Pennsylvania SB 992: A New Mini-TCPA With Greater Restrictions
Pennsylvania SB 992 would expand telemarketing rules to texts, ringless voicemail, AI calls, and stricter Do-Not-Call limits, making Pennsylvania a far tougher state for marketers.
Pennsylvania SB 992: A New Mini-TCPA With Greater Restrictions
Pennsylvania SB 992: A New Mini-TCPA With Greater Restrictions
Pennsylvania Senate Bill 992 is a 2025-2026 Pennsylvania General Assembly bill that amends the Pennsylvania Telemarketer Registration Act (TRA) to expand and modernize the Commonwealth’s regulation of telemarketing activity. On July 12, 2026, SB 992 was unanimously passed by both chambers of the Pennsylvania General Assembly and is currently sitting on Governor Josh Shapiro's desk awaiting his signature.
Once passed into law, SB 992 would materially expand and modernize the Commonwealth’s Telemarketer Registration Act by dramatically expanding the scope of the TRA’s coverage to include text messaging, ringless voicemail, automated communications, and deceptive AI-enabled calls. If enacted in its current form, the bill would make Pennsylvania a significantly more restrictive state for marketers and brands, particularly for those running cold-call prospecting campaigns, or operate through third-party vendors.
Background: The Pennsylvania Telemarketer Registration Act
It defines “telemarketer” as a person who “initiates or receives telephone calls to a consumer in connection with the purchase of consumer goods or services, or to solicit contributions for a charity,” as part of a plan, program, or campaign.
It requires “telemarketers” to register with the Attorney General at least 30 days before offering goods or services for sale in Pennsylvania, post a $50,000 bond, and pay a registration fee every two years.
It also defines “telephone solicitation” in terms of traditional calls placed to Pennsylvania residents, with associated unlawful acts and penalties for unwanted telemarketing, caller ID blocking, and violations of the Do‑Not‑Call provisions.
It prohibits certain telemarketing screening products or services (e.g., caller ID blocking) and unwanted telephone solicitation calls, with TRA violations treated as violations of Pennsylvania’s Unfair Trade Practices and Consumer Protection Law (UTPCPL).
Notably absent from the statute’s ambit is any reference to modern marketing techniques and tactics such as text messaging, ringless voicemails, AI-powered calls, and modern consent tactics, which prompted the introduction of SB 992.
What SB 992 Would Do
SB 992 is an omnibus update to the Pennsylvania TRA that updates definitions, modifies registration requirements, and revises provisions related to telemarketing practices. Key substantive changes include:
Expanded Channel Coverage: The current Telemarketer Registration Act was built primarily around traditional telephone solicitation calls. SB 992 would broaden that concept so that text campaigns, voicemail drops, and other automated outreach methods are treated as regulated solicitation channels, reducing the ability of marketers to treat those channels as falling outside Pennsylvania’s telemarketing framework.
Revised Consent and Exemption Structure: SB 992 would modernize the treatment of prior express written consent and established business relationships, so that communications made with qualifying prior express written consent or a recent established business relationship would fall outside the statute’s definition of “telephone solicitation.” In practical terms, this would make documented consent and relationship-based outreach even more important as operational safe harbors for Pennsylvania campaigns.
More Restrictive Calling Time Limits: SB 992 would ban telemarketing calls and text solicitations between 7:00 pm and 9:00 am and prohibit telemarketing entirely on Sundays and legal holidays; which goes well beyond the federal 9:00 pm to 8 am standard. These quiet hours would apply to calls and texts sent without consent or an EBR. Calls and texts placed with proper consent or an EBR would generally fall outside these restrictions.
Stronger DNC and Anti-Evasion Provisions. The bill would strengthen Pennsylvania’s Do-Not-Call protections by extending coverage more broadly and by targeting tactics that undermine consumer choice, including deceptive practices used to remove numbers from DNC protections without genuine consent. It would also require tighter call-list hygiene and increase the legal significance of list-suppression controls and documentation.
AI and Caller-ID Restrictions. SB 992 specifically addresses deceptive uses of AI and spoofing, including the use of AI technology to mislead or defraud subscribers and the manipulation of caller identity information. This is particularly important for businesses using AI voice agents, dynamic caller-ID features, branded calling tools, or third-party dialing platforms with synthetic voice capabilities in Pennsylvania.
Expanded Enforcement Exposure. SB 992 does not create a brand‑new, stand‑alone private right of action, but TRA violations will continue to be treated as violations of Pennsylvania’s Unfair Trade Practices and Consumer Protection Law (UTPCPL), which already gives consumers a private right of action including minimum statutory damages and potential treble damages. SB 992 would increase exposure not only for telemarketers but also for the businesses that hire them, which could face civil penalties of up to $1,000 per violation, or up to $3,000 where the contacted person is age 60 or older.
Operational Impact on Marketing Campaigns
SB 992 would function as a state-level “mini-TCPA” with broader channel coverage and more restrictive state-specific rules. Campaigns that currently treat SMS, ringless voicemail, or AI-enabled outreach as operationally separate from “telemarketing calls” would need to revisit that assumption for Pennsylvania.
The bill also increases the value of clean consent architecture. Because it appears as though prior express written consent and qualifying established business relationships can remove a communication from the definition of telephone solicitation, businesses will need strong intake, storage, and retrieval processes for consent and EBR records if they want to rely on those exclusions. In addition, brands will need more active oversight of outside call centers, lead generators, and platform vendors because the proposed framework places greater responsibility on both the entity placing the communication and the business on whose behalf it is made.
Overall Impact on Pennsylvania Telemarketing Compliance
Pennsylvania SB 992 is a pending amendment to the state’s Telemarketer Registration Act that would modernize an older, telephone‑centric statute by explicitly bringing text messages, ringless voicemail, and other automated communications within the definition of regulated “telephone solicitation,” tightening quiet hours and Do‑Not‑Call protections, and directly targeting caller‑ID spoofing and deceptive uses of AI.
Operationally, it would push brands and vendors to treat Pennsylvania as a high‑risk telemarketing jurisdiction, shift more outreach toward documented prior express written consent and established business relationships, and require Pennsylvania‑specific campaign configuration and vendor contracting to manage joint liability and enhanced enforcement exposure.
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