Pennsylvania Telemarketing and Robocall Laws: Statutes, Rules, and How They Differ from the TCPA

Overview

Pennsylvania regulates telemarketing principally through the Telemarketer Registration Act (TRA), Act of December 4, 1996, P.L. 911, No. 147, codified at 73 P.S. §§ 2241 to 2249. The TRA requires non-exempt telemarketers to register with the Office of Attorney General and post a $50,000 bond, maintains a state do-not-call list, restricts calling hours, requires disclosures at the start of each call, requires a signed written contract for most telephone sales, and bars caller ID blocking and call-screening circumvention. Every TRA violation is also a violation of the Unfair Trade Practices and Consumer Protection Law (UTPCPL), Act of December 17, 1968, P.L. 1224, No. 387, 73 P.S. § 201-1 et seq., which separately requires telephone sellers to identify themselves and the sales purpose of the call.

The TRA was substantially rewritten by Act 47 of 2026 (Senate Bill 992), approved by the Governor on July 20, 2026, which takes effect 90 days after enactment. Counting under 1 Pa.C.S. § 1908, which excludes the first day and includes the last, the 90th day is October 18, 2026; conduct before the effective date is governed by the prior text. Act 47 extends the TRA to text messages, voicemail and ringless voicemail; narrows the calling window to 9 a.m. to 7 p.m. and bans Sunday and legal holiday solicitations; requires prior express written consent for robocalls; adopts a federal-style list of keyword opt-outs for texts; prohibits deceptive consent-gathering and deceptive synthetic or computer-generated messaging; and restructures the registration exemptions.

The Bureau of Consumer Protection in the Office of Attorney General is the regulator. The headline difference from federal law is that Pennsylvania's calling window (9 a.m. to 7 p.m., no Sundays or legal holidays) is far narrower than the federal 8 a.m. to 9 p.m., and Pennsylvania requires registration, bonding and a signed written contract for most telephone sales. Federal courts have held, however, that the TRA itself gives consumers no private right of action; private enforcement runs through the UTPCPL, which requires an ascertainable loss.

Key statutes and regulations

Detailed provisions

Quotations from the TRA below are from the consolidated text published by the General Assembly, which reflects the amendments made by Act 47 of 2026 (identified in the text as "July 20, 2026, P.L.532, No.47").

1. Scope and definitions

Telephone solicitation. Act 47 adds a new definition that drives the statute: "'Telephone solicitation.' A telephone call, voicemail, ringless voicemail or text message made to a residential, business or wireless telephone subscriber for the purpose of soliciting the sale of consumer goods or services, or for the purpose of obtaining information that will or may be used for the direct solicitation of the sale of consumer goods or services or an extension of credit for that purpose." The definition excludes a call or message made to a subscriber:

• "(1) In response to the prior express written consent of the subscriber."
• "(2) In reference to an existing debt, contract, payment or performance."
• "(3) With whom the seller or telemarketer has an established business relationship within the past 12 months preceding the call."
• "(4) On behalf of an organization granted tax-exempt status under 26 U.S.C. § 501(c)(3), (5) or (8) (relating to exemption from tax on corporations, certain trusts, etc.) or a veterans organization chartered by the Congress of the United States and its duly appointed foundation."
• "(5) On behalf of a political candidate or a political party."

Telemarketer and telemarketing. A "telemarketer" is "Any person or business which, in connection with telemarketing, initiates or receives telephone calls or messages to or from a residential, business or wireless telephone subscriber in this Commonwealth, or when the person or business acting in connection with telemarketing is located within this Commonwealth when such calls or messages are initiated or received." "Telemarketing" is "A plan, program or campaign which is conducted to induce the purchase of consumer goods or services or to solicit contributions for any charitable purpose, charitable promotion or for or on behalf of any charitable organization by use of one or more telephones and which involves more than one telephone solicitation." The statute thus reaches both outbound and inbound telemarketing and both Pennsylvania-located callers and calls into Pennsylvania.

Robocall. "'Robocall.' A telephone solicitation that uses an automated dialing system to deliver prerecorded or artificial voice calls or messages." The TRA does not define "automated dialing system."

