synthesized voice. Do-not-call or opt-out list: National DNCL, copy no more than 31 days old.
• United Kingdom: Automated or AI marketing calls: Prior consent for automated calls (PECR reg. 19). Do-not-call or opt-out list: TPS and CTPS screening for live calls.
• European Union: Automated or AI marketing calls: Prior consent for automatic calling machines. Do-not-call or opt-out list: Opt-in or opt-out, set by each member state.
• Australia: Automated or AI marketing calls: Industry standard: hours, caller ID, end call on request. Do-not-call or opt-out list: Do Not Call Register.
• India: Automated or AI marketing calls: Promotional calls only to non-blocked or consenting subscribers. Do-not-call or opt-out list: TRAI preference and consent registers.
• Brazil: Automated or AI marketing calls: 0303 code for callers over 10,000 calls in a day (Anatel). Do-not-call or opt-out list: 0303 code shown on the recipient's screen.

What applies in the United States?

The FCC confirmed in February 2024 that the Telephone Consumer Protection Act's limits on "artificial or prerecorded voice" calls cover current AI technologies that generate human voices. Under the FCC's rules, telemarketing calls with an artificial voice need prior express written consent. Solicitation calls to residential subscribers are limited to 8 a.m. to 9 p.m. in the called party's local time, and numbers on the National Do Not Call Registry are off-limits without the person's signed written permission. The agent must identify the business at the start of the call, and sales calls must offer an opt-out. States add their own rules on top. The TCPA compliance guide for outbound AI voice calls covers the US in detail.

What applies in Canada?

The CRTC's Unsolicited Telecommunications Rules define an automatic dialing-announcing device (ADAD) as equipment used "to convey a pre-recorded or synthesized voice message." A telemarketing call made through an ADAD is not allowed "unless express consent has been provided by the consumer." ADAD calls that do not try to sell, such as notifications, are allowed without that consent, but they must stay off emergency lines and healthcare facilities, keep to the hours below, and begin with a clear message identifying who the call is for and its purpose, with a mailing or email address and a local or toll-free number. The rules do not say whether a conversational AI agent counts as an ADAD, so plan as if it does and confirm with Canadian counsel.

Telemarketing calls also follow the National Do Not Call List (DNCL) rules. Callers must use a copy of the list obtained no more than 31 days before the call. Telemarketing calls are limited to 9:00 a.m. to 9:30 p.m. on weekdays and 10:00 a.m. to 6:00 p.m. on weekends, in the consumer's local time, and the same window applies to non-sales ADAD calls.

What applies in the United Kingdom?

The Privacy and Electronic Communications Regulations (PECR) set two tracks. For live marketing calls, the ICO says you "must not make marketing calls to any number listed on the Telephone Preference Service (TPS) or Corporate TPS (CTPS)" unless the person has specifically consented, and you must say who is calling and display your number. Automated marketing calls are stricter: regulation 19 bars them unless the person has notified the caller that they consent to such calls.

Regulation 19 defines an automated calling system by what it can do: dial a sequence of numbers automatically and transmit "sounds which are not live speech." An AI agent that works through a call list and speaks with a synthetic voice should be planned for as an automated caller, with specific consent, unless counsel concludes otherwise. As of October 2026, the ICO notes that its telephone marketing guidance is under review after the Data (Use and Access) Act.

What applies in the European Union?

Three layers apply. First, the ePrivacy Directive (Article 13) allows "automated calling and communication systems without human intervention" for direct marketing only with the subscriber's prior consent. For other marketing calls, each member state chooses whether people must opt in or can opt out, so the rule differs country by country. Whether a conversational AI agent counts as an automatic calling machine also depends on how each member state applies the rule, so plan for prior consent unless local counsel says otherwise.

Second, the GDPR gives every person the right to object to direct marketing "at any time," after which their data can no longer be used for it. That right must be brought to the person's attention "at the latest at the time of the first communication." Recital 47 says direct marketing "may be regarded as carried out for a legitimate interest," but you still need a documented lawful basis.

