Several state laws and federal rules decide when an AI that talks to renters must say what it is, and what changes when it places calls. Here is what each one requires, and the practice that follows from them.

Does any law require an AI leasing agent to say it is an AI?

Some do, depending on the state and the channel. California bars bots that mislead people about what they are to drive a sale, Utah requires disclosure in some AI interactions, and Colorado will require notice from 2027 when AI shapes housing decisions.

California. Under the state’s bot disclosure law, known as the BOT Act, it is unlawful to use a bot to communicate or interact with a person in California online, with intent to mislead them about its artificial identity, in order to incentivize a purchase or sale of goods or services in a commercial transaction (B&P 17941). A person using a bot is not liable if they disclose that it is a bot, and the disclosure must be clear, conspicuous and reasonably designed to inform. Online means any public-facing website, web application or digital application, including social networks (B&P 17940).

Utah. The state’s Office of Artificial Intelligence Policy says SB 226 (2025) extended Utah’s 2024 AI law by requiring disclosure when generative AI is used in a consumer transaction, and confirmed liability for consumer protection violations that involve AI. It says the 2024 law already required disclosure when someone interacts with AI in a regulated occupation (Utah Office of AI Policy).

Colorado. SB 26-189, signed May 14, 2026, takes effect January 1, 2027 (Colorado General Assembly). It covers automated decision-making technology used to materially influence a consequential decision, and housing is on the list.

A business using such a system must give clear and conspicuous notice when consumers interact with it. It must also describe the system’s role in plain language within 30 days of an adverse outcome, and let consumers correct their data and request meaningful human review.

Nationwide. Announcing its Operation AI Comply sweep in September 2024, the FTC quoted its chair: using AI tools to trick, mislead or defraud people is illegal, and “there is no AI exemption from the laws on the books” (FTC).

What changes when the AI places calls?

Consent and identification rules apply. In a February 2024 ruling, FCC 24-17, the FCC confirmed that AI technologies that generate human voices are artificial voices under the Telephone Consumer Protection Act (TCPA). Calls made with them need the called person’s prior express consent, or prior express written consent if they advertise or telemarket (FCC 24-17).

The FCC added that the TCPA has no carve-out for technology that claims to be the equivalent of a live agent. Every artificial voice message must state the identity of the business at the start and give its phone number, and telemarketing messages must offer an automated opt-out (47 CFR 64.1200(b)).

The ruling covers calls the business initiates, such as an AI callback or a reminder call. Answering a renter’s incoming call is not initiating one, but recording law still applies.

In California, from everyone on the call when a cell or cordless phone is involved. Penal Code 632.7 makes it a crime to intercept or receive and intentionally record a call between cell or cordless phones, or between one of them and a landline, without the consent of all parties (PC 632.7).

Under Penal Code 637.2, a person injured by a violation can sue for the greater of $5,000 per violation or three times actual damages, and does not need to show actual damages (PC 637.2). Announcing the recording at the start of every call is the simple answer.

What do renters want?

To be told. In a survey of 800 US renters run in September 2025 and published in October 2025 by Rently, a vendor that sells leasing software including an AI leasing agent, 74% said they would feel less comfortable if AI use is not disclosed. In the same survey, 57% wanted human support available at any time (Rently).

What should an AI leasing agent do?

Disclose early, never pose as a person, and hand off. These habits follow from the rules above:

  • Say it is an AI in the first sentence of every call and the first message of every thread, and again whenever a renter asks. That is the disclosure the BOT Act treats as a defense, and the kind of notice Colorado’s law describes.
  • Never claim or imply to be a person, even when a renter asks to speak to one.
  • Announce recording and its purpose at the start of every call.
  • Offer a person whenever a renter asks, and leave decisions on applications to your team, which also gives renters the human review Colorado’s law calls for.
  • For outbound AI calls, get consent first, open with your business’s name and give a callback number.

The rules at a glance

Rule What it requires Source
California BOT Act No bot online may mislead people about being artificial to drive a sale; clear, conspicuous disclosure is a defense Cal. B&P 17940, 17941
Utah SB 226 (2025) Disclosure when generative AI is used in a consumer transaction, as the state’s AI office describes it Utah Office of AI Policy
Colorado SB 26-189, from January 1, 2027 Clear and conspicuous notice when AI materially influences a housing decision; explanation, correction, human review Colorado General Assembly
FCC 24-17 AI voices are artificial voices; outbound calls need prior express consent FCC
47 CFR 64.1200(b) Artificial voice messages name the business at the start and give a phone number 47 CFR 64.1200
FTC No AI exemption from existing law FTC
California Penal Code 632.7 Consent of all parties to record calls involving a cell or cordless phone Cal. PC 632.7, 637.2