COMPLIANCE GUIDE

California AI Voice Disclosure Laws: Complete 2025 Compliance Guide

AB 2905 and related AI disclosure requirements for business owners using automated voice systems

Last Updated: February 3, 2025 | 10 min read

⚠️ If You Use AI Voice Calls in California, This Affects You

As of January 1, 2025, all businesses using AI-generated voices to call California residents must disclose it's AI at the start of every call. Non-compliance can result in fines and legal action.

AB 2905 is a California law effective January 1, 2025, that requires any business using AI-generated voices in robocalls to clearly disclose at the start of the call that the voice is artificial or AI-generated. The law applies to all automated calls made to California residents and carries penalties for non-compliance including fines and legal action from the California Public Utilities Commission.

This comprehensive guide covers AB 2905 requirements, compliance steps, related California AI disclosure laws, and practical action items to protect your business from penalties.

What is AB 2905?

AB 2905 Status: ACTIVE LAW (Effective January 1, 2025)

Signed by Governor Newsom on September 20, 2024 | Chapter 316 of the 2024 Statutes

AB 2905 amends California's Public Utilities Code §2874 to require that any robocall using an AI-generated or AI-altered voice must clearly disclose this to the recipient at the beginning of the call.[1]

Who Must Comply?

  • Any business using automated dialing systems with AI voices
  • Telemarketers calling California residents
  • Political campaigns using robocalls
  • Customer service operations with AI voice assistants
  • Sales teams using AI follow-up calls
  • Any entity making prerecorded calls with artificial voices

What Counts as an "Artificial Voice"?

According to the law, an artificial voice is:

  • A voice generated by artificial intelligence
  • A human voice significantly altered by AI technology
  • AI voice cloning or synthesis
  • Text-to-speech systems powered by AI

Key Requirement:

The disclosure must be made at the start of the call using a live, natural human voice stating: (1) the nature of the call, (2) the organization making the call, and (3) that an artificial/AI voice will be used.

Immediate Compliance Checklist

✓ Action Items for Business Owners

Audit Your Current Call System – Identify if you're using AI voices in any automated calls, follow-ups, or customer outreach.

Update Call Scripts – Add mandatory AI disclosure at the beginning of every call using AI voices.

Implement Human Introduction – Ensure a live human voice introduces the call before any AI voice speaks.

Train Your Team – Make sure sales, customer service, and operations teams understand the disclosure requirement.

Document Compliance – Keep records of call scripts, disclosure language, and system configurations.

Review Vendor Contracts – If you use third-party AI calling services, ensure they comply with AB 2905.

Consult Legal Counsel – Work with an attorney familiar with California telecommunications law.

Monitor for Updates – California's AI regulation landscape is evolving—stay informed.

Sample Compliant Disclosure Script

"Hello, this is [Your Name] from [Company Name]. I'm calling to [state purpose of call]. Please note that after this introduction, you will hear an artificial intelligence-generated voice. [Continue with AI voice]"

Alternative shorter version:

"This is [Company Name]. This call uses an AI-generated voice. [Continue with AI voice]"

Penalties for Non-Compliance

⚠️ Serious Consequences

Violations can be enforced by the California Public Utilities Commission (CPUC) and may result in:

  • Civil fines and penalties
  • Misdemeanor charges (violation of CPUC orders)
  • Cease and desist orders
  • Potential lawsuits from recipients
  • Reputational damage

California takes robocall violations seriously. AB 2905 was partly motivated by incidents of AI voice cloning used in deceptive political robocalls and scams.

Your Complete 30-Day Compliance Roadmap

Week 1: Assessment

    Inventory all systems using AI voices (sales calls, customer service, appointment reminders, follow-ups)

    Identify which calls go to California residents

    Review current call scripts and recordings

    Check if your AI vendor provides compliance features

Week 2: Implementation

    Draft compliant disclosure scripts

    Update call flows to include human introduction or natural voice disclosure

    Configure systems to trigger disclosures for California area codes

    Test calls to ensure disclosure is clear and audible

Week 3: Training & Documentation

    Train all staff who manage calling systems

    Document your compliance process

    Create compliance checklist for new campaigns

    Update privacy policy and terms if needed

Week 4: Monitoring & Optimization

    Monitor call recordings for compliance

    Collect feedback from call recipients

    Adjust disclosure language for clarity

    Set up ongoing compliance audits

Compliance Tips for Different Business Types

For E-commerce & Lead Generation:

If you use AI to follow up with leads from ads (Facebook, Google, etc.), you MUST disclose AI voice even if the lead called you first or filled out a form. Update your consent forms to mention AI voice usage.