Third, Article 50(1) of the AI Act requires providers to ensure that AI systems that interact directly with people are designed so that people are informed they are interacting with an AI, unless that is obvious. Check with counsel whether you or your platform vendor is the provider for an agent you build. It applies from August 2, 2026, and the notice must come "at the latest at the time of the first interaction." In practice, put an AI disclosure in the agent's opening line for EU calls.

On data handling, Retell AI offers a Data Processing Addendum with EU Standard Contractual Clauses for self-signing, and its security and compliance page notes that Retell does not currently operate services within the EU. Factor that into any data residency review.

What applies in Australia, India and Brazil?

Australia

The Do Not Call Register Act 2006 prohibits unsolicited telemarketing calls to numbers on the register. Some calls are carved out by regulation, including appointment reminder and rescheduling calls and calls about payments. The Telemarketing and Research Calls Industry Standard 2017 requires calling line identification to be enabled, limits telemarketing calls to 9:00 a.m. to 8:00 p.m. on weekdays and 9:00 a.m. to 5:00 p.m. on Saturdays, bans them on Sundays and national public holidays, and requires the caller to end the call immediately when asked. The ACMA says its enforcement options for breaches of the standards run from formal warnings to penalties of up to A$250,000.

India

TRAI's commercial communications regulations, amended in February 2025, classify commercial voice calls as promotional, service or transactional. A promotional call may only reach subscribers who have not blocked that category or who have given consent, and any call that mixes promotional content with another type "shall be treated as a Promotional Voice Call." TRAI's explanatory memorandum says promotional robocalls should use 140-series numbers and service or transactional robocalls the 1600 series.

Brazil

Anatel requires companies that place a high volume of calls to use the 0303 number code, which networks must display clearly on the recipient's screen. Anatel's current numbering procedure (Ato 12712, as amended in August 2025) defines high volume as more than 10,000 calls on at least one day in a monthly observation period, and those callers must use 0303 on at least 90% of their calls. Callers register the activity, such as active telemarketing or collections. Using the code becomes optional if calls are authenticated and identified through a call authentication system that meets Anatel's criteria.

How do you run one agent across several countries?

Allowed calling hours differ by market, so one global schedule breaks somewhere. Telemarketing calls run until 9 p.m. in the US, 9:30 p.m. on weekdays in Canada and 8 p.m. on weekdays in Australia, where Sunday calls are banned. Each window uses the recipient's local time.

Treat each country as its own deployment with shared building blocks. Retell-purchased numbers can call 15 countries; imported numbers depend on your telephony provider's settings.

Calling windows are the first thing to split. With batch calling, each batch carries its own time window, so create one batch per country or time zone rather than one global list. Batch calls do not check Retell's internal do-not-call flag, so scrub each list against your own do-not-call list and the right national register before upload: the National Do Not Call Registry in the US, the DNCL in Canada, the TPS and CTPS in the UK, and the Do Not Call Register in Australia.

Disclosure comes next. Write the opening line for each market in the caller's language, and include the AI disclosure for EU calls. Every language an agent uses must be supported by both its voice provider and its speech recognition provider, so confirm the combination in the dashboard before you script it. For more on running agents across languages, see this guide to multilingual AI phone agents. Retell's Do-not-contact Handling confirms opt-out requests in the caller's language, and once a contact is marked, every campaign with internal DNC turned on skips that number.

Data agreements close the loop. Retell's docs say a DPA with Standard Contractual Clauses is required for processing personal data of EU and UK residents, and it can be self-signed alongside the BAA.

• An opening line for each market, written in the local language.
• AI disclosure in the opening line for EU calls.
• Consent evidence stored per contact and matched to each market's standard.
• Each list scrubbed against that country's register before every batch.
• One batch per country or time zone, each with its own time window.
• Your number displayed on every call (required for UK marketing calls and Australian telemarketing).
• DPA with Standard Contractual Clauses signed before calling EU or UK residents.
• Do-not-contact Handling on, and internal DNC enabled on every campaign.

For a single-country launch list, use the consent and disclosure checklist. Teams handling health data in the US should also read the HIPAA guide for AI phone agents.

A multi-country rollout is easiest to get right one market at a time, with consent, disclosure and opt-out handling proven on real calls before the next country goes live. Talk to Retell about a pilot in your first market.