Why Canada’s Cell Phone Rules Are Changing Now

Canada's telemarketing rules were built for a world of physical dialers and call centers — not for AI voice agents that can place thousands of calls from a cloud subscription. That gap is exactly why the CRTC is rewriting the rulebook right now, and why any business running outbound calls needs to pay attention.

The CRTC's Unsolicited Telecommunications Rules (UTR), first established in 2007, have not seen a substantive update since 2014. That matters because the rules define automated calling around hardware — equipment, dialers, physical systems. As M3AAWG's formal intervention to the CRTC puts it, "someone can spin up thousands of AI-generated voice calls using nothing more than a cloud subscription, a language model, and a list of phone numbers. There's no hardware, no physical dialer, no 'equipment' in the sense the old rules imagined."

The stakes are real. Under the current UTR framework, penalties reach $15,000 per call for corporations, and vicarious liability means a business can be held responsible when a vendor or lead generator breaks the rules calling on its behalf.

Under Notice of Consultation 2026-132, the CRTC is actively reviewing the UTRs. The proposed changes, drawn from stakeholder filings, include:

• Expanding the definition of automated calling to explicitly cover AI-generated voices
• Requiring upfront disclosure when a call is made by an AI
• Tying consent to individuals rather than phone numbers
• Requiring identification of both the calling platform and the hiring business
• Retiring outdated distinctions like sequential versus random dialing

The most significant shift is philosophical. M3AAWG argues the rules should be built around outcomes, not mechanisms — the question is no longer what hardware placed the call, but whether someone received an unwanted automated call "without meaningful consent, without disclosure, and without anyone accountable for it."

These proposals are still under review, not enacted law. But the direction is clear, and waiting for final rules is a poor strategy. Businesses that already verify consent records before calling, disclose AI use on every call, and honor opt-outs immediately will face little disruption when the new rules land.

This is why My AI Call Center reviews list sources and consent records before any campaign launches, and flags bought lists without clear permission records. Under the proposed framework, accountability follows the hiring business — a vendor's violation becomes your violation. Building those habits now costs far less than retrofitting them later.

Plan a compliant outbound campaign with reviewed, permissioned lists — from 9¢ per connected minute.

What the New Rules Mean for AI Voice Calls and Consent

If an AI voice places a call in Canada today, regulators don't treat it as a clever new technology — they treat it as a robocall. That single framing drives most of the compliance risk for any business running AI-assisted outbound calling.

Canada's Unsolicited Telecommunications Rules govern voice telemarketing, and automated calls fall under the Automatic Dialing-Announcing Device (ADAD) provisions. Companies are prohibited from using an ADAD to call any Canadian number unless express consent has been provided — and that consent must clearly evidence the consumer's authorization, including the specific number called.

The timing matters as much as the consent itself. AI voice agents placing calls without prior express consent may violate ADAD rules, and consent must be obtained before the call is placed, not after the recipient answers. Penalties reinforce the stakes: up to $1,500 per call for individuals and $15,000 per call for corporations under the UTR. And because vicarious liability applies, a business that hires a vendor can be held liable for that vendor's violations.

The CRTC's current framework hasn't been substantively updated since 2014, which is why the agency opened a review under Notice of Consultation 2026-132. M3AAWG, an industry association representing over 200 member organizations, filed a formal intervention in July 2026 proposing changes aimed squarely at AI calling:

• Expanding the definition of automated calling systems to explicitly cover AI-generated voices
• Requiring upfront disclosure when a call is made by an AI
• Requiring identification of both the calling platform and the hiring business
• Treating consent as tied to individuals rather than phone numbers

These proposals remain under review — they are not yet enacted law. But M3AAWG's core argument signals the regulatory direction: "Rules should be built around outcomes, not mechanisms." The question is whether a person received an unwanted automated call without meaningful consent, disclosure, or accountability — not what hardware placed it.

This is where operational discipline separates compliant campaigns from risky ones. My AI Call Center reviews list source and consent records before any campaign launches, flagging or declining bought lists without clear permission records — directly addressing the ADAD consent requirement, which is the highest-risk element of Canadian rules.

Its call handling also mirrors the proposed disclosure requirements. AI disclosure appears on every call, recipients can request a human or opt out with keywords like STOP, and opt-outs are logged and honored immediately, then carried into client DNC records. Businesses running outbound campaigns should treat consent verification, upfront AI disclosure, and instant opt-out handling not as future requirements, but as today's baseline.

How to Stay Compliant Across Voice and Text Channels in Canada

Running outbound campaigns in Canada requires navigating two distinct regulatory frameworks: the CRTC's Unsolicited Telecommunications Rules (UTR) for voice calls and Canada's Anti-Spam Legislation (CASL) for SMS and electronic messages. Assuming US TCPA compliance is sufficient creates significant risk, as Canada's rules operate independently and cover different channels. For example, CASL penalties can reach up to $10 million for a first violation, while UTR violations carry fines of up to $15,000 per call for corporations. This split means a campaign combining calls and texts must secure separate consent for each channel to remain compliant.

Voice calls under the UTR require prior express consent for automated dialing, adherence to strict calling windows (weekdays 9:00 a.m.–9:30 p.m.; weekends 10:00 a.m.–6:00 p.m.), and compliance with the National Do Not Call List (DNCL). Telemarketers must use a DNCL version no more than 31 days old and stop contacting registered numbers within 31 days of registration. Equally critical is maintaining an internal DNC list, where opt-out requests must be processed within 14 days and retained for three years and 14 days — the DNCL alone does not substitute for this internal tracking. For multi-touch campaigns like a Database Reactivation Blitz, this means tracking call consent and text consent separately, honoring opt-outs in real time via keyword triggers like STOP or REVOKE, and ensuring AI disclosure is provided on every automated voice call as both a current best practice and an anticipated rule change under active CRTC review. My AI Call Center builds these requirements into every campaign launch, reviewing consent records and list sources before any outreach begins.