EPIC Joins NCLC in Calling Upon FCC to Require Consent and Disclosures for AI-Powered Robocalls

On November 15, EPIC joined Consumer Federation of America and Public Knowledge on reply comments submitted to the Federal Communications Commission by the National Consumer Law Center (NCLC) regarding proposed consent and disclosure requirements for robocalls in which AI is used. Building on their initial comments, the consumer advocacy groups articulated a tiered approach based on risk, such as whether the call requires prolonged interaction from the consumer or merely broadcasts information (e.g. an appointment reminder) or whether the call uses AI to impersonate a specific individual. The reply comment outlined numerous sources of authority regarding the need for protections for consumer interactions with AI and also outlined the FCC’s authority under the TCPA to promulgate rules to that effect.

EPIC routinely participates in regulatory and legislative processes concerning robocalls and files amicus briefs in robocall cases. EPIC has also published two reports, Generating Harms and Generating Harms II, explaining why Generative AI needs strong safeguards.