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Must an AI receptionist say it's AI? Disclosure and recording rules

We found no federal rule that makes an AI answering your phone say what it is, but some states have rules, and recording law is stricter. What each law says, and a greeting that covers both.

By Sam, the owner14 November 202616 min read

A dental hygienist talking with a patient in the treatment chair
The short answer

Does an AI receptionist have to disclose it is AI? We found no federal rule that requires it on calls a dental office receives. Some states do have rules, such as Maine, Utah and Texas. Recording is a separate question, and several states want everyone's consent. The cautious set-up covers both: the greeting says it's an AI assistant and that the call is recorded, it never claims to be a person, and callers can reach one.

General information, not legal advice. Last checked: 14 November 2026. Each law links to the text we read, and the note at the end says how each one was read.

Most pages for this search come from sellers of AI phone software, and they don't agree on which states have rules. So this post goes to the laws themselves. We sell one too, our AI receptionist for dental practices, and what ours does is near the end. New to the idea? Start with what an AI dental receptionist is.

Disclosure, recording and privacy: three different questions

Each has its own law, and a yes on one tells you nothing about the others.

  1. Must it say it is an AI? Disclosure laws. We found no federal rule for answered calls, and a few state laws.
  2. May the call be recorded? Recording laws: the federal one, your state's, and sometimes the caller's state's.
  3. Is the patient's information protected? That is HIPAA, the federal patient privacy law, and it has its own post: is an AI receptionist HIPAA compliant?

Does an AI receptionist have to disclose it is AI under federal law?

For a call your office receives, we found no federal law or rule that requires it. Two federal texts come up in almost every article on this.

The FCC's 2024 ruling is about calls you make

In February 2024 the Federal Communications Commission (FCC) ruled that AI-generated voices count as "artificial" voices under the Telephone Consumer Protection Act. A business that places such a call needs the prior express consent of the person it calls, unless the call is for an emergency or an exemption applies. In August 2024, in a proposal for new rules, the FCC wrote that the Act's requirements do not extend to technology used to answer incoming calls.

That proposal would also make callers say, at the start of each call they place, that it uses AI-generated technology. We found no final rule. So the FCC matters if AI ever places calls for you, such as reminder or recall calls.

Recording: federal law needs one party's consent

Under the federal wiretap law, 18 U.S.C. 2511(2)(d), a person who is on a call may record it, and so may someone who has one party's prior consent, unless the recording is made to commit a crime or a civil wrong. Some states ask for more, so they have their own table below.

Which states require an AI receptionist to say it is AI?

These are the state laws we could read on 14 November 2026. The list is not complete, and new laws keep arriving, so use it as a starting point, not as a verdict for your state.

State and lawWho it coversWhat it asks forIn force since
Maine: 10 M.R.S. section 1500-DDAnyone who uses an AI chatbot, typed or spoken, or other computer technology to do business with a consumer.Don't use it in a way that may lead a reasonable consumer to think they are dealing with a human, unless they are told clearly and conspicuously that they are not. A breach counts under Maine's Unfair Trade Practices Act.A 2025 law (Public Law 2025, chapter 294)
Utah: Utah Code 13-77-103 and 13-77-104A business that uses generative AI with a person in a consumer transaction. Also licensed or state-certified professionals regulated by Utah's Department of Commerce, when they use generative AI to provide their services.Say it is AI and not a human when a person clearly asks. In a "high-risk" interaction, which the definitions say includes collecting health data, the licensed professional must say so out loud at the start. A business that discloses clearly at the start, and throughout, that it is an AI assistant is protected from enforcement under these sections.7 May 2025. The definitions were amended in May 2026.
Texas: HB 149, Business and Commerce Code section 552.051Government agencies. Also the provider, when an AI system is used "in relation to" a health care service or treatment given by a licensed person.Tell the person they are dealing with an AI system, clearly and conspicuously and in plain language, even if it would be obvious. In health care, no later than the day the service is first provided, or as soon as reasonably possible in an emergency.1 January 2026
California: Health and Safety Code section 1339.75 (AB 3030)A health facility, clinic, physician's office or physicians' group practice that uses generative AI for messages about a patient's clinical information. Appointment scheduling, billing and other clerical or business matters are left out.A notice that AI generated the message, spoken at the start and the end of an audio interaction, plus how to reach a person. Not needed when a licensed provider has read and reviewed the message.1 January 2025

Not in the table: Colorado's SB 24-205 disclosure rule had its start moved to 30 June 2026, and in May 2026 it was repealed and re-enacted by SB 26-189, which is about technology used in decisions such as access to health care. Hawaii's 2026 law, SB 3001, which some seller pages cite, covers "AI companions" built for an ongoing personal relationship. California's 2019 "bot" law defines a bot as an automated online account, and its auto-dialer law (AB 2905) is about calls placed, not answered. None of these seems written for a front-desk line.

