Answering calls with an AI receptionist is one thing. Having an AI voice agent call people is another, and in Canada it comes with specific rules. If you're considering AI for appointment reminders, lead follow-up or reactivating past customers, this is the part to get right before you launch.
This is a plain-language overview, not legal advice. Rules change, and your situation may have details that matter. Check with a lawyer before running an outbound calling program.
The short version
- Outbound calls in Canada fall under the CRTC's Unsolicited Telecommunications Rules, which cover telemarketing, the National Do Not Call List, and automated calls.
- The rules for automatic dialing-announcing devices (ADADs) cover equipment that delivers a pre-recorded or synthesized voice message. The safe assumption is that an AI voice agent placing calls falls under these rules.
- Sales or marketing calls made with an ADAD need the person's express consent, even if they're an existing customer.
- Non-sales calls, like appointment reminders, are treated differently, but they still have to identify who is calling.
- Follow-up texts and emails fall under Canada's anti-spam law (CASL), not the telemarketing rules.
- The CRTC is reviewing these rules in 2026, and AI voices are specifically on the table.
Is an AI voice agent an "ADAD"?
The CRTC defines an automatic dialing-announcing device as equipment that can store or produce phone numbers and be used to send a pre-recorded or synthesized voice message. The word "synthesized" has been in the definition for years.
An AI voice agent is more interactive than a classic robocall. It can listen and respond. But it still dials automatically and speaks with a synthesized voice. Until the CRTC or a court says otherwise, the cautious approach is to treat AI outbound calls as ADAD calls. The CRTC's own 2026 consultation asks whether the definition should explicitly cover "software, applications, or technologies that use synthesised voices, recordings, artificial intelligence, or other methods of non-human generated voice messages." That question tells you regulators already see AI calling as part of this area.
Sales calls: express consent comes first
Under the CRTC's key telemarketing rules, a telemarketing call made with an ADAD requires the consumer's express consent to receive that kind of call. The business must be able to prove the consent. Accepted forms include:
- a signed or completed written form,
- oral consent with the recording kept,
- consent through a toll-free number,
- other methods, as long as there is a documented record.
People can withdraw consent at any time.
The "existing customer" trap
Many business owners assume they can call past customers because of the existing business relationship exemption. That exemption is real, but it applies to the National Do Not Call List. It lets you make live telemarketing calls to customers who bought from you in the last 18 months, or asked about your services in the last six months, even if they're on the list (CRTC summary).
It does not replace express consent for sales calls made with an automated or synthesized voice. So a campaign where an AI agent calls past clients to offer a promotion likely needs documented express consent from each person called, even if every one of them is a past customer.
Non-sales calls: reminders, confirmations, service updates
Calls that aren't trying to sell something are treated differently. Examples are appointment reminders, confirming a booking the customer made, or telling someone their technician is running late. Even so, automated calls must still begin by identifying who the call is from and provide contact information, including a phone number where someone can be reached.
The line between "reminder" and "sales call" matters. "Your cleaning is Thursday at 2 p.m." is a reminder. "Your cleaning is Thursday, and while we have you, we're running a whitening special" has become a sales call.
General telemarketing rules still apply
Whether the caller is a person or an AI system, telemarketing calls must follow the general rules (CRTC overview), including:
- Identify yourself and the purpose of the call at the start.
- Call only between 9:00 a.m. and 9:30 p.m. on weekdays and 10:00 a.m. and 6:00 p.m. on weekends.
- Keep an internal do-not-call list and honour requests to stop calling.
- Register with the National Do Not Call List and check it, unless an exemption applies.
Penalties are real. The CRTC can impose administrative monetary penalties of up to $1,500 per violation for individuals and up to $15,000 per violation for businesses.
Texts and emails: that's CASL
If your AI workflow sends a follow-up text or email after a call, that message is a commercial electronic message under Canada's Anti-Spam Legislation. CASL has its own consent rules, including implied consent for existing business relationships within set time limits, and it requires identification and a working unsubscribe option. Voice calls themselves are covered by the telemarketing rules above, not CASL.
What the 2026 CRTC consultation could change
On June 11, 2026, the CRTC opened Compliance and Enforcement Notice of Consultation 2026-132. It is the first major review of the unsolicited telecommunications framework since 2014. Among the questions it asks:
- Whether the ADAD definition should explicitly cover AI and other non-human voices.
- Whether telemarketers should have to tell people at the start of the call that they are not speaking to a live person.
- Whether the identification message should keep requiring both a mailing or email address and a phone number.
Comments closed in the summer of 2026. Any new rules will come later. It's reasonable to expect AI disclosure to become an explicit requirement, so building it in now costs little.
A practical checklist for AI outbound calls
- Classify each campaign. Is it a reminder or service call, or is it selling something? Write it down.
- For sales calls, collect express consent first. Add a clear consent line to intake forms and booking flows, and store the record.
- Disclose AI at the start. "Hi, this is the automated assistant for [your business], calling about your appointment..." is clear and costs you nothing.
- Identify the business and give a callback number in every automated call.
- Respect calling hours and honour do-not-call requests right away.
- Keep records: who was called, when, the consent basis, and the outcome.
- Treat texts separately under CASL.
- Get legal advice before your first sales campaign.
How we handle this at Vocemi
Our lead reactivation workflows start with the contact list, the consent basis and the script, before anyone is called. The business decides who may be contacted and under which rules. The agent stays inside the approved message. And campaigns can be limited to people who have given the consent the call requires. If a list doesn't meet the rules, we'll say so before launch.
Questions about a specific campaign? Get in touch.