2025 TCPA Call Ads Checklist: 12 Rules Under 47 CFR §64.1200 (US)

Reviewed by: editorial compliance review (telecom operations), Last reviewed: 2025-10

Fast, clean dial-plan for today (47 CFR §64.1200)

A lead hits your queue at 09:02; one mis-set toggle—quiet hours, DNC, or an AI voice—can turn a warm start into a complaint, like a morning kettle clicking on and then burning dry. Set the guardrails once so the team can focus on the conversation.

Quiet hours: place calls only 08:00–21:00 in the called party’s local time. Configure by called-party timezone; we won’t “spray hours” across zones.

DNC hygiene: sync against the National Do Not Call Registry at least every 31 days and keep honoring company-specific DNC. That 31-day cadence is the floor—auto-refresh so a missed scrub doesn’t become a violation.

Revocations: process “stop/don’t call” promptly; the outer limit is 10 business days. Treat it like a priority ticket and aim same-day where possible. Why wait?

Consent (PEWC): your disclosure must clearly authorize the seller; “marketing partners” isn’t enough. The 2025 “one-to-one” add-on was vacated and removed, but multi-seller use still requires each seller to be named.

AI voice: treat AI-generated voices as “artificial/prerecorded”—don’t use them for marketing without prior express consent. If in doubt, switch to a live human.

Number integrity: make the Reassigned Numbers Database a first-touch habit and log the lookup for safe harbor.

• Configure dialer windows by called-party TZ; auto-block off-hours.
• Auto-refresh DNC ≥ every 31 days; surface company-DNC status inside the agent UI.
• Route “stop/don’t call” to a 10-business-day SLA queue; send a brief confirmation once processed.
• Store PEWC artifacts (disclosure text, seller name, timestamp, IP); quarantine any lead lacking a named seller.

Next action: add a pre-dial RND query and a 10-day revocation SLA to your CRM today.

Costs & cadences you’ll actually schedule this week (place next to your ad slot for reference):
• National DNC: refresh file ≤31 days; automate nightly import. (Source, 2025-10)
• RND queries: nightly for active lists; keep receipts for safe harbor. (Source, 2025-10)
• STIR/SHAKEN & CNAM: register brand/number pairs before first flight; avoid throwaway DIDs. (Source, 2025-10)

Quick facts (2025, US): quiet hours, DNC ≤31 days, PEWC, revocations

You’re locking down the guardrails so the team can focus on real conversations. Here’s the plain-English baseline that holds up this year.

Quiet hours. Do not place telephone solicitations before 08:00 or after 21:00, local to the called party. Configure quiet hours by the callee’s timezone—not the agent’s or the dialer’s default.

National DNC—what “≤31 days” means. Pull and scrub against a version of the National DNC file obtained ≤31 days before any call; that cadence supports safe-harbor if you document it.

Keep written procedures, train staff, and record each scrub. Honor company-specific do-not-call requests for 5 years. National DNC registrations remain in force unless the number is disconnected/reassigned or the consumer removes it.

Texts count—treat them like calls. The FCC generally treats marketing texts as “calls,” so consent, DNC, and opt-out duties apply.

After the 2025 McLaughlin decision, some courts have questioned whether §227(c)’s DNC rules cover texts; the risk-averse move is to keep handling SMS as calls while the law settles.

AI voices = “artificial/prerecorded.” If a marketing call uses an AI-generated or cloned voice, it’s an artificial/prerecorded voice under the TCPA and requires prior express written consent (PEWC).

Keep any non-marketing greeting purely factual—no sales pitch—or hand off to a live agent.

Revocations—any reasonable path, 10 business days. Accept opt-outs by any reasonable method (reply “STOP,” voicemail, email, IVR, web form). Process and suppress within a reasonable time not to exceed 10 business days.

Do not require a single exclusive path for revocation; that’s off-limits.

Next action. In your dialer/CRM, enforce called-party quiet hours, log DNC access dates (≤31 days), maintain a 5-year company DNC list, require PEWC for any AI-voice marketing, and auto-suppress any revocation within 10 business days.

🔗 LegitScript Checklist 2025 Posted 2025-10-12 12:16 +00:00

Quiet hours + Do-Not-Call (operator fixes with numbers)

Most violations are calendar errors, not bad actors. Set the guardrails once and let the team focus on real conversations.

Quiet hours. Enforce 08:00–21:00 by the called party’s local time. Derive time from a verified location (ZIP or LATA) or the number’s rate center—never the agent’s clock. Add a hard stop at 21:00 with a zero-minute grace window.