How each one may touch a dental office

  • Maine. A natural voice with a person's name could lead a caller to think they reached a person. The cautious reading: say "I'm an AI assistant" up front.
  • Utah. At the least, it must tell the truth when asked. A caller who describes a toothache is sharing health information, so ask your adviser whether the up-front rule for licensed professionals reaches your phone line.
  • Texas. The text does not say whether answering the phone counts as use "in relation to" care. The cautious choice is the line in the greeting.
  • California. The law takes its meaning of "clinic" from section 1200, which mentions dental treatment. But section 1206 keeps offices owned and run by licensed practitioners out of that chapter, and the enforcement part names the two medical boards, not the Dental Board. Whether it reaches a private dental office is a question for a lawyer. It also leaves out scheduling, which covers many front-desk calls.
  • Everywhere else. We found nothing, or did not read it. One sentence in the greeting costs nothing if a law arrives.

Call recording laws for a dental office: who has to agree?

An AI receptionist often records calls and writes them down, so your team can check each message. Seller pages give different counts of "two-party consent" states, because a few states have a twist. "RCFP" below is the Reporters Committee for Freedom of the Press guide, written for journalists and last updated for these states in 2019 and 2020, so treat it as a pointer.

StateRule for recording a phone callWhere we read it
CaliforniaConsent of all parties to a confidential call, and for any call with a cell or cordless phone on it. A first offense can bring a fine of up to $2,500 per violation, and the person recorded can sue for $5,000 per violation or three times their actual damages, whichever is greater.Penal Code sections 632, 632.7 and 637.2
Florida, MarylandLawful when all parties have given prior consent.Fla. Stat. 934.03(2)(d), Md. Courts and Judicial Proceedings 10-402(c)(3)
Illinois, MassachusettsNo secret recording without the consent of all parties. The Illinois text is about private conversations.720 ILCS 5/14-2, Mass. General Laws chapter 272, section 99
New HampshireConsent of all parties. Without it, recording is a crime, even for a person who is on the call.RSA 570-A:2
PennsylvaniaConsent of all parties, per RCFP. It adds that courts find consent when people knew, or should have known, the call was being recorded.RCFP. The state's statute site would not show the text to us.
WashingtonConsent of all participants. It counts as given when one party announces that the call is about to be recorded, and the announcement is recorded too.RCW 9.73.030
MontanaNo recording with a hidden device without the knowledge of all parties. The rule does not apply to people given warning of the recording.Montana Code 45-8-213
ConnecticutTwist: a civil rule. It asks for all parties' consent, or a spoken notice recorded at the start of the call, or a warning tone about every 15 seconds.General Statutes 52-570d
NevadaTwist: the statute allows one-party consent on a phone call only in an emergency. RCFP reads it as all parties for a phone call.NRS 200.620, RCFP
DelawareTwist: two laws that don't agree. The privacy law says all parties, and RCFP advises following it.11 Del. Code 1335(a)(4), RCFP
MichiganTwist: courts disagree on whether a person on the call may record it without the others' consent, per RCFP.RCFP only

We did not check every other state. Where a state has no stricter rule, the federal one-party rule is the floor.

An announcement does much of the work. Washington's, Connecticut's and Montana's statutes each make room for a spoken notice or warning. California's main rule covers "confidential" calls, and leaves out calls where people can reasonably expect to be recorded. So "this call is recorded" belongs in the first sentence, before the caller says anything private. Whether that is enough in your state is a question for your adviser.

Callers cross state lines. We found no single rule that settles whose law applies when a patient calls from another state, so a cautious habit is to follow the strictest rule on every call.

Recordings are patient information too. HHS's summary of the Privacy Rule says it protects identifiable health information in any form, oral included, whether your practice holds it or a company working for you does. Its business associates page lists, as one example of a business associate, a vendor's chatbot on a patient portal that handles things like appointment scheduling. So ask who keeps your recordings, and for how long.

A lawsuit dental offices should know about

In July 2025 a patient filed a proposed class action in federal court in Illinois against a large dental support organization and its cloud phone provider. She alleged that the provider's AI monitored her calls to a dental practice without her knowledge or consent, in breach of the federal Wiretap Act (Sheppard Mullin's summary). The judge dismissed the claims in January 2026 and, after an amended complaint, dismissed the case with prejudice on 24 July 2026, Becker's Dental Review reported. The court docket shows the case closed that day. The companies won, but the case ran for a year. Telling callers up front costs one sentence.

What a careful AI receptionist greeting sounds like

This example is written for Bright Smile Dental, a made-up demo practice. Change the wording to fit yours.

  1. Receptionist:Thanks for calling Bright Smile Dental. I'm the practice's AI assistant, and this call is recorded. How can I help?

And when a caller asks:

  1. Caller:Am I talking to a real person?
  2. Receptionist:No, I'm an AI assistant for the practice. I can take a message, and the front desk will call you back.

It says what it is and that the call is recorded before the caller shares anything. Our phone scripts post has greetings you can copy. To check any vendor yourself, make test call 10: ask if it is a real person.

What an AI receptionist should never say

  • That it is a person, or a job title that implies one, such as "I'm the office manager."
  • Anything clinical: what is wrong, what to take, or whether it can wait.
  • That the call is not recorded when it is.

