§1
The agent says it's AI. Every call, first thing.
The FCC has ruled AI voices are artificial voices under the TCPA. Disclosure isn't a courtesy — it's the price of admission. A system with a 'sound human' mode is a lawsuit with a dial tone.
The Governed Outbound Standard
AI will make the calls. The only question is what governs it.
Every plaintiff firm is about to run outbound at machine scale — reactivation, document-chase, retainer-chase, intake. Done ungoverned, that's the next TCPA class-action wave, and the defendants will be law firms. Done governed, it's how stalled dockets get worked and claimants get answered at 9pm. These are the eight rules we believe any governed system must meet. Hold your vendors to them. Including us.
§2
The consent floor has no override.
Not for an admin. Not for a supervisor. Not for the vendor. If anyone at the firm can switch off the consent and do-not-call checks on a busy day, the firm doesn't have a compliance system — it has a compliance suggestion.
§3
Calling hours follow the claimant's clock, statute attached.
The stricter of the federal window and the claimant's own state rule, computed in their timezone, with the citation on file so counsel can audit the rule — not just the outcome.
§4
Stop means stop. Everywhere. Immediately.
An opt-out on any channel ends contact on every channel. There is no re-enrollment path around a suppression record, and no cadence that outlives a 'stop.'
§5
When in doubt, it doesn't dial.
Missing timezone, unattested consent, ambiguous status — a governed system holds the touch and waits for a human. Ungoverned systems default open and apologize later. Defaults are the whole game.
§6
Every decision leaves a record someone else can verify.
Tamper-evident, independently checkable, exportable. If the vendor's answer to 'prove it' is 'trust us,' the record isn't a record.
§7
Rules decide. The model never does.
Language models conduct the conversation; written, versioned criteria make every qualification decision — and rehearse in simulation before touching a real claimant.
§8
The firm holds the wheel.
Live transcripts, mid-call takeover, the firm's own scripts and criteria, the firm's own data. A tool the firm operates — never a black-box service dialing on its behalf.
Published by Compensable, 2026. Use it in your vendor diligence — no attribution needed. The questions matter more than who wrote them down.
Hold us to it.
We'll run a live call, work a sample docket, and show you the system refusing a call it shouldn't make.