Prior express written consent. New in 2026, the definition requires "A written agreement executed between a called party and a seller that authorizes the seller to initiate or cause to be initiated a telephone solicitation to the called party, including a robocall or text message." The agreement must (1) identify "the telephone number to which the called party authorizes the calls or messages"; (2) contain "a clear and conspicuous disclosure that, by executing the agreement, the called party consents to receive telephone solicitations from the seller, including a robocall or text message"; (3) state "that the consent is not a condition of purchasing property or consumer goods or services"; and (4) be "signed by the called party, which may include an electronic or digital signature consistent with the requirements under 15 U.S.C. Ch. 96." The consent runs to "the seller," which mirrors the FCC's one-to-one consent concept.

Established business relationship. "A prior or existing relationship formed by a voluntary two-way communication between a person or entity and a residential, business or wireless telephone subscriber, with or without an exchange of consideration, on the basis of an inquiry, application, purchase or transaction by the residential, business or wireless telephone subscriber regarding products or services offered by such persons or entity. In regard to an inquiry, the person or entity shall obtain the consent of a residential, business or wireless telephone subscriber to continue the business relationship beyond the initial inquiry." Combined with the 12-month limit in the telephone solicitation definition, Pennsylvania's relationship exception is both shorter than the federal 18-month window for purchases and stricter for inquiries.

Residential and business subscribers. A "residential telephone subscriber" includes "both wire line telephone service numbers and wireless telephone service numbers." Pennsylvania protects business lines as well; a "business telephone subscriber" excludes a subscriber "that engages in telemarketing, makes telephone solicitation calls or is a telemarketing business."

2. Telemarketer registration and bonding (§§ 3 and 4)

Requirement. Section 3(a) provides that "a telemarketer or the telemarketing business which employs the telemarketer shall be required to register with the Office of Attorney General at least 30 days prior to offering for sale consumer goods or services through any medium." It adds: "Notwithstanding any other provision of this act, any business which provides telemarketing services to other entities and has been under the same ownership and control for less than five years shall register under this section." Section 3(b) makes it "unlawful for a telemarketer to initiate a telephone call or message to, or to receive a telephone call or message from, a residential, business or wireless telephone subscriber in this Commonwealth in connection with the purchase of consumer goods or services unless the telemarketer or the telemarketing business which employs the telemarketer is registered with the Office of Attorney General." "Failure to register as required by this act constitutes a misdemeanor of the second degree." (§ 3(c).)

Exemptions (§ 3(b.1)). Act 47 consolidated the registration exemptions in a new subsection (b.1). They include catalog sellers meeting size and circulation tests; callers who do not complete the sale during the call and complete it at a later face-to-face meeting; negative option and continuity plans; "A person or business conducting a business-to-business sale if the selling business has operated continuously for at least three years under the same business name and at least 50% of its dollar volume consists of repeat sales to existing businesses"; "A person or business engaged in a business or occupation licensed by, certificated by or registered with a Federal or Commonwealth agency while acting within the scope of the business for which licensure, certification or registration is required"; specified educational, hospital, library, senior center, parent-teacher and small charitable organizations; sellers calling prior purchasers if the business "has operated continuously for at least three years under the same business name"; established periodical publishers; retail establishments operated in Pennsylvania for at least two years under the same name; telemarketing vendors operating "continuously for at least five years under the same ownership and control and deriving 75% of its gross telemarketing sales revenue from contracts with persons or businesses exempt under this section"; small food sellers; SEC-registered issuers and their subsidiaries; and "A person or business that is not engaged in telemarketing because the calls or messages initiated by the person or business do not meet the requirements of telephone solicitation." Licensed businesses that telemarket outside the scope of their license are subject to Attorney General registration regulations under § 4(c).

Process, bond and fee. The Attorney General provides "an application form for biennial registration" (§ 4(a)). The application "shall be accompanied by a surety bond in the sum of $50,000" that "shall provide for the indemnification of any person suffering a loss as the result of any fraud, misrepresentation, violation of section 5 or violation of" the UTPCPL (§ 4(b)). Cash, a certificate of deposit or government bonds of $50,000 may be substituted. "The biennial fee for those persons or businesses registering under subsection (a) shall be $500." (§ 4(d).)

Burden of proof. "In any civil proceeding alleging a violation of this act, the burden of proving an exemption or an exception from a definition is upon the person claiming it." (§ 8(a).)

