§1
The agent says it's AI. Every call, first thing.
The FCC has ruled AI voices are artificial voices under the TCPA. Disclosure is 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.
All of plaintiff law 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 Floor has no override.
Not for an admin, a supervisor, or the vendor. If anyone at your organization can switch off the consent and do-not-call checks on a busy day, you have a compliance suggestion, not a compliance system.
§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 as well as 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.
When the timezone is missing, the consent unrecorded, or the status ambiguous, a governed system holds the call 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
You hold the wheel.
Live transcripts, mid-call takeover, your own scripts and criteria, your own data. A tool you operate, never a black-box service dialing on your behalf.
Published by Compensable, 2026. Use it in your vendor diligence; no attribution is 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.