AI outbound calling: consent, hours and disclosure

AI outbound calling means an AI agent phones people on your behalf: a customer who stopped ordering, a lead who filled in a form, someone you promised to call back. The calls sound like a conversation, but the law treats the voice as artificial, and that decides almost everything about how you may place them. This guide covers the rules first, then how Centillion places these calls. Following the rules is your responsibility: Centillion places the calls you set up, and does not check consent, calling hours or how often you call.

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What an AI outbound call is

A traditional robocall plays a recording. An AI call listens and answers: the agent introduces your business, says why it is calling, responds to what the person says, and records what came of it. That makes it useful for work a recording cannot do, like asking a former customer why they left and listening to the answer. It also makes it easy to get wrong at scale. One badly written rule repeated across a thousand calls is a thousand complaints. So the useful way to think about an outbound agent is as a representative of your business on the phone: everything it is allowed to say, and everything it must say, is written down before the first call and checkable after the last one.

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Consent comes first

In the United States, the Federal Communications Commission settled the main question in February 2024. Its declaratory ruling (FCC 24-17) confirms “that the TCPA’s restrictions on the use of ‘artificial or prerecorded voice’ encompass current AI technologies that generate human voices.” As a result, such calls “require the prior express consent of the called party to initiate such calls absent an emergency purpose or exemption.” (FCC 24-17) Two things follow:

• You need consent before the call, not during it. A call made with an AI voice to someone who never agreed to it is the problem the ruling describes, however polite the agent is.
• Selling raises the bar. The FCC’s rules ask for prior express written consent for calls that advertise or telemarket (47 CFR 64.1200).

Keep a record you could show someone: the number, when the person agreed, how (a web form, a signed document, a recorded call), the exact words they agreed to, and where the proof is kept. If you cannot answer those five questions for a number, do not call it. Other countries have their own rules. Some require consent, some keep do-not-call registries, some require special number prefixes. The rules change, and this guide is not legal advice: have your counsel review each country you plan to call.

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Say who is calling, and how to stop it

The same ruling reminds callers that “all artificial or prerecorded voice messages must provide certain identification and disclosure information for the entity responsible for initiating the call,” and that a message that is telemarketing “must also offer specified opt-out methods.” (FCC 24-17) The FCC’s rules spell out the basics: “At the beginning of the message, state clearly the identity of the business,” and during or after it, “state clearly the telephone number” the person can call (47 CFR 64.1200(b)). A good opening does four things in a few seconds:

1. Names your business.
2. Says that the caller is an AI.
3. Says how to stop the calls.
4. Gives a number to call back.

Saying it is an AI is also the honest thing to do. People who find out halfway through a call that they were talking to software stop trusting everything else the call said.

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Calling hours and do-not-call lists

US federal rules bar telephone solicitations to a residential subscriber “before the hour of 8 a.m. or after 9 p.m.” local time, and protect numbers on the national do-not-call registry (47 CFR 64.1200(c)). Several states are stricter, with shorter hours, no calls on some days, or limits on how often one number can be called. Two practical consequences:

• Local time is the customer’s, not yours. In the US, an area code is the usual estimate of the time zone, but people keep their numbers when they move, and a few area codes span two zones. Call only at an hour that fits every zone the number could be in.
• Your own do-not-call list matters as much as the national one. When someone says “don’t call me again,” that request has to reach every agent and every campaign you run, permanently.

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What else to watch for

• Voicemail. A message about someone’s account left on a shared voicemail is not private. The safest default is to hang up without leaving one.
• The wrong person. Before an agent says why it is calling, it should check that it is speaking to the account holder: the reason alone can tell a stranger something about the customer. A number that reached someone else should not be called again for that customer.
• Number reputation. Phone carriers and your calling provider watch how your numbers behave, such as how many calls are answered and how many end within seconds. Calls people do not want show up in both.
• Pushing too hard. A representative makes the case once and accepts a no. An agent that argues loses the customer and the number’s reputation together.