3. Calling hours, Sundays and legal holidays

As amended by Act 47, § 5(a) prohibits:

• "(1) Initiating or causing to be initiated a telephone solicitation on a Sunday or after 7 p.m. or before 9 a.m."
• "(10) Initiating or causing to be initiated a telephone solicitation on a legal holiday."

Before Act 47, § 5(a)(1) prohibited "Conducting telemarketing" after 9 p.m. or before 8 a.m. (as shown in the bracketed deleted text of SB 992, Printer's No. 1649). The statute does not specify a time zone or define "legal holiday." Because the TRA applies to calls into Pennsylvania, the conservative reading is Pennsylvania local time.

4. State do-not-call list (§ 5.2)

Prohibition. "No telemarketer shall initiate or cause to be initiated a telephone solicitation to a telephone number of a residential, wireless or business telephone subscriber who does not wish to receive telephone solicitations and has caused the subscriber's name, address and telephone number to be enrolled on a do-not-call list maintained by the list administrator. This prohibition shall be effective 30 days after a quarterly do-not-call list is issued by the list administrator which first contains a residential, wireless or business telephone subscriber's name, address and residential, wireless or business telephone number." (§ 5.2(a).)

List administrator and the national registry. The list administrator is a nonprofit designated by the Bureau of Consumer Protection, but if the Federal Trade Commission (FTC) or Federal Communications Commission (FCC) establishes a national registry, the Bureau "may enter into an agreement to utilize the services of the administrator of any such national No Call Registry in lieu of using any nonprofit organization" (§ 2, definition of "List administrator"). Section 5.2(a) also authorizes the Bureau to release Pennsylvania enrollments to the national registry.

List purchase. "Telemarketers making telephone solicitations shall quarterly obtain listings of residential, business and wireless telephone subscribers in this Commonwealth who have arranged to have their names, addresses and telephone numbers enrolled on the list administrator's do-not-call list or shall utilize a service provider who has quarterly obtained and will use such listings." (§ 5.2(b).) Fees may not exceed production and distribution costs "or at a fee authorized by 16 CFR 310.8" (§ 5.2(d)).

Duration. "A listing on a do-not-call list shall be maintained until the telephone number is no longer valid for the residential, business or wireless telephone subscriber or until the subscriber requests to have the telephone number removed from the list." (§ 5.2(c).)

Affirmative defense. A telemarketer is not in violation if "(1) The telemarketer has established and implemented written procedures to comply with this section," "(2) The telemarketer has trained the telemarketer's personnel in the procedures," "(3) The telemarketer acting on behalf of the seller has maintained and recorded lists of residential, business or wireless telephone subscribers who may not be contacted," and "(4) Any subsequent call is the result of error." (§ 5.2(e).)

Use restriction. The list may not be used "for any purpose other than to remove residential, business or wireless telephone subscribers from telephone solicitation lists" (§ 5.2(g)).

5. Company-specific opt-outs and text keyword opt-outs

Section 5(a)(2) prohibits "Initiating or causing to be initiated an outbound telephone solicitation, including a robocall, to a residential, business or wireless subscriber when the subscriber previously has stated that the subscriber does not wish to receive a telephone solicitation made by or on behalf of the seller or telemarketer." For texts, "the person may state the intent to stop receiving telephone solicitation text messages by responding 'stop,' 'quit,' 'end,' 'revoke,' 'opt out,' 'cancel' or 'unsubscribe' in reply to an incoming text." The same written-procedures, training, list-maintenance and error defense applies. Section 5(a)(8) separately prohibits "Failing to end a telephone solicitation when a called party indicates the called party wants to end the call or message."

6. Robocalls and prerecorded messages

Consent. New § 5(a)(11) prohibits "Initiating or causing to be initiated a robocall to any residential, business or wireless telephone line without the prior express written consent of a called party, unless the call is initiated for emergency purposes or is otherwise exempt under this act."