For Service Businesses (Contractors, Shipping, Real Estate):

Appointment reminders and quote follow-ups count as robocalls if they use AI voices. Either switch to human callers or add the required disclosure.

For Healthcare Providers:

You need BOTH AB 2905 (voice disclosure) and AB 3030 (healthcare-specific disclosure + human contact option). Consider having a doctor review AI messages to avoid double disclosures.

For Customer Service:

If customers call you and reach an AI voice system, disclose it immediately: "You've reached [Company]. This system uses an AI voice. For a human representative, press 0."

Frequently Asked Questions

Do I need to disclose if someone calls ME and hears an AI voice?

Yes. AB 2905 applies to "automatic dialing-announcing devices" which includes any system that plays prerecorded AI voices to callers.

What if I only call people who opted in?

Opt-in doesn't exempt you from disclosure requirements. You still must tell them it's an AI voice at the start of the call.

Can the AI voice itself make the disclosure?

The law requires a "live, natural voice" introduction. This means either a real human or a clearly natural-sounding recording (not obviously robotic) must make the initial disclosure before the AI voice takes over.

What about text-to-speech that sounds human-like?

If it's AI-generated or AI-altered, you must disclose it. The law defines artificial voice broadly to include AI-synthesized speech.

Does this apply outside California?

AB 2905 is California state law, but if you call California residents from another state, you must comply. Other states may pass similar laws—watch for developments.

What if my AI voice vendor doesn't support disclosures?

You're responsible for compliance, not the vendor. Either work with them to add disclosure features or switch to a compliant provider.

Are there exemptions for small businesses?

No. The law applies to any entity using automated AI voice calls in California, regardless of business size.

What counts as "AI-generated" vs. regular recorded voice?

A traditional recording of a human voice (not altered by AI) doesn't require disclosure. But if you use AI voice synthesis, voice cloning, or AI to modify recordings, you must disclose.

Why California Is Leading AI Transparency

California has enacted more AI disclosure laws than any other state, creating a comprehensive framework requiring transparency across:

  • Voice calls (AB 2905)
  • Online bots (SB 1001)
  • Healthcare (AB 3030, AB 489)
  • Social media & content (SB 942, AB 853)
  • Political campaigns (AB 2355)
  • Government services (SB 896)
  • Companion AI (SB 243)

The common theme: If it's AI, you must say it's AI.

This approach protects consumers from:

  • Deceptive sales tactics using AI voices
  • Political manipulation via deepfakes
  • AI impersonation scams
  • Misleading medical advice from AI
  • Undisclosed AI relationships (chatbots posing as humans)

The Bottom Line for Business Owners:

Transparency builds trust. Disclosing AI use isn't just a legal requirement—it's good business practice. Customers appreciate honesty, and compliance protects you from penalties and reputational damage.

Sources & References

All information verified from official legislative sources and legal analysis:

  1. California Legislative Information – AB-2905 Bill Text & History (2023-2024)
  2. Willkie Farr (Compliance Concourse) – California Enacts 17 AI Bills in 2024
  3. California Assembly Privacy & Consumer Protection Committee – AB 2905 Analysis (April 2024)
  4. Akin Gump – California's Bot Law (SB 1001) Analysis
  5. Clark Hill PLC – A View From California: AI Bills Summary (2024)
  6. O'Melveny & Myers – California Continues its Push to Regulate AI (2025)
  7. California State Senator Steve Padilla – AI Chatbot Safeguards (SB 243)
  8. Smith Anderson – AI in Healthcare (AB 489) Analysis

Last Updated: February 2026 | This guide is for informational purposes only and does not constitute legal advice. Consult with a qualified attorney for specific compliance questions.

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