On July 20, Pennsylvania Governor Josh Shapiro signed Senate Bill 992 (the Bill) into law, with an effective date of October 19, 2026. The amendments modernize the Telemarketer Registration Act (the Act) for the first time in almost three decades to address today’s technology, including robocalls, text messages, ringless voicemails, and AI-generated messaging and impose new compliance obligations on businesses that contact Pennsylvania consumers by phone or text. Significant changes are discussed below.

Expanded Definitions Broaden the Law’s Reach

• The prior law focused narrowly on telephone calls. The updated Act replaces the term “telephone solicitation call” with “telephone solicitation,” defined to include: telephone calls, voicemails, ringless voicemails, and text messages.
• The prior definition of “robocall” was limited to calls made using a computerized autodialer to deliver a prerecorded telemarketing message. The new definition is broader: a robocall is any telephone solicitation that uses an automated dialing system to deliver prerecorded or artificial voice calls or messages. This language aligns more closely with federal standards under the Telephone Consumer Protection Act and captures AI-generated voice calls.
• The definition of “telemarketer” has been updated to cover persons or businesses initiating or receiving calls or messages to or from residential, business, or wireless telephone subscribers (not just consumers) in Pennsylvania.

A New Consent Standard

One of the most significant additions to the Act is the new defined term “prior express written consent,” which is defined to mean having a written agreement between the called party and the seller that:

1. Identifies the specific telephone number being authorized for contact;
2. Includes a clear and conspicuous disclosure that the called party is consenting to receive telephone solicitations, including robocalls or text messages;
3. States that consent is not a condition of purchasing any property, goods, or services; and
4. Is signed by the called party, which may include an electronic or digital signature consistent with the federal E-SIGN Act.

Under the revised Act, robocalls can only be made where “prior express written consent” exists. Verbal consent or implied consent from a prior business relationship is no longer sufficient to authorize robocalls.

Additionally, communications made pursuant to “prior express written consent” are expressly not considered a “telephone solicitation” and therefore are generally not subject to the quiet-hour restrictions. However, this exemption requires documented evidence. If you cannot produce a consent record for a Pennsylvania number, treat the consent as absent.

New Prohibited Acts

The Bill makes varies amendments to the Act’s Unlawful Acts and Penalties section (§ 2245), and adds three new categories of prohibited conduct:

• Robocalls Without “Prior Express Written Consent.”
  • It is now unlawful to initiate or cause to be initiated a robocall to any residential, business, or wireless telephone line without the “prior express written consent” of the called party, unless the call is for emergency purposes or is otherwise exempt under the Act.
• Deceptive or Unfair Consent Practices.
  • Telemarketers may not use unfair or deceptive acts or practices in an effort to obtain a subscriber’s consent to receive telephone solicitations or messages. Consent must be obtained honestly and transparently.

• AI and Synthetic Messaging Fraud.
  • The Act now expressly prohibits using any technology or any synthetic or computer-generated messaging to defraud, deceive, or mislead a residential, business, or wireless subscriber. This provision directly targets AI-generated voice cloning and deepfake audio used in scam calls, and likely will be read as prohibiting caller ID spoofing, including “neighbor spoofing” a consumer’s own area code, aligning Pennsylvania with the federal Truth in Caller ID Act.

Calling Hours Restricted Further

The permitted calling window has been narrowed. Under the amended Act, telemarketers may not initiate or cause to be initiated a telephone solicitation:

• On Sundays (previously calls on Sunday were permissible, subject to the general time restriction).
• After 7 p.m. (previously 9 p.m.).
• Before 9 a.m. (previously 8 a.m.).

Businesses that currently call anytime on Sunday or before 9 a.m. or after 7 p.m. on the remaining days of the week will need to adjust their outreach schedules before the Act takes effect. Importantly, quiet-hour suppression must be keyed to the recipient’s location, not the operations center’s time zone.

Text Message Opt-Out Now Expressly Addressed

The amended Act adds a specific opt-out mechanism for text message solicitations. A subscriber may opt out of receiving text message solicitations by replying with any of the following words: “stop,” “quit,” “end,” “revoke,” “opt out,” “cancel,” or “unsubscribe.”

A seller or telemarketer that has established and implemented written opt-out procedures that comply with the above opt-out process, trained personnel on those procedures, and maintained do-not-contact lists will not be liable for a violation if a subsequent contact results from an error.

Caller ID Blocking Prohibition Strengthened

The Act’s section dealing with the blocking of caller identification (§ 2245.1) is updated to also prohibit a telemarketer from taking any action with the primary intent to falsely identify the telemarketer’s name or telephone number to any recipient. The prior version of this section included a limiting clause tied to whether the equipment was capable of transmitting the telemarketer’s identity. That limitation has been removed, creating a broader prohibition.

Additionally, the Act extends the current prohibition against circumventing, bypassing, or disabling any product or service the subscriber uses to screen calls to also cover messages.

Registration Requirements Clarified

The Act’s registration requirement is updated in a couple important ways:

• Under the current Act, neither the terms “telemarketer” nor “telemarketing” are limited by the term “telephone solicitation call.”  This means that on the face of the current Act, it is possible to qualify as a telemarketer and be subject to the registration requirement while not making a “telephone solicitation call.”  The Bill addressed this by limiting the scope of the terms “telemarketer” or “telemarketing” to the new term “telephone solicitation.”  Therefore, if a communication is excluded from the scope of the term “telephone solicitation”, the person making the communication does not qualify as a “telemarketer” and therefore is not subject to the registration.
• The exemptions previously embedded within the definition of “telemarketer” are reorganized into a new dedicated registration exemption section, located in § 2243, covering the same 12 historical categories, plus a new thirteenth exemption that is an expressed exemption for any person engaged in communications that do not constitute “telephone solicitations”.
• Since the revised Act expressly excludes from the registration requirement any person not making a telephone solicitation, having “prior express written consent” for all recipients is functionally a new registration exemption.

Enforcement

The Act imposes civil penalties of up to $1,000 per violation, rising to $3,000 per violation where the consumer is 60 years of age or older. Violations of the Act also constitute violations of Pennsylvania’s Unfair Trade Practices and Consumer Protection Law (UTPCPL), which carries a private right of action and permits recovery of actual damages or $100, whichever is greater.