Opt-out mechanics. A telemarketer that uses robocalls "Shall establish a procedure, consistent with the requirements under subparagraph (ii), for a called party to opt out of receiving future telephone solicitations from that telemarketer or telemarketing business and be immediately taken off the telemarketer's call list" (§ 5.2(l)(1)(i)). It must "provide notice to a called number, at the beginning of the call, stating how a called party can opt out," and "Immediate opt out shall be available through an automated, interactive voice-activated or key-press-activated opt-out mechanism for the called party to make a do-not-call request, including brief explanatory instructions on how to use the opt-out mechanism, within two seconds of disclosing the name of the caller and the name of the person or entity on whose behalf the call is being made. The called party shall be able to opt out throughout the duration of the call." (§ 5.2(l)(1)(ii).) The telemarketer "May not require a called party's written consent as a condition to opt out" and "May not consider the action of opting out as the creation of an established business relationship" (§ 5.2(l)(1)(iii), (iv)). A robocall left on voicemail "must provide a toll-free telephone number that enables the called party to call back at a later time and connect directly to the automated, interactive voice-activated or key-press-activated opt-out mechanism and automatically record the called party's number to the do-not-call list of the telemarketer or telemarketing business" (§ 5.2(l)(2)).

Callback numbers. If a telemarketer solicits by robocall, the contact "telephone number may not be a 900 number or any other number for which charges exceed local or long-distance transmission charges" (§ 5.2(j)).

Autodialer definition and Facebook v. Duguid. The TRA regulates "robocalls," defined by the use of "an automated dialing system to deliver prerecorded or artificial voice calls or messages," and does not separately regulate live-agent calls placed with an autodialer. Because "automated dialing system" is not defined, the TRA does not adopt the random or sequential number generator test of Facebook, Inc. v. Duguid, 592 U.S. 395 (2021), and we have located no decision construing the term.

7. Text messages, voicemail and ringless voicemail

From the effective date of Act 47, a "telephone solicitation" expressly includes a "voicemail, ringless voicemail or text message." Texts are therefore subject to registration, calling hours, the Sunday and holiday bans, the state do-not-call list, the company-specific opt-out rule (with the keyword list above), and, where the text is a "robocall" as defined, the prior express written consent requirement. Pennsylvania's express coverage of ringless voicemail has no direct counterpart in the text of the federal statute.

8. Caller ID, call screening and synthetic messaging

Section 5.1 provides: "No telemarketer shall take any action with the primary intent: (1) to prevent the transmission of a telemarketer's name or telephone number or to falsely identify the telemarketer's name or telephone number to any recipient of a telephone solicitation; or (2) to circumvent, bypass or disable any product or service used by the residential, wireless or business telephone subscriber to screen telephone calls or messages."

Section 5(a)(9) incorporates federal standards by prohibiting "Engaging in any deceptive or abusive telemarketing acts or practices in violation of 16 CFR 310 (relating to telemarketing sales rule), 47 U.S.C. § 227(e) (relating to restrictions on use of telephone equipment) or any regulation of the Federal Communications Commission relating to caller identification requirements." A violation of the FTC's Telemarketing Sales Rule (TSR) or of the federal Truth in Caller ID Act is therefore also a TRA violation and, through § 6(a), a UTPCPL violation.

Act 47 adds two conduct prohibitions aimed at lead generation and artificial intelligence: "(12) Using or causing to be used any unfair or deceptive act or practice in an effort to obtain a residential, business or wireless subscriber's consent to receive telephone solicitations" and "(13) Using or causing to be used any technology or any synthetic or computer-generated messaging to defraud, deceive or mislead a residential, business or wireless subscriber."

9. Disclosures at the start of the call

Section 5(a)(5) prohibits "Failing to disclose promptly to any residential, business or wireless telephone subscriber during the initial telephone contact the purpose of the call, the name of the telemarketer or telemarketing business and, if applicable, what the telemarketer or telemarketing business is selling." Section 5.2(j) requires the telemarketer to provide "the name of the caller, the name of the person or entity on whose behalf the call is being made and, upon request, a telephone number or address at which the person or entity may be contacted."

The UTPCPL independently defines as an unfair or deceptive practice "Making solicitations for sales of goods or services over the telephone without first clearly, affirmatively and expressly stating: (A) the identity of the seller; (B) that the purpose of the call is to sell goods or services; (C) the nature of the goods or services; and (D) that no purchase or payment is necessary to be able to win a prize or participate in a prize promotion if a prize promotion is offered" (73 P.S. § 201-2(4)(xvii)).

For prize promotions, § 5(a)(6) requires disclosure of the odds of winning, that no purchase or payment is necessary, the no-purchase method of entry, and all material costs or conditions, "prior to the customer's payment for the consumer goods or services offered."

