Outbound AI Calls: How They Work and the Consent Rules to Know

Outbound AI calls are phone calls placed by an AI agent rather than received by one. Calling a business on your behalf is one thing; calling your customers is another. In the US, the FCC treats AI-generated voices as artificial voices under the TCPA, so those calls generally need the called person's prior express consent.

Concierge's AI agents answer calls, but they don't place them. Your teammates can make calls from your business number. This post explains the topic and the rules so you can judge any tool that offers it. It isn't legal advice.

Lindy's docs describe the first kind: you tell it who to call and what you want done, it calls from its own number, it "can navigate phone menus, wait on hold, and leave a voicemail", and it reports back (checked November 1, 2026).

In a declaratory ruling released February 8, 2024 (FCC 24-17), the FCC said AI technologies that generate human voices count as an "artificial" voice under the Telephone Consumer Protection Act. Calls using them need the called party's prior express consent, unless there is an emergency purpose or an exemption (checked November 1, 2026).

In practice, that leads to some questions to take to your lawyer:

• What consent do you hold? Under the FCC's rules (47 CFR § 64.1200), artificial voice calls that advertise or telemarket need prior express written consent, which is stricter than the consent other calls need.
• Do you identify the caller and offer a way to opt out? The same rules require artificial voice messages to name the business at the start, and telemarketing messages to offer an automated opt-out.
• Do your state or country add rules on calling times, AI disclosure or recording?
• Do you check do-not-call lists, and do you record opt-outs where every system can see them?

See our glossary entry on the TCPA and our guide to call recording consent. Rules change, so check the current position for wherever you call.

• Reasonable to explore: Calling suppliers for a stock check, where a wrong answer is cheap. Consent rules can still apply to calls to mobile numbers, so check before you start.
• Be careful: Reminders and service calls to customers who agreed to them. Test whether a text would do the job.
• Avoid unless reviewed by a lawyer: Cold sales calls to consumers. The legal risk and the damage to your reputation are both high.

Before any AI calls a customer, ask whether a call is right at all. A customer can read a text whenever it suits them, and a delivery update rarely needs a ringing phone.

If you use a tool that calls businesses for you, a tight brief limits the risk. Here is an example: "Call [supplier] at [number]. Say you are an AI assistant calling for [brand]. Ask whether SKU [code] is in stock and when the next delivery is due. You may share our account number. Don't place an order, agree to any price or share anything else. If they need a decision, say a person will call back. If nobody answers, leave no message and report back."

Every line in it does a job. The disclosure is honest. The narrow question keeps the call short. The list of what it may share stops it from giving away too much, and the rule about decisions keeps a commitment from being made by mistake.

A call interrupts somebody, a voice can feel like a person until it doesn't, and a mistake is harder to review than a written message. Answering machines, poor connections and people who get confused all need handling. People have also learned to distrust unknown callers, so an AI call can hurt your answer rates for real calls from your team. A text or email leaves a written record, lets the customer reply when it suits them and gives them an obvious way to opt out. So try the quieter channel first, and keep calls for when a conversation really is the better way.

Concierge's AI agents don't place phone calls, either to businesses for you or to your customers. They handle calls this way:

• Answering: Agents answer calls to your business number, using the customer's history and your rules. See the phone channel.
• Joining and transferring: A teammate can join a live call or take it over.
• Calls by your team: Teammates place calls from your business number in the Finn iPhone app.
• Written follow-up: For proactive messages to customers, use SmartyTap flows, with SMS consent and opt-outs. These are fixed messages and don't start an agent.

If you need an agent to phone other businesses for you, Lindy offers this, as our comparison says. Also read AI voice agents for Shopify and IVR vs an AI phone agent.

They can be, with the right consent. The FCC said in 2024 that AI-generated voices count as artificial voices under the TCPA, so these calls generally need prior express consent unless an emergency purpose or exemption applies. Speak to a lawyer before calling consumers.

Concierge's AI agents don't place calls. They answer calls to your business number. Teammates can place calls from that number in the Finn iPhone app, and a teammate can join or take over a live call.

An inbound agent answers people who chose to call you, while an outbound agent starts the contact. The second raises consent questions, because the person didn't ask for the call.

Yes, as a sensible practice. Check the disclosure rules for where you call, and answer honestly whenever someone asks.