A disclosure and recording checklist for your practice

  1. The greeting names the practice.
  2. It says it is an AI or automated assistant, in the first sentence.
  3. It says the call is recorded, before the caller shares anything.
  4. Asked "are you a real person?", it tells the truth.
  5. Callers have a way to reach a person: a message with a call back, or a transfer.
  6. It gives no clinical advice, and it tells callers with a life-threatening emergency to call 911.
  7. Recordings are kept for a set time and then deleted.
  8. A business associate agreement is signed before the first patient call.

Then show the greeting and this list to your own adviser, and check your state's law.

What ours does, and what it doesn't

We're a small, new US company, run by Sam (short for Ibtisam), the owner. Here is our receptionist against that checklist.

  • Recording. Calls are recorded, so you can check every message yourself. The caller is told the call is recorded, and the recording is kept only for your practice. Call records are deleted automatically 90 days after each call, unless you choose a different period.
  • Saying it is AI. If a caller asks, it says it is an AI. That is less than line 2 of the checklist, and we say so plainly.
  • Reaching a person. By default it takes a message and alerts your team, and your front desk calls back. If you ask for it, it can also put the caller through to a number you give us. We test that by phone first, and if a transfer fails, it takes a message.
  • No clinical advice. It never gives medical advice. For a life-threatening emergency, it tells the caller to call 911.
  • Paperwork. Before the receptionist answers any patient call, we sign a business associate agreement (a BAA) with your practice. Our voice platform has signed a BAA with us.
  • Outgoing calls. It only answers calls. It does not call or text your patients.
  • Your part. Please check that the recording notice is enough for your state's call-recording law. We can't do that for you.

Hear it before you decide. Call Sophie, our demo receptionist, at (631) 502-5443, and ask her if she is a real person. She answers for Luxe Dental, a demo practice. On the demo line she books into a sample calendar, so nothing booked is real. A new practice starts with messages. Calls to the demo line are recorded and written down, so use made-up details.

A practice can try its own receptionist on its real calls, free for one week. If you don't want to keep it, tell us before the week ends and you pay nothing. To talk it through, book 15 minutes with Sam. There are more questions on our FAQ page.

Common questions

Does an AI receptionist have to tell callers it is AI?

For calls a business receives, we found no federal rule that requires it. Some states have rules: Maine's applies when a caller could think they are talking to a person, and Utah's applies at least when a caller clearly asks. The simple answer is to say it in the greeting.

Is it legal for a dental office to use an AI receptionist?

We found no law that stops a dental office from having AI answer its phone. The laws we read are about telling callers the truth, getting consent to record, and protecting patient information. State rules differ, so check yours with your own adviser.

Can a dental office record patient phone calls?

Federal law allows a call to be recorded when one party consents. Several states ask for every party's consent, and some accept a spoken notice at the start of the call. A cautious practice says in the first sentence that the call is recorded, and checks its own state's statute.

Which states require everyone's consent to record a call?

From the statutes and guides we read: California, Florida, Illinois, Maryland, Massachusetts, Montana, New Hampshire, Pennsylvania and Washington. Nevada is read that way for phone calls. Connecticut, Delaware and Michigan each have a twist, which is why published counts differ. We did not check every state.

Does the FCC's AI voice rule apply to a dental office?

The FCC's February 2024 ruling is about calls placed with an AI voice, such as reminder or recall calls. Those need the called person's prior express consent, unless an emergency or an exemption applies. In August 2024 the FCC wrote that the law's requirements do not extend to technology that answers incoming calls.

Does California's AI health care law apply to dental offices?

It names health facilities, clinics, physicians' offices and physicians' group practices, and it leaves out scheduling, billing and clerical matters. Its clinic definition mentions dental treatment, but another section keeps practitioners' own offices out of that clinic chapter. Ask your own lawyer rather than assume either way.

Does HIPAA cover call recordings?

HHS says the Privacy Rule protects identifiable health information held by a practice or a company working for it, in any form, oral included. A recording with a patient's name and reason for calling fits that description. A company that keeps those recordings for you generally needs a business associate agreement with your practice.

General information, not legal advice. Laws change, and your state may have rules we did not find. All sources were read on 14 November 2026: most on the official sites linked; the federal wiretap law on Cornell Law School's copy of the U.S. Code; Utah's sections 103 and 104 on Justia's copy of the 2025 Utah Code. The Texas, Florida, Illinois, Massachusetts, Washington, Connecticut, New Hampshire, Nevada and Hawaii sites, and Utah's definitions page, would not load for us, so we read the Internet Archive's copies of those official pages, saved between July and November 2026. Texas was read as the bill as passed, and Hawaii as the final bill text. The Pennsylvania and Michigan statutes could not be opened. Spotted an error? Email [email protected].

Try it now

Hear Sophie answer your question

Call our demo line any hour, any day. Ask about hours or insurance, or leave a message, the way a patient would.

Sophie answers for Luxe Dental, a demo practice. On the demo line she books into a sample calendar, so nothing booked is real. A new practice starts with messages.