No Sundays, Nothing After 7: What Pennsylvania's Act 47 Says About Calls, Texts, and AI Voices

Status as of Tuesday, Oct 20, 2026, 9:15 a.m. CT: Act 47 is in effect. Sources differ by one day on the start date (more below). We found no new guidance from the Pennsylvania Office of Attorney General on the amendments, and its Telemarketing FAQ page still quotes the older "telephone solicitation call" definition. We'll update this line if that changes.

The short version. Pennsylvania's Act 47 of 2026 rewrote the state's Telemarketer Registration Act. The amended law defines a telephone solicitation as "a telephone call, voicemail, ringless voicemail or text message" made to sell consumer goods or services, bars telephone solicitations "on a Sunday or after 7 p.m. or before 9 a.m.," and requires "prior express written consent" for robocalls (with exceptions the Act lists), a term that now covers "prerecorded or artificial voice calls or messages." The definition of telephone solicitation still carves out calls or messages "in reference to an existing debt, contract, payment or performance." Which side of that line each of your Pennsylvania messages sits on is the question this post is built around.

Who this is for

Owners and operators at lenders (including banks and credit unions), third-party agencies and debt buyers, and in-house collections teams at tech companies that call or text Pennsylvania numbers, or that run outbound from Pennsylvania. It matters most if one stack sends both account messages (servicing, payments, collections) and offers (refinance, new credit, upgrades, add-ons).

On scope, the Act speaks for itself. It defines a "telemarketer" as "any person or business which, in connection with telemarketing, initiates or receives telephone calls or messages to or from a residential, business or wireless telephone subscriber in this Commonwealth, or when the person or business acting in connection with telemarketing is located within this Commonwealth when such calls or messages are initiated or received." "Telemarketing" is "a plan, program or campaign which is conducted to induce the purchase of consumer goods or services," among other things, "and which involves more than one telephone solicitation." And "consumer goods and services" means "real or personal property or services used for personal, family or household purposes." Teams often review how those definitions map to their programs with their compliance team or counsel.

Pennsylvania just moved the dinner-hour line. The old Act barred "conducting telemarketing after 9 p.m. or before 8 a.m." The new one bars telephone solicitations before 9 a.m. or after 7 p.m., and on Sundays all day.

That's the headline everyone ran with. For operators, the more interesting part is quieter. The law now covers texts, voicemails, and ringless voicemails by name. It defines robocalls to include artificial voices. It adds a line about "synthetic or computer-generated messaging." And it keeps the existing-debt carve-out word for word from the old definition. For outbound programs that mix account messages and offers, that combination is where most of the questions land.

What happened

According to the General Assembly's bill history, SB 992 was sponsored by Sen. Michele Brooks (R-50). It passed the Senate 50-0 on Oct 29, 2025, and the House 202-0 on July 12, 2026. The Senate concurred in the House amendments 50-0 the same day, and Gov. Josh Shapiro approved it July 20, 2026, as Act 47 of 2026. The Act's last section reads: "This act shall take effect in 90 days."

Which day counts as day 90 depends on who you read. Receivables Info and Contact Center Compliance (DNC.com) put the effective date at Oct 18. The Consumer Financial Services Law Monitor, the Troutman Pepper Locke blog, gave Oct 19, and Sen. Brooks's office posted a release on Oct 19 saying "Act 47 of 2026 takes effect today." Both dates are behind us now.

Brooks's release says the Act "updates Pennsylvania's Telemarketer Registration Act for the first time in nearly 30 years to address the technology and tactics scammers and telemarketers use today." It also says the law "addresses the growing use of artificial intelligence and other technology in deceptive communications by prohibiting the use of computer-generated messages to deceive consumers."

What the Act says, in its own words

All quotes below are from the Telemarketer Registration Act as amended by Act 47 (73 P.S. 2241 and following). Section numbers are the Act's own.

What counts as a telephone solicitation (Section 2)

The amended definition: "A telephone call, voicemail, ringless voicemail or text message made to a residential, business or wireless telephone subscriber for the purpose of soliciting the sale of consumer goods or services, or for the purpose of obtaining information that will or may be used for the direct solicitation of the sale of consumer goods or services or an extension of credit for that purpose."

The term "does not include a call or message made to a residential, business or wireless telephone subscriber":

1. "In response to the prior express written consent of the subscriber."

2. "In reference to an existing debt, contract, payment or performance."

3. "With whom the seller or telemarketer has an established business relationship within the past 12 months preceding the call."