10. Written contracts, payment authorization and refunds

Signed contract. Section 5(a)(7) prohibits "Failing to reduce any sale of consumer goods or services made during a telephone solicitation to a written contract and obtaining the consumer's signature on the written contract, except as provided in subsection (d)." The contract must contain the seller's and telemarketer's name, address and telephone number, the total price, "A detailed description of the consumer goods and services purchased or rented which shall match the oral description given in the telephone solicitation," any oral or written representations made during the call, and "A statement that reads 'You are not obligated to pay any money unless you sign this contract and return it to the seller.'" (§ 5(c).)

Exceptions. No signed contract is needed if the sale is regulated under other Pennsylvania law, follows the consumer's visit to a permanent retail location, results from the consumer's review of the seller's advertisement or catalog containing the required information, is made by a 501(c)(3) charity, or offers a full refund "upon the return of undamaged and unused consumer goods within ten days of receipt of the consumer goods or upon sending a cancellation of consumer service notice to the telemarketer or telemarketing business within five days of the transaction," with the policy disclosed and refunds processed within 30 days (§ 5(d)).

Bank account debits. Section 5(a)(3) prohibits submitting a check or draft on a person's account "without the person's express verifiable authorization," which may be written, tape-recorded oral authorization containing specified terms, or written confirmation sent before submission. Records must be kept "for at least 24 months" (§ 5(b)).

Recovery services. Section 5(a)(4) bars charging for recovery of money lost in a previous telemarketing transaction "until seven business days after such money or other item is delivered to that person," except for services by a licensed attorney.

11. Private rights of action

TRA. The TRA contains no express private right of action. Section 6(a) provides: "A violation of this act is also a violation of the act of December 17, 1968 (P.L.1224, No.387), known as the Unfair Trade Practices and Consumer Protection Law." Section 7 provides that "Nothing in this act shall be construed to limit the remedies available to consumers, the Attorney General or any district attorney under" the UTPCPL "or any other State or Federal law." Federal courts in Pennsylvania have consistently held that consumers cannot sue directly under the TRA (see Shelton and Garcia, below).

UTPCPL. The UTPCPL private action is limited to "Any person who purchases or leases goods or services primarily for personal, family or household purposes and thereby suffers any ascertainable loss of money or property, real or personal, as a result of the use or employment by any person of a method, act or practice declared unlawful." Such a person "may bring a private action to recover actual damages or one hundred dollars ($100), whichever is greater. The court may, in its discretion, award up to three times the actual damages sustained, but not less than one hundred dollars ($100), and may provide such additional relief as it deems necessary or proper. The court may award to the plaintiff, in addition to other relief provided in this section, costs and reasonable attorney fees." (73 P.S. § 201-9.2(a).) A consumer who simply receives unwanted calls, without a purchase and resulting loss, will generally not meet these requirements.

Statutory damages and class actions. Pennsylvania provides no per-call statutory damages comparable to the TCPA's $500. Neither statute bars class actions by its terms, but the ascertainable loss requirement makes class treatment of call-receipt claims difficult.

Limitations. Neither the TRA nor the UTPCPL text we reviewed states a limitations period for private UTPCPL actions.

12. Attorney General enforcement and penalties

The Bureau of Consumer Protection "shall investigate any complaints received concerning violations of this section," and the Attorney General "may bring an action to impose a civil penalty and to seek other relief, including injunctive relief," under the UTPCPL (§ 5.2(k)(1)). As an incentive, "The Attorney General shall remit 10% of any civil penalty collected under this section to the person filing the complaint leading to the civil penalty. In no event, however, shall the amount of this remittance exceed $100 for any person." (§ 5.2(k)(2).) The Attorney General may subpoena witnesses and documents before suit (§ 9(b)) and must report annually to the General Assembly on enforcement (§ 5.2(k)(3)).

Under the UTPCPL, for willful violations the Attorney General or a district attorney may recover "a civil penalty of not exceeding one thousand dollars ($1,000) per violation," and where the victim "is sixty years of age or older, the civil penalty shall not exceed three thousand dollars ($3,000) per violation" (73 P.S. § 201-8(b)). Violating an injunction or assurance of voluntary compliance carries "a civil penalty of not more than five thousand dollars ($5,000) for each violation" (§ 201-8(a)). Failure to register is a second-degree misdemeanor (TRA § 3(c)). Act 47 deleted former § 6(b), which had authorized the Attorney General to seek revocation of registration after a second violation, and former § 6(c), which subjected Attorney General actions under the TRA to administrative-agency procedure.

