Tennessee Pre-recorded and AI-Voice Call Laws

Compliance Insights

Tennessee's new limits on pre-recorded and AI-voice calls: what to know before the first filing

A state law passed in Tennessee this year (HB 2408) puts new volume limits, recordkeeping, and reporting obligations on marketers that use pre-recorded or artificial voice messages to reach Tennessee consumers. The first report to the state is due April 1, 2027.

Does this apply to my campaigns?

The law covers telephone solicitations that deliver pre-recorded or artificial voice messages to Tennessee residential subscribers. That includes pre-recorded outbound messages, voicemail drops, and AI-generated voices. If your campaigns use any of these to reach Tennessee residential numbers, these requirements likely apply.

Calls answered and handled entirely by a live agent don't involve a pre-recorded or artificial voice, so they fall outside the law. TPUC has also reportedly confirmed that calls made with a subscriber's prior express permission are not "telephone solicitations" under its rules. That makes documented consent especially valuable for Tennessee campaigns.

What's already in effect

Since July 1, 2026, every telemarketer must keep a monthly record of how many pre-recorded or artificial voice calls it made to Tennessee residential subscribers. This applies at any volume: even a single pre-recorded or AI-voice solicitation into Tennessee in a month must be counted.

The same date brought a hard cap. No person or entity may make more than 10,000 of these solicitations to Tennessee residential subscribers in a month, and TPUC's notice treats 10,000 or more per month as a violation. This counts only calls to Tennessee residential numbers, not your total volume nationwide

Reporting

Reporting applies only to solicitors making 500 or more of these calls to Tennessee residential subscribers in a month. If you meet that threshold, you must submit your monthly records to the Tennessee Public Utility Commission twice a year. The first report is due April 1, 2027, and reports are due every April 1 and October 1 after that. The Commission or the Attorney General may also request your records at any time, whatever your volume.

Penalties

Reporting violations are enforced by TPUC under Tennessee's Do Not Call Act. Exceeding the volume cap is an unfair or deceptive practice under the Tennessee Consumer Protection Act, with penalties of at least $1,000 per violation.

How Convoso is helping

We're developing tools to help customers track their Tennessee volume ahead of the April 2027 filing deadline.

What outbound teams should review now

Start by measuring your monthly Tennessee volume for any campaign that plays a pre-recorded message, drops a voicemail, or uses an AI voice. If you're anywhere near the cap, plan to stay below 10,000. Make sure your consent records for Tennessee consumers are complete and retrievable, since the consent exclusion is only as strong as your documentation.

If your organization places calls under multiple brands, subsidiaries, or client programs, get legal advice on how the cap applies to your structure. The law does not define "entity" for purposes of the volume limit and reporting obligations. Finally, add April 1 and October 1 to your compliance calendar as recurring filing dates.

This update is for informational purposes only and is not legal advice. Please consult your own legal counsel about how Tennessee's requirements apply to your business.