4. On behalf of certain tax-exempt organizations or a congressionally chartered veterans organization.

5. "On behalf of a political candidate or a political party."

The old definition was "a call." The new one names four channels. The existing-debt exclusion carries over unchanged from the prior text.

The Act defines an "established business relationship" (last amended in 2019, not by Act 47) as "a prior or existing relationship formed by a voluntary two-way communication between a person or entity and a residential, business or wireless telephone subscriber, with or without an exchange of consideration, on the basis of an inquiry, application, purchase or transaction by the residential, business or wireless telephone subscriber regarding products or services offered by such persons or entity." It adds: "In regard to an inquiry, the person or entity shall obtain the consent of a residential, business or wireless telephone subscriber to continue the business relationship beyond the initial inquiry."

When (Section 5(a)(1) and (a)(10))

Prohibited: "Initiating or causing to be initiated a telephone solicitation on a Sunday or after 7 p.m. or before 9 a.m." The deleted text it replaced was "Conducting telemarketing after 9 p.m. or before 8 a.m."

Also prohibited: "Initiating or causing to be initiated a telephone solicitation on a legal holiday."

Opt-outs (Section 5(a)(2), (a)(8), and 5.2(l))

For solicitation texts, the Act says "the person may state the intent to stop receiving telephone solicitation text messages by responding 'stop,' 'quit,' 'end,' 'revoke,' 'opt out,' 'cancel' or 'unsubscribe' in reply to an incoming text." Those are the same seven words the FCC lists in its revocation rule at 47 CFR 64.1200(a)(10).

The same paragraph says a seller or telemarketer "shall not be liable for violating the provisions of this paragraph if" it "has established and implemented written procedures," "has trained" its personnel in them, "has maintained and recorded lists of persons who may not be contacted," and "any subsequent call is the result of error."

Section 5(a)(8) prohibits "failing to end a telephone solicitation when a called party indicates the called party wants to end the call or message."

For robocalls, Section 5.2(l) requires an opt-out notice "at the beginning of the call," with an "automated, interactive voice-activated or key-press-activated opt-out mechanism" available "within two seconds of disclosing the name of the caller and the name of the person or entity on whose behalf the call is being made," and "the called party shall be able to opt out throughout the duration of the call." Robocalls left on voicemail must give "a toll-free telephone number" that connects to that mechanism.

Robocalls, artificial voices, and consent (Sections 2 and 5(a)(11))

"Robocall" now means "a telephone solicitation that uses an automated dialing system to deliver prerecorded or artificial voice calls or messages." The old definition was "made to a large number of people, using a computerized autodialer, to deliver a prerecorded telemarketing message."

Prohibited: "Initiating or causing to be initiated a robocall to any residential, business or wireless telephone line without the prior express written consent of a called party, unless the call is initiated for emergency purposes or is otherwise exempt under this act."

"Prior express written consent" is "a written agreement executed between a called party and a seller" that (1) "identifies the telephone number to which the called party authorizes the calls or messages," (2) "contains a clear and conspicuous disclosure that, by executing the agreement, the called party consents to receive telephone solicitations from the seller, including a robocall or text message," (3) "states that the consent is not a condition of purchasing property or consumer goods or services," and (4) "is signed by the called party," which may include an electronic signature under the federal E-SIGN Act.

Deception, consent-gathering, and caller ID (Sections 5(a)(9), (a)(12), (a)(13), and 5.1)

Three lines that stand out for operators running AI:

• (a)(12): "Using or causing to be used any unfair or deceptive act or practice in an effort to obtain a residential, business or wireless subscriber's consent to receive telephone solicitations."

• (a)(13): "Using or causing to be used any technology or any synthetic or computer-generated messaging to defraud, deceive or mislead a residential, business or wireless subscriber."

• (a)(9) now references "47 U.S.C. Sec. 227(e) (relating to restrictions on use of telephone equipment) or any regulation of the Federal Communications Commission relating to caller identification requirements," alongside the FTC's Telemarketing Sales Rule (16 CFR 310).

Section 5.1 bars a telemarketer from acting with the primary intent "to prevent the transmission of a telemarketer's name or telephone number or to falsely identify the telemarketer's name or telephone number to any recipient of a telephone solicitation," or "to circumvent, bypass or disable any product or service" a subscriber uses "to screen telephone calls or messages."