How Pennsylvania law differs from federal law

Where Pennsylvania is stricter. The 2026 calling window is among the narrowest in the country, and the Sunday and legal holiday bans have no federal parallel. Pennsylvania requires registration, a $50,000 bond, and a signed written contract for most telephone sales. Its established business relationship exception lasts 12 months, not 18. It protects business lines on its do-not-call list, covers ringless voicemail expressly, and regulates deceptive consent-gathering and synthetic messaging.

Where Pennsylvania is looser or narrower. Consumers have no direct TRA claim, the UTPCPL requires a purchase and an ascertainable loss, and there are no per-call statutory damages. Robocall regulation is tied to an undefined "automated dialing system" and, unlike the federal prerecorded-message rule, does not by its terms reach prerecorded calls made without an automated dialing system. The TRA's do-not-call prohibition is subject to a written-procedures, training and error defense.

Where Pennsylvania follows federal law. The text-message opt-out keywords track the FCC's 2024 revocation rule, the prior express written consent elements track the federal definition, and § 5(a)(9) imports the TSR and federal caller ID standards directly.

Notable enforcement and case law

• Shelton v. FCS Capital LLC, No. 2:18-cv-03723-JDW (E.D. Pa. Dec. 11, 2019). On summary judgment, the court held that "The PTRA vests enforcement authority with Pennsylvania's Attorney General, not individual consumers," relying on § 5.2(k)(1) and Pennsylvania authority that where "the General Assembly commits the enforcement of a regulatory statute to a government body or official, this precludes enforcement by private individuals," and concluded that the plaintiff "cannot maintain such a claim as a matter of law." The court awarded TCPA damages of $1,500 per admitted willful violation of §§ 227(b) and 227(c). Shelton v. FCS Capital (E.D. Pa. 2019) memorandum
• Bower v. National Administrative Service Co., LLC, No. 4:21-CV-00998 (M.D. Pa. Mar. 17, 2022). The plaintiff, on the state and federal do-not-call lists, bought a vehicle service policy after receiving the same prerecorded warranty message seven times, and pleaded UTPCPL claims predicated on TRA § 5.2(a) and § 5.1 violations. Noting that the TRA "does not allow for private rights of action," the court nevertheless denied the defendants' motion to dismiss, reasoning that "the logical conclusion at this pleading stage is that these identical pre-recorded messages came from the same source." Bower v. National Administrative Service (M.D. Pa. 2022) opinion
• Garcia v. Star Power Marketing Group, LLC, No. 2:24-cv-04823-CH (E.D. Pa. June 24, 2026). After the parties agreed to set aside an earlier default, the defendant answered but did not respond to the plaintiff's class certification motion. The court denied certification without prejudice, explaining that the "PTRA does not create a private cause of action" and that, although "the PTRA may serve as a predicate claim under Pennsylvania's Unfair Trade Practices and Consumer Protection Law" for a person who suffers an ascertainable loss, the "Plaintiff does not appear to make any such requisite allegations." The court ordered supplemental briefing. Garcia v. Star Power Marketing Group (E.D. Pa. 2026) memorandum opinion

Recent amendments

• Act 47 of 2026 (SB 992), Act of July 20, 2026, P.L. 532, No. 47. Approved by the Governor July 20, 2026; "This act shall take effect in 90 days" (SB 992, Printer's No. 1649, § 5), which we compute as on or about October 18, 2026. Principal changes: new definitions of "telephone solicitation" (including voicemail, ringless voicemail and texts), "prior express written consent" and "robocall"; deletion of the former "telephone solicitation call" definition and the former definitional exemptions within "telemarketer"; new consolidated registration exemptions in § 3(b.1); calling hours of 9 a.m. to 7 p.m. with no Sunday or legal holiday solicitations; text keyword opt-outs; prior express written consent for robocalls; prohibitions on deceptive consent-gathering and deceptive synthetic messaging; expansion of caller ID and screening protections to "calls or messages"; and deletion of § 6(b) and (c).
• Act 73 of 2019, Act of October 4, 2019, P.L. 447, No. 73. Added business telephone subscribers, the established business relationship consent rule for inquiries, the affirmative defense structure in § 5.2(e), and the robocall opt-out requirements in § 5.2(l).
• Act 22 of 2003, Act of September 12, 2003, P.L. 105, No. 22. Added wireless numbers to "residential telephone subscriber" and amended § 5.2.

