EU: the AI Act's transparency rule
Article 50(1) of the EU AI Act says that AI systems meant to interact directly with people must be designed so that those people are informed they're interacting with an AI system, unless that's obvious from the context. The obligation has applied since 2 August 2026; the 2026 "Digital Omnibus" changes delayed other parts of the Act but not this one (Goodwin, August 2026).
On a phone call nothing is obvious: a natural AI voice can sound like a person. The simplest way to comply is to say it at the very start of the call.
EU: GDPR and transcripts
Transcripts and messages contain personal data: names, numbers and whatever callers say. Under the GDPR, callers have to be told that their call is processed, by whom and why (Article 13), and data should be kept no longer than necessary (Article 5). In practice:
Say in the greeting that the call is transcribed, link a privacy notice from your website, keep transcripts only as long as you need them, and sign a data processing agreement with your AI receptionist provider. If callers may share health or other sensitive data, check the extra rules for your sector and country before you start.
USA: recording and transcription consent
Federal law allows recording a call when one party consents, but a number of states, including California, Florida, Illinois, Maryland, Massachusetts, Pennsylvania and Washington, require the consent of everyone on the call. Transcribing a call in real time is generally treated like recording it, so the safe practice is to announce it at the start: a caller who stays on the line after hearing it has been informed.
The FCC ruled in 2024 that AI-generated voices count as "artificial" voices under the Telephone Consumer Protection Act. That ruling is about outgoing robocalls; answering calls your customers make to you is a different situation. Some states have their own rules about bots and AI disclosure, and sector rules such as HIPAA for health information may apply to what callers tell the assistant.
What your greeting should say
One sentence covers the disclosure in most places: who is answering, that it's an AI assistant, and that the call is transcribed. For example:
"Hi, I'm Sara, the AI assistant at Bright Smile Dental, and this call is transcribed. How can I help?"
RingLily starts every default greeting this way in all seven languages, and warns you if you edit the greeting and remove the AI or transcription part.
Good practice beyond the minimum
- Offer a person: transfer callers who ask for one during working hours, or take a message for a call back.
- Don't let the assistant pretend: if a caller asks whether they're talking to a person, it should say it's an AI.
- Keep transcripts for as short a time as works for you. RingLily deletes them automatically after the retention period you choose (90 days by default), and keeps no audio recording.
- Limit what's collected: tell the assistant not to ask for card numbers, health details or other data it doesn't need.
- Write down how calls are handled in your privacy notice.