Registration (Section 3)

Section 3 says telemarketers must register with the Office of Attorney General "at least 30 days prior to offering for sale consumer goods or services through any medium." The exemptions now sit in a new Section 3(b.1). Two stand out: (b.1)(5), "a person or business engaged in a business or occupation licensed by, certificated by or registered with a Federal or Commonwealth agency while acting within the scope of the business for which licensure, certification or registration is required," and the new (b.1)(13), "a person or business that is not engaged in telemarketing because the calls or messages initiated by the person or business do not meet the requirements of telephone solicitation." Section 4 requires a $50,000 surety bond with the application.

Records and enforcement (Sections 6 and 8)

Section 8(a): "In any civil proceeding alleging a violation of this act, the burden of proving an exemption or an exception from a definition is upon the person claiming it."

Section 6(a): "A violation of this act is also a violation of" the Unfair Trade Practices and Consumer Protection Law (UTPCPL). Under UTPCPL Section 8(b), in an action brought by the Attorney General or a district attorney, if a court finds a person "is wilfully using or has wilfully used" an unlawful practice, the Commonwealth "may recover ... a civil penalty of not exceeding one thousand dollars ($1,000) per violation," and where the victim "is sixty years of age or older, the civil penalty shall not exceed three thousand dollars ($3,000) per violation." Commentators also mention private suits under the UTPCPL. Its private-action section, Section 9.2, begins with "any person who purchases or leases goods or services primarily for personal, family or household purposes and thereby suffers any ascertainable loss of money or property." It's the kind of section teams often read with counsel before repeating anyone's summary of it, ours included.

Act 47 at a glance

A side-by-side for your team. The left columns are Pennsylvania's text; the right column is federal text on the same topic, quoted for comparison only. Neither column says what applies to you.

What commentators have said

These are their readings, attributed and linked. We're reporting them, not adopting them.

Liisa M. Thomas and Kathryn Smith of Sheppard, writing Aug 21: "The law has not changed the exceptions to telephone solicitations, of which robocalls are a subset. These include a prior existing business relationship in the last 12 months, calls about an existing debt or contract, and calls made on behalf of a tax-exempt entity." Their takeaway: "Pennsylvania's law is one more reminder that federal rules alone are not enough."

Troutman Pepper Locke's Consumer Financial Services Law Monitor (Sept 3) said the new robocall definition "aligns more closely with federal standards under the Telephone Consumer Protection Act and captures AI-generated voice calls." On calling hours, the same post said: "Importantly, quiet-hour suppression must be keyed to the recipient's location, not the operations center's time zone."

Contact Center Compliance, which publishes DNC.com, wrote that the synthetic-messaging provision "shouldn't be read as a blanket prohibition on using AI in outbound outreach. The language specifically addresses technology used to defraud, deceive or mislead." On consent records: "A CRM field that says 'opted in' doesn't necessarily tell you what language the person saw, which number they authorized or which seller they agreed could contact them."

Receivables Info, an ARM trade outlet, wrote in July: "Ordinary communications concerning an existing debt, contract, payment, or performance are excluded from the law's definition of a telephone solicitation."

One related federal data point. AccountsRecovery.net reported on a California class-action complaint, filed under the federal TCPA, alleging that two past-due texts from a collection company were telemarketing. Per the article, the second text "offered to settle the balance for less than the full amount," and the complaint states: "The subject messages were not informational or transactional." That's an allegation in a complaint, not a ruling, and it isn't a Pennsylvania case.

Questions for your team

None of these need a lawyer to ask. Plenty of them end up with one. Many teams start with the ops lead and bring the answers to compliance or counsel.

Which of our Pennsylvania outbound is about an existing account, and which is an offer?

Refinance offers, new credit lines, card upgrades, add-on products, renewal pitches, "you're pre-approved" texts. Who decides how each campaign is classified, and where is that decision written down?

What happens when a conversation changes purpose?

A payment call where the borrower asks about lowering their rate. A collection text thread where someone wants to talk about a new loan. Does a human or an agent pivot on the spot? How does compliance want a pivot handled, and does it run as a separate, approved flow?

What does "within the past 12 months" look like in our data?

The Act's established business relationship definition talks about "an inquiry, application, purchase or transaction." Can your systems show the date of the last qualifying event per number, and does compliance agree on what qualifies?

Does our scheduler know Pennsylvania's window, Sundays, and legal holidays, and for which campaigns?

Which holiday calendar does it use? Whose clock: the area code, the account address, or something else? (See Troutman's comment above.) Where does that setting live, in our dialer, our texting platform, our AI agent platform, or a vendor's?