Practical compliance checklist

1. Recalibrate dialing and texting windows for Pennsylvania numbers to 9 a.m. to 7 p.m., Monday through Saturday, with no solicitations on legal holidays, effective on Act 47's effective date.
2. Confirm registration status or document a specific § 3(b.1) exemption for each seller and vendor; vendors under the same ownership for less than five years must register.
3. If registration is required, file biennially with the Attorney General, pay the $500 fee, and post the $50,000 bond at least 30 days before selling.
4. Obtain the Pennsylvania do-not-call list quarterly (or use a service provider that does) and suppress numbers within 30 days of each quarterly list, including business and wireless numbers.
5. Treat texts, voicemail and ringless voicemail as telephone solicitations and honor the seven keyword opt-outs.
6. Obtain prior express written consent that names the seller, identifies the number, discloses robocall and text consent, and states that consent is not a condition of purchase; audit lead generators for deceptive consent practices.
7. Script prompt disclosure of the purpose of the call, the caller's and seller's names and what is being sold; provide a contact number or address on request; end calls when asked.
8. For robocalls, provide an automated opt-out within two seconds of identification, available throughout the call, and a toll-free opt-out number on voicemail messages.
9. Reduce telephone sales to a signed written contract with the required terms, or adopt and disclose a qualifying 10-day goods or 5-day services refund policy.
10. Transmit accurate caller ID, do not use technology that circumvents call-screening products, and review any AI-generated voice or message content for deception risk.

References

• Telemarketer Registration Act, Act of Dec. 4, 1996, P.L. 911, No. 147 (consolidated text, PDF): https://www.palegis.us/statutes/unconsolidated/law-information/view-statute?txtType=PDF&SessYr=1996&ActNum=0147.&SessInd=0
• Telemarketer Registration Act, law information page: https://www.palegis.us/statutes/unconsolidated/law-information?SessYr=1996&SessInd=0&ActNum=147
• SB 992 (2025 to 2026 Session), bill information: https://www.palegis.us/legislation/bills/2025/sb992
• SB 992, Printer's No. 1649 (final): https://www.palegis.us/legislation/bills/text/HTM/2025/0/SB0992/PN1649
• Legislation amending the TRA, 2025 to 2026 Session: https://www.palegis.us/legislation/bills/statute-references?AmendingAct=147&AmendingSessInd=0&AmendingSessYr=1996&SessInd=0&SessYr=2025
• Unfair Trade Practices and Consumer Protection Law, Act of Dec. 17, 1968, P.L. 1224, No. 387 (PDF): https://www.palegis.us/statutes/unconsolidated/law-information/view-statute?txtType=PDF&SessYr=1968&ActNum=0387.&SessInd=0
• Shelton v. FCS Capital LLC (E.D. Pa. 2019): https://www.govinfo.gov/content/pkg/USCOURTS-paed-2_18-cv-03723/pdf/USCOURTS-paed-2_18-cv-03723-0.pdf
• Bower v. National Administrative Service Co. (M.D. Pa. 2022): https://www.govinfo.gov/content/pkg/USCOURTS-pamd-4_21-cv-00998/pdf/USCOURTS-pamd-4_21-cv-00998-0.pdf
• Garcia v. Star Power Marketing Group, LLC (E.D. Pa. 2026): https://www.govinfo.gov/content/pkg/USCOURTS-paed-2_24-cv-04823/pdf/USCOURTS-paed-2_24-cv-04823-0.pdf
• 47 U.S.C. § 227: https://www.govinfo.gov/content/pkg/USCODE-2023-title47/html/USCODE-2023-title47-chap5-subchapII-partI-sec227.htm
• 47 C.F.R. § 64.1200: https://www.ecfr.gov/current/title-47/chapter-I/subchapter-B/part-64/subpart-L/section-64.1200
• 16 C.F.R. Part 310: https://www.ecfr.gov/current/title-16/chapter-I/subchapter-C/part-310

This page summarizes state law for general informational purposes and is not legal advice. Statutes change; confirm current text with the official source before relying on it.