TL;DR / Key Takeaways
- Under the FCC's 2024 ruling (FCC 24-17), AI-generated voices are an artificial voice under the TCPA: calls need prior express consent, and written consent for telemarketing.
- AI voice agents fit consented calls: reminders, form follow-up and opted-in customers. Cold outreach belongs with a human rep on a dialer.
- Retell AI is the only voice platform here that documents built-in federal and state do-not-call screening, and it is off until you connect your FTC registry account.
- Several dialers, including CloudTalk and Aircall, state that DNC screening and consent are the customer's job.
- Avoid Air AI: the FTC announced a settlement with it on March 24, 2026.
Short answer: "AI outbound calling" means two different products. An AI voice agent places the call and does the talking; under a 2024 FCC ruling that call uses an "artificial" voice, so you need the person's prior express consent, and prior express written consent if the call is marketing. Use one for appointment reminders, follow-up on people who just filled in your form, and customers who agreed to hear from you: Retell AI documents the most built-in compliance tooling, ElevenLabs Agents bundles minutes into plans from $6 a month, and Bland AI has one flat per-minute rate. An AI dialer dials for a human rep who talks: Nooks and Orum for parallel dialing at sales-team scale, JustCall or CloudTalk for published seat prices. Updated November 9, 2026.
How we checked: prices, limits, integrations and compliance features come from each vendor's own pricing page, docs, help center or terms, read November 9, 2026. The legal section cites only the FCC's own documents, the Federal Register, the U.S. Code and a state statute page. We did not place test calls with these tools, so this guide compares published price, features and documented safeguards, not call quality. Where a vendor's page does not state something, we say "Not stated".
Read this first: the consent rules for AI calls #
This section summarizes primary sources. It is not legal advice; talk to a lawyer about your own calling program.
The FCC ruling: AI voices are "artificial" voices
On February 2, 2024 the FCC adopted a Declaratory Ruling (FCC 24-17, CG Docket No. 23-362, released February 8 and effective on release). It says: "we confirm that the TCPA's restrictions on the use of 'artificial or prerecorded voice' encompass current AI technologies that generate human voices." As a result, those calls "require the prior express consent of the called party to initiate such calls absent an emergency purpose or exemption." A footnote adds that if the call introduces an advertisement or contains telemarketing, the rules "require that the caller obtain the prior express written consent of the called party."
Two more points from the ruling matter for buyers. It says the TCPA "does not allow for any carve out of technologies that purport to provide the equivalent of a live agent", so an AI agent that holds a real conversation is still an artificial voice. And it applies the existing identification and opt-out rules "to any AI technology that initiates any outbound telephone call using an artificial or prerecorded voice to consumers."
What the FCC's rules require on every such call
From 47 CFR 64.1200 as published on eCFR (current as of November 5, 2026):
- Consent. Artificial-voice calls to cell phones need prior express consent; if they are marketing, prior express written consent (section 64.1200(a)(1) and (a)(2)). Artificial-voice marketing calls to residential lines need prior express written consent (a)(3). The cell phone rule covers "any telephone number assigned to a ... cellular telephone service", and many business prospects answer on a cell phone.
- What written consent is. Section 64.1200(f)(9): "an agreement, in writing, bearing the signature of the person called that clearly authorizes the seller" to deliver advertisements or telemarketing using an artificial or prerecorded voice, plus "the telephone number to which the signatory authorizes" those calls.
- Identify yourself. Every artificial-voice message must, "at the beginning of the message, state clearly the identity of the business" responsible, and state a callback telephone number (b)(1)-(2).
- Opt-out on the call. Artificial-voice marketing calls must offer an automated, voice- or key-press opt-out "within two (2) seconds" of the identification, record the number to the do-not-call list and end the call (b)(3).
- Calling hours. No telephone solicitation to a residential subscriber "before the hour of 8 a.m. or after 9 p.m. (local time at the called party's location)" (c)(1). This applies whether a person or an AI talks.
- National Do Not Call. No telephone solicitation to numbers on the national registry, unless an exception applies. The safe harbor requires using a version of the registry obtained "no more than 31 days prior" to the call (c)(2).
- Your own do-not-call list. Telemarketers must keep a written policy and an internal do-not-call list, and honor a request "for 5 years" (d).