Do all seven words stop the next solicitation text, in every system that could send it?

Including the AI agent's text channel, the marketing platform, and any vendor. How long does a STOP take to reach the last system? And when FCC 26-67 takes effect, how does compliance want our federal revocation setup to line up with Pennsylvania's list?

Can we produce the signed consent?

For any robocall or text that relies on prior express written consent: the number, the disclosure language, the "not a condition of purchase" statement, and the signature. All four, per number, on request.

Does compliance treat our AI voice calls as "artificial voice" calls?

The FCC's 2024 ruling (FCC 24-17) says the TCPA's "artificial or prerecorded voice" restrictions "encompass current AI technologies that generate human voices." Pennsylvania's robocall definition uses "artificial voice" too. If any AI voice outreach to Pennsylvania is a solicitation, does it have the opt-out mechanism Section 5.2(l) describes?

How does our agent introduce itself?

Section 5(a)(5) prohibits failing to disclose promptly, during the initial contact, "the purpose of the call, the name of the telemarketer or telemarketing business and, if applicable, what the telemarketer or telemarketing business is selling." What disclosure script does compliance want for each campaign type, and does the agent say it?

Has anyone re-read our registration position?

The exemptions moved into a new Section 3(b.1), and (b.1)(13) is new. If the program relied on an old exemption, has counsel looked at whether the reasoning holds under the reorganized text?

Questions for AI agents and automation

This part is about systems, not law. These are the design questions we think about as operators.

Is purpose a field or a vibe?

Does every outbound message carry a purpose tag (account servicing, payment, collection, marketing, offer), and who sets it, and when? Do the send-time rules key off that tag plus the number's state? If the only record of what a message was for is the copywriter's memory, answering that question later gets hard.

What happens when a borrower asks about something else?

An agent working a collection or servicing flow hears a borrower ask about a refinance. Can it bring up an offer on the spot, or does it log the request and route it to an approved flow or a human? It's a small moment where a helpful answer and an approved campaign can drift apart.

Where do state rules live?

Pennsylvania changed on a specific date. Does the rule engine hold calling windows, day restrictions, holiday calendars, and keyword lists per state with an effective date, so one change reaches every campaign? Or is someone hand-editing hours in forty campaign scripts on a Saturday night before a Sunday ban? (Yes, we've asked this before. It keeps coming up.)

How many opt-out lists are there?

Do the AI agent, the human team, the marketing platform, and the vendor all read and write the same suppression state? Does anything log how long each opt-out took to propagate? "We honored it in the system that received it" and "every system knows" are two different answers.

What gets logged at send time?

Purpose tag, consent record ID if any, the state rule set version, the result of the check? Section 8(a) says the burden of proving an exemption or an exception from a definition "is upon the person claiming it." Is a message's purpose recorded when it goes out, or reconstructed later?

How does the agent introduce itself?

Does it state who it is, who it's calling for, and why, at the start of every call and in every first text? The answer feeds straight into the disclosure question above.

Last week's bankruptcy noticing outage raised a similar point from a different angle: the rule lives wherever the clock and the suppression list live, and that's often inside a vendor. See The Bankruptcy Notices Stopped. The Filings Didn't.

How this sits next to the federal rules

Federal law didn't move on Oct 18, but it's part of the picture.

• The TCPA's state-law section says that, except for certain technical standards and the national database provision, nothing in the TCPA or its rules "shall preempt any State law that imposes more restrictive intrastate requirements or regulations on, or which prohibits," among other things, "the use of artificial or prerecorded voice messages" or "the making of telephone solicitations." (47 U.S.C. 227(f)(1)) See our TCPA glossary entry.

• For debt collectors, the FDCPA's own time-of-day presumption is in 15 U.S.C. 1692c(a)(1), and its state-law section says it does not exempt anyone "from complying with the laws of any State with respect to debt collection practices, except to the extent that those laws are inconsistent with any provision of this subchapter." (15 U.S.C. 1692n) See our FDCPA glossary entry.

• The FCC's Report and Order in FCC 26-67 (adopted Sept 30, released Oct 1, 2026) says it will "allow callers to designate an exclusive means to revoke consent," and that the rule changes "become effective 30 days after Federal Register publication." It was not in the Federal Register when we checked the morning of Oct 20. How a state keyword list and a federal exclusive-method option fit together for your program is a question for counsel.