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Set up outbound calls in Centillion

Your agent can phone a contact, introduce itself, follow its published instructions and workflow, and save the outcome. Start a batch from an uploaded call list on the workspace or agent’s Outbound page. Existing voice campaigns can also use a contact audience and playbook. The full reference is Outbound AI calls. Campaigns require Standard or above, and connected calls use six credits per commenced minute, on top of model requests.

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What Centillion does on every call

• A do-not-call list that only grows. A number goes on it when the person asks not to be called again, texts STOP or sends STOP on WhatsApp, or when someone in your workspace adds it. Numbers are never taken off it, and no agent or campaign calls them.
• The right person. On a voice campaign, the agent checks it is speaking to the right person before saying why it is calling. If not, it ends the call. If the number itself is wrong, that number is not called again for that contact. A wrong person is not added to the do-not-call list unless they ask not to be called.
• Straight answers. If the person asks who is calling, whether it is an AI or how to stop the calls, the agent answers plainly and truthfully.
• Voicemail. With Voicemail detection enabled, the agent hangs up when it recognizes voicemail. If a message is configured, it waits for the greeting to finish, plays the message and ends the call.
• Number health. Calling numbers shows each number’s calls in the last 24 hours, the share answered over 7 days, and the share of answered calls that ended in 12 seconds or less. An answer rate above 70% and no more than 10% of calls that short show green.
• Limits. Calls use the selected number’s carrier permissions and the agent’s volume and duration limits. A number places at most 100 calls in any 24 hours unless the team set another limit.

Batch calls start on your selected schedule. Unanswered and failed recipients are retried only when you choose Retry. Voice campaigns keep their quiet hours and automatic retries.

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What stays with you

Centillion does not check consent, disclosures, calling hours, do-not-call registries or how often a number is called. The first time you place a test call or launch a batch from the dashboard, Centillion shows the Outbound communications terms and conditions. By agreeing, you confirm that you have every consent the law requires for your calls and messages, that you give every disclosure it requires, including those about automated or AI-generated communications, and that you alone are responsible for the laws, regulations and industry standards that apply, such as the TCPA. Each person agrees once per workspace, and again if the terms change. Choose calling times and disclosures appropriate for your recipients. Carrier access does not establish consent or legal permission to call.

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Questions

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Does the agent say that it is an AI?

When you tell it to, and whenever someone asks: asked whether it is an AI, the agent answers truthfully. Write the identification and AI disclosure in Agent → First message → Call and the agent’s instructions. A batch uses that opening, or a recipient’s first_message override. When the agent records calls, a fixed sentence saying the call is recorded and transcribed plays before it. A voice campaign opens without a fixed notice, so put the disclosure in the agent’s instructions or the campaign’s playbook.

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Which countries can my agent call?

Any number with its country code, such as +52, that the connected phone provider’s geographic permissions allow. Centillion does not limit calls by country, so check the rules of each country you call: some require consent, some keep do-not-call registries, and some require special number prefixes.

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What happens when a call reaches voicemail?

Enable Voicemail detection in Tools. In Customize, leave the optional Voicemail message blank to hang up silently, or enter a callback message. The agent waits for recording to begin, plays the message once, then hangs up. New blank agents start with this tool off; existing agents keep their settings. Publish the configuration before running a batch. Use a general message because a shared voicemail is not private. Part of the fixed opening can still reach the recording, since it starts when the call is answered. The result stays Voicemail, and it ends the contact’s calls for that campaign. The conversation shows any message the agent spoke.

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How does someone stop the calls?

They ask not to be called again, text STOP, or send STOP on WhatsApp. The number goes on the workspace’s do-not-call list, and no agent or campaign calls it again.

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Does Centillion check consent and calling hours for me?

No. Your workspace is responsible for consent, disclosures, calling hours and how often a number is called, and agrees to that in the outbound communications terms. Centillion keeps calls off your do-not-call list and away from numbers that reached the wrong person.

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Does the do-not-call list stop WhatsApp messages too?

No. The list is about calls. WhatsApp has its own opt-out: a customer who replies STOP to your WhatsApp number stops getting campaign messages and automatic replies.

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Try it

Write your opening once, start with a few customers who asked to hear from you, and run a small batch. Every outcome lands on the contact. Or ask the assistant on this page.

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