What changed since February 2024
- The one-to-one consent rule never took effect. The FCC's 2023 rewrite of the written-consent definition (one consent per seller) was vacated by the U.S. Court of Appeals for the Eleventh Circuit. The court's mandate issued April 30, 2025, and the FCC put the prior definition back into its rules on August 29, 2025 (90 FR 42137 ). The FCC notes the revised rule "had not gone into effect."
- Revoking consent. Today a person can revoke consent "using any reasonable method", and you must honor it within ten business days (section 64.1200(a)(10)). An FCC order published October 26, 2026 (91 FR 67214 , FCC 26-67), effective November 25, 2026, lets callers designate an exclusive revocation method (an automated opt-out on the call, standard reply words to a text, or a designated website or phone number) if it is clearly disclosed on the call or text. Under the new text, a revocation in response to a marketing call "revoke[s] consent to all future calls or text messages containing an advertisement or constitute telemarketing from that caller." A companion proposal (91 FR 67239 ) asks about shortening the ten-day window; comments close November 25, 2026.
- No AI-specific disclosure rule yet. In August 2024 the FCC proposed defining "AI-generated calls" and requiring callers to disclose AI use (89 FR 73321 ). The FCC's 2026 regulatory agenda lists that item's next action as "Undetermined" (Unified Agenda , RIN 3060-AM12), and we found no final rule in the Federal Register as of November 9, 2026. Several vendors require an AI disclosure in their own terms anyway (see below).
What a violation costs, and state law on top
The TCPA lets a person sue for actual losses or "$500 in damages for each such violation, whichever is greater", and a court may raise that to "not more than 3 times" if the violation was willful or knowing; state attorneys general can sue too (47 U.S.C. 227). States add their own rules. For example, the Florida Telephone Solicitation Act (section 501.059(8)(a)) bars an unsolicited telephonic sales call that "involves an automated system for the selection and dialing of telephone numbers or the playing of a recorded message" without the called party's prior express written consent, with $500 minimum damages per violation for the person called. Check every state you call into.
Avoid Air AI #
Air AI appears on many older "AI cold calling" lists. On March 24, 2026 the FTC announced a settlement with Air AI, related companies and its owners. The FTC alleged they falsely claimed buyers were likely to make substantial earnings and that buyers of the "Air AI Access Card or licenses" were protected by a refund or buy-back guarantee, in violation of the Telemarketing Sales Rule and the Business Opportunity Rule. The proposed order bans them from selling or marketing any business opportunity and carries an $18 million judgment, largely suspended because they cannot pay, with $50,000 to the FTC for consumer relief. The FTC notes such orders take effect only once the court approves them. The air.ai domain now presents an unrelated defense company. Do not buy from anyone selling "Air AI" today.
The comparison table #
| Tool | Who talks | Price model, as published | CRM integrations documented | Compliance features the vendor documents |
|---|---|---|---|---|
| Retell AI | AI | $0.07 to $0.31/min all-in range ($0.055/min platform + voice + LLM + phone); batch +$0.005/dial; $10 free credits | Salesforce, HubSpot, Dynamics 365, GoHighLevel, Zoho | Screening against internal, federal and state DNC, TCPA litigators, reassigned numbers (federal/state need your own FTC registry account; only internal DNC on by default); calling window in each contact's time zone; in-call do-not-call action; branded caller ID (US) |
| ElevenLabs Agents | AI | Plans $6 to $990/month with included minutes; extra minutes $0.08; LLM billed on top | HubSpot, Salesforce | Campaign calling windows; terms require consent, business name at call start, opt-out, 5-year consent records; AI disclosure required; no built-in national DNC scrub stated |
| Bland AI | AI | $0.14/min (Start, $0) or $0.12/min (Build, $299/month), LLM and voice included; phone extra | HubSpot, Salesforce, Cal.com, Zapier | Internal do-not-call list dropped at dial time; national DNC and calling hours: Not stated |
| Vapi | AI | $0.05/min hosting + models at cost + phone; Vapi's own estimate $82 to $129 for 1,000 minutes | GoHighLevel (first-party doc) | TCPA consent guide; campaign calling window (one time zone per campaign); pre-dial webhook to skip contacts on consent or suppression; built-in DNC scrub: Not stated |
