Tennessee robocall law 2026: the 500-call reports and 10,000 cap

Tennessee’s new robocall law makes anyone who sends prerecorded or artificial-voice sales calls to Tennessee homes count them every month. At 500 or more a month, you must report the counts to the state’s Public Utility Commission twice a year, starting with a report due 1 Apr 2027. Nobody may make more than 10,000 such calls a month.

The rules come from Public Chapter 1029 (House Bill 2408 and Senate Bill 2659), which adds section 65-4-411 to the Tennessee Code. The Tennessee Public Utility Commission (TPUC) explained the schedule in a public notice to telephone solicitors. Everything below is as of October 2026.

What section 65-4-411 says

The new section has three parts, and they start on different dates.

Rule	From	Who it applies to	Enforced by
Keep a record of how many such solicitations you make each month	1 Jul 2026	Anyone making them	TPUC
Send copies of those records to TPUC every 6 months	1 Oct 2026	Callers making 500 or more a month	TPUC, under the Do Not Call Act
Hand over the records on request	1 Oct 2026	Callers making 500 or more a month	TPUC or the Attorney General
Make no more than 10,000 a month	1 Jul 2026	Anyone	Attorney General, under the Consumer Protection Act

“Such solicitations” has a specific meaning here: telephone solicitations made with an automated telephone dialing system to deliver artificial or prerecorded voice messages to residential subscribers in Tennessee.

TPUC’s notice sets the reporting dates as 1 Apr and 1 Oct each year, with the first report due 1 Apr 2027. Breaking the 10,000 cap is an unfair or deceptive act under the Tennessee Consumer Protection Act of 1977, and the act sets a civil penalty of at least US$1,000 per violation.

Who it covers, and who it doesn’t

The law is narrower than its headlines. Three tests decide whether a call counts.

1. It is a telephone solicitation. Section 65-4-401 defines that as a call to encourage buying or investing in goods, services or property. The same definition leaves out calls made with the subscriber’s prior express permission, calls to existing customers with a business relationship in the last 12 months, and some calls by tax-exempt nonprofits.
2. It delivers an artificial or prerecorded voice. A rep talking live is not covered by this section.
3. It goes to a residential subscriber in Tennessee. Calls to business lines fall outside the wording of this section.

Whether your consented calls drop out of the count, and how a mobile used for both home and work is treated, are questions for your counsel. The law does not answer them in so many words, so a cautious team counts first and asks second.

Why AI voice agents belong in the count

Tennessee’s text says “artificial or prerecorded voice”. It does not mention AI. The FCC, however, decided in FCC 24-17 (Feb 2024) that AI-generated voices are “artificial” voices under the federal TCPA.

So if an AI voice agent places sales calls to Tennessee homes, assume those calls sit inside the Tennessee count. Federal law already requires consent for them. Under 47 CFR 64.1200, an artificial or prerecorded voice telemarketing call to a residential line needs the person’s prior express written consent. Reps make cold calls; AI agents call people who agreed to it. Our guide to AI voice agent consent rules covers the federal side in full.

A worked example

This example uses made-up numbers.

A home services company runs an AI appointment-setting agent. It calls people who filled in a quote form and ticked a consent box, plus a monthly reactivation campaign to past customers. In November it places 1,800 calls to Tennessee numbers:

• 1,100 to new leads with written consent;
• 600 to customers from the last 12 months;
• 100 to old customers from 2023, with no recent consent.

If counsel advises counting everything with an artificial voice, the company is over 500 a month and must keep records and report to TPUC on 1 Apr 2027. Under a narrower reading that drops consented calls and recent customers, the count is 100, and the real problem is different: those 100 calls likely have no valid consent under federal rules. Either way, the 10,000 cap is far away.

The useful point of the example: the count is easy if every call is tagged with the contact’s state, the voice type and the consent basis when it is placed. It is painful to rebuild from a phone bill in March.

What to do before 1 Apr 2027

1. Tag Tennessee contacts. Use the number and the address, since people keep numbers when they move.
2. Mark the voice type on every call. Live rep, prerecorded message, or AI agent.
3. Store the consent basis with the call. Written consent, existing customer within 12 months, or none.
4. Run a monthly count of artificial or prerecorded voice solicitations to Tennessee residential numbers, starting with July 2026.
5. Set an alert at 400 a month so you know before you cross 500, and a hard stop well below 10,000.
6. Ask counsel which calls count, and how TPUC wants the records sent.
7. Keep the state’s own list in view. Tennessee runs its own do-not-call/text program, separate from the federal registry.

If you call into several states, the Pennsylvania telemarketing law changed on 18 Oct 2026 too, and our guide to state telemarketing calling hours collects the state calling windows.

How DialSavvy handles this

DialSavvy runs compliance checks before every call: calling hours in the contact’s time zone and your do-not-call list. Every call is itemized on your bill. DialSavvy Agents is in early access, and we build the first agent with you, including who it may call. Per-state US rules and AI-voice consent checks are coming, so for now keep Tennessee contacts in their own list and run the monthly count yourself.

If you run AI agent calls into Tennessee, book a demo and bring a month of call data. We’ll walk through how you would count it.