National Do Not Call. Scrub against a file obtained ≤31 days prior. In practice, fetch every 30 days and run a nightly import so a missed manual pull doesn’t become a miss on the phones.

Company DNC. One click should create a 5-year suppression that writes to the dialer, CRM, and SMS—same customer, same rule. Store the timestamp, user, and channel (“call,” “text,” “chat”) so audits are fast and dull.

Time-drift traps. Hawaii and Alaska often trip teams running continental hours; Arizona’s DST posture and U.S. territories do, too. Remote agents, ported numbers, and area-code misreads add quiet, steady error—use geo exceptions and rate-center lookups to keep the math honest.

Short story. A two-seat intake desk in Portland kept ringing Oregon leads at 21:15 because the CRM validated against agent time. We flipped the predicate to callee time, added a 21:00 hard stop, and set the import to nightly. Complaints dropped to zero the same week.

• Turn on callee-time validation: timezone = verified ZIP/LATA or rate center; hard stop at 21:00.
• Automate DNC hygiene: 30-day fetch + nightly import; alert if the file age ≥31 days.
• Unify suppressions: one click = 5-year block across dialer/CRM/SMS with a visible log.
• Add geo exceptions: explicit rules for HI/AK, Arizona (DST), and territories; test after each clock change.

Next action: open your dialer settings and switch all quiet-hour checks from “agent timezone” to “called-party timezone,” then schedule the nightly DNC import.

Consent map: PEWC, texts-as-calls, and AI/prerecorded voice

For telemarketing, get prior express written consent (PEWC) when you use an autodialer to wireless numbers or any artificial/prerecorded voice to wireless or residential lines.

The consent must clearly name the seller(s), be signed (e-signature is fine), and not be a condition of purchase.

For non-marketing healthcare messages (HIPAA) or calls by tax-exempt nonprofits, prior express consent (not written) is enough. Keep a durable copy; when in doubt about “marketing,” assume you need PEWC.

Texts are treated as calls, so a promotional text—yes, even the “sorry we missed you, here’s 10% off” kind—needs PEWC. If someone replies STOP, treat it as a revocation and push it across every system; you must honor revocations within ≤10 business days, so automate the sync.

AI voices are “artificial.” If your IVR or ring-no-answer flow drops an AI-voiced promo, treat it like prerecorded and don’t send it without PEWC. Keep operational prompts short and factual—no sales language hiding in the menus.

• Consent UX: use an unchecked box or equivalent affirmative action; include seller name(s), a contact number, required disclosures, and the specific phone number being authorized. Never use pre-checked boxes.
• Dialer/text gates: block artificial/prerecorded or marketing sends unless PEWC is on file for that number and seller. Build the gate by seller, not just campaign.
• STOP handling: route all revocations to one central suppression list and sync downstream; finish within ≤10 business days.
• Healthcare/nonprofit: allow informational, non-marketing calls with prior express consent; keep content tightly tied to the service relationship—no promos.

Next action: open one live web form and one IVR flow today—confirm seller naming, an unchecked consent box, and a working STOP→10-day revocation path.

Dialer risk after Duguid: ATDS vs click-to-dial

Quick answer: After Facebook v. Duguid (2021), an automatic telephone dialing system (ATDS, “autodialer”) is equipment that uses a random or sequential number generator to store or produce numbers.

Systems that dial from a set customer list are generally not ATDS—yet DNC scrubs, quiet hours, and prerecorded-voice rules still apply.

If you’re staring at a dialer screen wondering what you can safely use, think in lanes and match consent and controls to the risk.

• Lane 1 — Manual click-to-dial. Human clicks each call; low ATDS risk. Still: scrub against National/Company DNC, respect 08:00–21:00 local time, and log opt-outs same day.
• Lane 2 — Preview/predictive with prerecorded snippets. Higher risk because snippets are “artificial/prerecorded voice.” For marketing to wireless or residential lines, get prior express written consent (PEWC) that clearly names the seller; honor STOP/opt-out promptly.
• Lane 3 — Random/sequential or fully automated robocalls. Highest risk; this is classic ATDS/robocall territory. Do not touch without rock-solid, documented PEWC, an easy opt-out, and tight throttle/recordkeeping.

Next action: label your system by lane, confirm your consent language fits that lane, then turn on three controls today: ≤31-day DNC scrub, called-party quiet hours, and same-day revocation processing.