| Thoughtly | AI | Not stated: quote only; pilot of 30 to 60 days | HubSpot, Salesforce, Zoho, HighLevel, Pipedrive, Keap, Attio | Quiet hours by channel; branded caller ID; TCPA and state DNC review on higher tiers; terms require prior express consent |
| Synthflow | AI | Annual enterprise contract only; no free plan, trial or per-minute rate | HubSpot, Salesforce, GoHighLevel | Campaign calling windows; caller ID number pooling; DNC and consent records: Not stated |
| Telnyx AI Assistants | AI | $0.05/min including speech-to-text and voice; LLM and phone extra | Salesforce, HubSpot, ServiceNow, Zendesk | AUP requires telling people they are talking to AI and bans unsolicited calls |
| Nooks | Human rep | Not stated: custom quote | HubSpot, Salesforce (plus Outreach, Salesloft) | Calling-hours restrictions; internal do-not-call snooze; recording controls by area code; says national DNC removal is up to your data provider |
| Orum | Human rep | Not stated: 9-seat minimum, request pricing; trial limited to 500 dials | HubSpot, Salesforce, Outreach, Salesloft | Org-wide internal DNC; rep-only recording in two-party-consent area codes; national DNC and calling hours: Not stated |
| JustCall | Human rep (also sells an AI voice agent) | $29 to $89/user/month annual ($39 to $109 monthly), 2-license minimum; power dialer from Pro ($49) | Salesforce, HubSpot, Pipedrive, Zoho CRM, Close, Freshsales | DNC check before dialing; dialing hours by time zone; consent field tracking (Salesforce); number reputation and CNAM registration |
| CloudTalk | Human rep (also sells AI voice agents) | EUR 25 to EUR 49/user/month annual; power dialer add-on EUR 15, parallel EUR 39 | HubSpot, Pipedrive, Salesforce | Local-time calling protection; STIR/SHAKEN on US outbound; branded caller ID from EUR 0.07/call; DNC screening is the customer's job |
| Kixie | Human rep | Not stated on the pricing page; 7-day trial | HubSpot, Salesforce, Zoho, Pipedrive, Close | National DNC check (compliance add-on); internal suppression lists; recording off for two-party-consent states; spam-label remediation |
| Aircall | Human rep (also sells AI voice agents) | $30 or $50 per license/month billed annually, 3-license minimum; power dialer on Professional ($50) | HubSpot, Salesforce, Pipedrive, Zoho | Number eligibility filtering; says calling hours, consent and DNC are the customer's job; number reputation $0.03/check; branded caller ID $0.08/call |
Part 1: AI voice agents that place the call themselves #
Use these only for calls the person agreed to receive. For a deeper cost-per-minute comparison of the same platforms, see our AI voice agent platform guide and Vapi alternatives.
Retell AI: the most compliance tooling built in
Retell AI's pricing page lists $0.07 to $0.31 a minute for voice agents, built from a $0.055 platform fee plus the voice, the LLM and telephony, with $10 of free credits and 20 free concurrent calls. Outbound add-ons are listed separately: batch calls at $0.005 a dial and branded caller ID at $0.10 per outbound call. Its Dialer runs campaigns inside a calling window "in each contact's time zone", and its compliance checks can screen each contact against your internal list, "the federal and state do-not-call registries, known TCPA litigators, reassigned numbers, and landline or VoIP line types." Only the internal list is on by default, the federal and state checks need your own FTC registry account, and screening is billed per number at a rate the page does not state. CRM sync covers Salesforce, HubSpot, Dynamics 365, GoHighLevel and Zoho.
Retell's terms require customers to "document proof of the required level of consent" and to scrub against do-not-call lists at least every 31 days. Not for: a team that wants a finished product with no setup. Retell is a developer platform, and the per-minute total depends on which voice and model you choose.
ElevenLabs Agents: minutes bundled into a plan
ElevenLabs Agents's pricing page includes call minutes in every plan: 15 free, 75 on Starter ($6 a month), 275 on Creator ($22), 1,238 on Pro ($99), 3,738 on Scale ($299) and 12,375 on Business ($990). Extra minutes are $0.08 ($0.16 burst), and LLM usage is billed on top. Outbound runs through campaigns with retries and calling windows "evaluated in your specified timezone", and HubSpot and Salesforce integrations are documented.
Its agent terms require you to obtain consents before placing a call, identify "the name of the business" and the purpose at the start of each outbound call, offer an opt-out and keep consent records for five years, and its docs require telling people they are talking to AI. Its TCPA guide advises you to scrub against the National DNC Registry yourself; we found no built-in scrub. Not for: someone who wants the model cost inside the per-minute price.
Bland AI: one flat rate per minute
Bland AI's pricing page charges $0.14 a minute on the free Start plan (10 concurrent calls, 100 calls a day) or $0.12 on Build at $299 a month (50 concurrent, 2,000 calls a day). The rate includes the LLM, speech-to-text and voice; telephony is billed separately. Batch calls take a CSV of recipients, and numbers on your do-not-call list "are dropped at dial time." HubSpot, Salesforce and Cal.com integrations are documented.
Not for: teams that want the platform to handle national DNC screening or calling hours: we found neither documented, and Bland's terms make you "solely responsible" for legal compliance.
Vapi: for developers who want to pick every layer
Vapi's pricing page charges $0.05 a minute for hosting with models passed through at cost, plus telephony; its own calculator estimates $82 to $129 for 1,000 minutes. Plans run from Core at $29 a month, and HIPAA is a $2,000-a-month add-on. Outbound campaigns use one calling window and time zone "for every contact" in the campaign, and a pre-dial webhook can skip contacts "based on current consent, suppression status". Vapi publishes a TCPA consent guide. GoHighLevel has a first-party doc; we found none for HubSpot or Salesforce.
Not for: a non-technical team, or a list spread across time zones, unless you split campaigns by zone.
Thoughtly: CRM-first, quote only
Thoughtly's pricing page shows no prices: plans are by quote, and most teams start with a 30 to 60 day pilot. It lists two-way CRM sync with HubSpot, Salesforce and Zoho, and its docs add HighLevel, Pipedrive, Keap and Attio. It documents quiet hours ("dark windows") that block outbound calls, texts and emails, and branded caller ID. A TCPA and state DNC compliance review is listed on its higher tiers, though its own pages differ on which. Its terms require "prior express consent from all recipients" before AI voice calls. Not for: anyone who needs a price before a sales call.
Synthflow: enterprise contracts only
Synthflow documents batch calling with calling windows and integrations with HubSpot, Salesforce and GoHighLevel. Its pricing page now says it is sold only as an annual enterprise agreement, with no free plan or trial and no rate by the minute. Not for: a small business or anyone who wants to try before signing.
Telnyx AI Assistants: carrier and AI in one bill
Telnyx sells AI assistants on its own phone network. Its pricing page lists $0.05 a minute covering orchestration, speech-to-text and voice, with LLM tokens and telephony extra. Its docs describe scheduled outbound calls for "appointment reminders, follow-ups, and renewal calls"; we found no campaign dialer. Its acceptable use policy requires telling people they are talking to AI "no later than the start of the interaction" and says unsolicited calls "remain prohibited ... whether made by a human or by automated or AI means." Not for: bulk campaigns that need a list dialer out of the box.
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Part 2: AI dialers where a human rep talks #
These tools dial faster and take notes, but a person holds the conversation. That is the setup for B2B cold calling, where it is allowed. Calling hours, the National Do Not Call Registry and your internal list still apply to telephone solicitations, and several vendors say outright that list scrubbing is your job.
Nooks: parallel dialing for SDR teams
Nooks lists parallel, multi-line and power dialing with AI answer detection, plus AI coaching. Its pricing page is quote only, and it integrates with HubSpot and Salesforce or a CSV upload. Its compliance guide says tools "are available to restrict calls to permissible calling hours" and that it can limit recordings by area code, but tells you to "ensure that your data providers automatically remove prospects from National DNC Registry." Not for: a team of one or two, or anyone needing a list price.
Orum: parallel dialing with a 9-seat minimum
Orum's dialer runs "up to 5 lines at once" in parallel mode or one in power mode. Its pricing page states a 9-seat minimum and no dollar figures; the trial is limited to 500 dials. It integrates with HubSpot, Salesforce, Outreach and Salesloft, keeps an org-wide internal do-not-call list, and can record only the rep's audio in two-party-consent area codes. We found no national DNC scrubbing or calling-hour control documented. Not for: small teams.
JustCall: published seat prices and DNC checks
JustCall's pricing page lists Team at $29 per user a month billed annually ($39 monthly), Pro at $49 ($69) with the power dialer, and Pro Plus at $89 ($109), each with a two-license minimum; the multi-line SalesPro plan is by quote. Its parallel dialer page says "lists are checked against do-not-call records first", lets you "set dialing hours by time zone" and tracks consent fields in Salesforce. JustCall also sells an AI voice agent; its pricing page and product page give different per-minute figures, so ask before you budget. Its outbound AI page says that product "should not be used for cold calling or purchased lists." Not for: teams that want parallel dialing at a list price.