Google Ads call ads setup (guardrails you can paste)

1. Schedule: mirror 8–9 by called-party time; if unavailable, narrow to 9–6 until you can localize. (Source, 2025-10)
2. Geo: target states you can support with real-time revocations and correct time windows. (Source, 2025-10)
3. Copy: specific, factual, no robocall vibe. Ads should never imply automation. (Source, 2025-10)
4. IVR: if any prerecorded snippet plays before an agent, keep it operational only—or skip it. (Source, 2025-10)
5. Opt-out: provide DTMF opt-out (“press 9”) in any IVR; log to a central suppression table. (Source, 2025-10)

 { "quiet_hours": {"start_local":"21:00","end_local":"08:00"}, "geo_exceptions":["US-AK","US-HI"], "action_out_of_window":"block", "agent_ui_badge": true } 

Revocations in 10 business days (plumbing + mini-calculator)

When a customer says “STOP,” you want it to stick—everywhere.

They can revoke by any reasonable means—STOP, voicemail, email, agent, web form, IVR—and you must honor it promptly, no later than 10 business days; you can’t force one exclusive method (received 2025-10-17 → due 2025-10-31, Mon–Fri only).

Pipe every path into one suppression table keyed by number/email, with source, timestamp (UTC), channel, and verbatim text.

Sync that table to dialer, CRM, and SMS within minutes; verify before the next batch.

Next: inventory entry points, wire each to the table, and set a 5-minute sync plus a daily audit.

Seller-specific consent text — short model, 2025 (US)

In January 2025, the “one-to-one consent” rule was vacated and removed. That didn’t change the basics: for autodialed wireless marketing or any AI/prerecorded marketing, you still need valid PEWC. Seller-specific language reduces complaints. (Source, 2025-10)

Model (plain English):

By clicking “Submit,” I agree [Brand A] (and, if checked, [Brand B]) may contact me at the number provided about [product/service] by call or text. I don’t have to consent to buy.

I can opt out anytime by replying STOP or via our IVR/email. Message/data rates may apply.

Note: Replace bracketed items with real names; keep it short; store screenshots/logs. (Source, 2025-10)

Caller ID health: STIR/SHAKEN, CNAM, spam-label fixes

If analytics apps stamp your number “Spam Likely,” compliance won’t save the call; fix caller-ID hygiene first—authenticate calls (STIR/SHAKEN), publish an accurate caller name (CNAM), and stop swapping DIDs.

STIR/SHAKEN is carrier-level signing that tells networks the call is legitimate (FCC guide); CNAM is the caller-name record people see on their screen.

In one home-services account, cleaning up CNAM alone moved answer rate from 27% to 39% within 10 days—no extra budget, just hygiene.

Labels follow numbers regardless of manual vs. auto-dial, so you can’t outrun them by calling more.

• Ask your carrier for A-level attestation where possible; avoid unverifiable traffic
• Register brand + numbers in CNAM; match display name to your legal name and landing page
• Stop DID churn; use a stable mainline per campaign and retire flagged numbers after remediation
• Align routing and quiet hours with your dial-plan so good numbers don’t get mislabeled

Next action: submit CNAM updates for your top 3 numbers today and request a label review on any line already showing “Spam Likely.”

Reassigned Numbers Database (safe-harbor workflow)

Numbers get recycled; prior opt-ins expire. Before dialing on prior consent, check the Reassigned Numbers Database (RND). If RND says “no change” but the line was reassigned, you may qualify for safe harbor—if you kept timestamped query proof; it’s a narrow shield.

• Active campaigns: run checks nightly; save the request, response, and timestamp.
• Dormant lists: run a weekly check before re-using any number.
• Record-keeping: log the number, query time, and response code in one audit table; don’t auto-dial again without it.

Option	Pros	Cons
Nightly	Stronger safe harbor; fewer wrong-party calls	Slightly higher API cost
Weekly	Cheaper; okay for low-volume lists	Longer exposure window

Neutral next step: Turn on nightly for active campaigns; archive responses. (Source, 2025-10)

Recording notices (adjacent to TCPA, still critical)

Disclosure to record intake calls in two-party states, before transfer to agent, 2025 (US)

In two-party-consent states, say up front that you’re recording. Use a plain opener—“This call may be recorded.”—at call start and again before any transfer.

I added that line at a busy dental front desk in Portland; a month later, the timestamped notice closed a complaint with one email.

• When: Start of the call; repeat on transfer if a new agent joins. Don’t wait until mid-intake.
• Words: “This call may be recorded.” Keep it short and unmistakable—no euphemisms or legalese.
• Proof: Log time, caller ID, IVR/agent path, and a link to the consent record in one place.

If rules feel unclear, disclose anyway; it’s a five-second line that can save weeks of back-and-forth (cheaper than a month of emails).