CloudTalk: add-on dialers, priced in euros
CloudTalk's pricing page showed euro prices when we read it: Starter EUR 25, Essential EUR 29 and Expert EUR 49 per user a month billed annually. The power dialer is a EUR 15 add-on (included on Expert) and the parallel dialer, "up to 10 numbers at once", is EUR 39. Its dialer page says campaigns "only dial contacts during reasonable hours in each contact's own local time" and that US outbound calls carry STIR/SHAKEN, but also that "your team is responsible for consent and Do Not Call screening." It also sells AI voice agents. Not for: buyers who need US-dollar pricing in writing; the page's dollar prices were not readable to us.
Kixie: DNC checks as an add-on
Kixie offers single-line and multi-line power dialing ("up to 4 lines"), with HubSpot, Salesforce, Zoho, Pipedrive and Close integrations. Its pricing page shows plan names but no prices. A national DNC feature checks lists against the registry as a compliance add-on, and recordings can switch off automatically for two-party-consent states. Not for: anyone comparing on price before a demo.
Aircall: a phone system with a power dialer
Aircall (our Aircall listing) is a business phone system. Its pricing page lists Essentials at $30 and Professional at $50 per license a month billed annually, three licenses minimum; the power dialer, which calls up to 1,000 imported numbers in sequence, is on Professional. Its AI Voice Agents start at a $99 monthly minimum, $0.29 a minute pay-as-you-go. Its help center says "calling hours, consent documentation, and Do Not Call list management remain your organization's responsibility." Not for: high-volume SDR teams that want parallel dialing; we found no parallel dialer on the pricing page. See also our business phone systems guide.
How to choose #
- Reminders and confirmations for existing customers: an AI voice agent.Retell AI if you want registry screening and per-contact calling windows built in;ElevenLabs Agents for a fixed monthly plan;Bland AI for one flat rate.
- Calling people back minutes after they fill in a form: an AI voice agent, if your form collects consent that covers that call, worded to the standard above when the call is marketing. Keep the signed record.
- Cold outreach to new prospects: a human rep on a dialer.Nooks orOrum for teams;JustCall ,CloudTalk orAircall if you need list prices and a phone system.
- Whatever you buy: check whether it scrubs the National DNC Registry or leaves that to you, whether calling windows follow each contact's local time, and how it records opt-outs. Several tools here leave all three to the customer.
Frequently asked questions #
Is AI outbound calling legal?
It can be, with consent. The FCC's February 2024 Declaratory Ruling (FCC 24-17) says AI-generated voices are an artificial voice under the TCPA, so those calls need the called party's prior express consent, and prior express written consent if the call is telemarketing. Calling hours, do-not-call and state rules also apply. This is not legal advice.
Can I use AI for cold calling?
Not with an AI voice talking to people who have not consented. Under the FCC's 2024 ruling, an AI voice agent's call is an artificial-voice call, and marketing calls of that kind need prior express written consent. Cold outreach, where permitted, is done by a human rep, often using an AI-assisted dialer such as Nooks, Orum or JustCall, and still follows calling-hour and do-not-call rules.
What is the best AI appointment setter?
For calls to people who booked or asked to be contacted, Retell AI documents the most built-in outbound compliance tooling, including calling windows by contact time zone and optional do-not-call registry screening. ElevenLabs Agents bundles minutes into plans from $6 a month, and Bland AI charges one flat rate of $0.12 to $0.14 a minute plus telephony.
Did the FCC's one-to-one consent rule take effect?
No. The Eleventh Circuit vacated the FCC's 2023 rewrite of the prior express written consent definition, with its mandate issued April 30, 2025, and the FCC restored the earlier definition in its rules on August 29, 2025. The FCC notes the revised rule never went into effect.
Do AI calls have to say they are AI?
The FCC proposed an AI disclosure rule in 2024, but its 2026 agenda lists the next action as undetermined and no final rule had been published as of November 9, 2026. Existing FCC rules already require artificial-voice calls to identify the business at the start. Retell, ElevenLabs and Telnyx require an AI disclosure in their own terms or policies.
What happened to Air AI?
On March 24, 2026 the FTC announced a proposed settlement with Air AI and its owners over alleged false earnings and refund claims. It bans them from marketing business opportunities and carries an $18 million judgment, largely suspended, with $50,000 for consumer relief. The air.ai domain now belongs to an unrelated defense company.