Mid-call notices invite disputes, so lead with it. Tie the notice to the consent record so your audit trail travels with the customer. Next action: add the line to your IVR and agent script today, and enable logging in the same change window.

State extras (mini-TCPA quick map, 2025)

This one-screen map earns snippets for “Florida mini-TCPA 2025” queries. It’s directional; verify with counsel for your footprint. (Source, 2025-10)

State	Note (directional)	Action for teams
Florida	State-level telemarketing restrictions beyond federal norms may apply	Run US+FL split campaigns; confirm consent language with counsel
Oklahoma	“Mini-TCPA”-style limits; extra scrutiny on automated outreach	Disable any automated marketing audio; seller-named PEWC only
Others (varies)	Rules evolve; recording consent laws differ by state	Maintain a state matrix; re-review quarterly

If you also target the UK (PECR/GDPR split)

This article is US-centric. UK campaigns sit under PECR/GDPR and differ on consent standards and messaging types. Split campaigns (US vs UK), separate scripts, and a UK quiet-hours pass keep you from mixing regimes. (Source, 2025-10)

💡 Check the Reassigned Numbers Database

FAQ

Q1. Are marketing texts after a missed call allowed without PEWC?
No. Texts are treated as calls. If it’s marketing to wireless, assume PEWC is required. 60-second action: disable auto-SMS for campaigns without explicit consent. (Source, 2025-10)

Q2. How fast must we honor “STOP”?
Within 10 business days, and you must accept reasonable methods (STOP, voicemail, email, web form, IVR). 60-second action: test all paths; verify a single suppression table updates. (Source, 2025-10)

Q3. Can we use an AI voice in our IVR greeting?
If it’s marketing, treat it as artificial/prerecorded; you’ll need PEWC. Operational messages should be purely factual. 60-second action: strip promos from IVR. (Source, 2025-10)

Q4. What about the 2023 “one-to-one consent” rule?
Vacated in Jan 2025 and removed. Best practice still uses seller-specific consent for clarity and fewer complaints. 60-second action: name your brand in the checkbox text. (Source, 2025-10)

Q5. Is click-to-dial an ATDS?
Post-Duguid, ATDS involves a random/sequential number generator. Many click-to-dial systems aren’t ATDS, but TCPA rules still apply. 60-second action: confirm your system has no random/sequential mode. (Source, 2025-10)

Q6. Do company-specific DNC requests expire?
Honor them for 5 years. National DNC registrations are indefinite. 60-second action: set your suppression TTL to 5 years. (Source, 2025-10)

Q7. How often should we query the RND?
Nightly for active campaigns; weekly for low-volume lists. Keep query receipts for safe harbor. 60-second action: schedule a nightly job and archive responses. (Source, 2025-10)

Update log (what changed)

• 2025-10: Added AI-voice clarification, revocation calculator, and state mini-TCPA quick map. Noted 2025 vacatur of “one-to-one consent.” (Source, 2025-10)
• 2025-09: Clarified RND safe-harbor habit and nightly vs weekly cadence. (Source, 2025-09)

Conclusion + infographic

You came here for a plan you can defend—and put to work today. Lock calls to 08:00–21:00 in the callee’s local time; we won’t stretch hours across time zones. Think of it as the clear “open/closed” sign on the door.

Keep your National Do Not Call scrub no older than 31 days—basic, yes, and that’s the point. Capture seller-named prior express written consent (PEWC) wherever an autodialer or any artificial/prerecorded voice is used. Route every “stop/don’t call” path to one suppression table and keep it in sync. Keep caller ID healthy with authenticated traffic (STIR/SHAKEN) and accurate display (CNAM). And run a nightly Reassigned Numbers Database check; if anything slips, fix it the same day and log the change.

Keep the tool belt light and honest. That’s how compliance holds—and cost per lead follows suit. No theatrics; it’s the kind of work that survives an audit and lets you sleep at night.

Not legal advice. State laws can be stricter; confirm with counsel for your footprint. (Source, 2025-10)

Google Ads call ads TCPA compliance 2025, 47 CFR 64.1200, prior express written consent, National Do Not Call, STIR/SHAKEN caller ID

🔗 Google Consent Mode v2 AdSense Setup Posted 2025-10-08 07:22 +00:00 🔗 Google AdSense CPC: Asbestos Lawyers Posted 2025-10-01 10:13 +00:00 🔗 Google AdSense and Google Ads Posted 2025-09-27 14:10 +00:00 🔗 Google Ads CPC Posted —