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

Overview

Vermont regulates telemarketing through its Consumer Protection Act, 9 V.S.A. chapter 63. It has no standalone telemarketing code and no state do-not-call list. Instead, a cluster of sections in subchapter 1 does the work:

• Prohibited telephone solicitations (§ 2464a). Telemarketers must register before calling. The section also folds the federal do-not-call rules into state law and requires caller ID transmission.
• Registration (§ 2464b). Telemarketers register with the Secretary of State.
• Private right of action (§ 2464c). People who receive calls that violate § 2464a(b) can sue.
• Robocalls (§ 2464e). Added in 2022 and effective July 1, 2023, this section bans autodialed and prerecorded calls that violate the federal Telephone Consumer Protection Act (TCPA) or the Telemarketing and Consumer Fraud and Abuse Prevention Act. It gives a private remedy and sets criminal penalties.
• Telemarketing payments (§ 2464). This older section controls how telemarketers take payment by check and electronic funds transfer.
• Home solicitation sales (§§ 2451a, 2454). Telephone sales can count as home solicitation sales, which carry a three-business-day cancellation right.

Vermont mostly adopts federal standards rather than writing its own. Its do-not-call rule is the federal rule, made enforceable under state law. Its robocall statute says it means to be "coextensive" with the federal laws and their judicial construction.

Vermont adds three things federal law lacks:

• a registration requirement backed by a felony-level criminal penalty;
• a private remedy with fee shifting for do-not-call, caller ID and registration violations;
• an escalating civil penalty of $1,000 for each violation after the first.

The Office of the Attorney General enforces the Consumer Protection Act. It can seek civil penalties of up to $10,000 for each unfair or deceptive act.

Source note: the official statutes site of the Vermont General Assembly says "The Statutes below include the actions of the 2025 session of the General Assembly." We found no 2026 act amending these sections. H.829 (2026), a bill on notification of artificial-voice robocalls, was referred to committee on January 29, 2026 and has had no further recorded action.

Key statutes table

Detailed provisions

1. Scope and definitions

Section 2464a's definitions apply to it and to §§ 2464b and 2464c. Who counts as a protected customer depends on location and phone service, not on the type of phone line. A "Customer" is "a customer, residing or located in Vermont, of a company providing telecommunications service as defined in 30 V.S.A. § 203(5)."

A telephone solicitation "means the solicitation by telephone of a customer for the purpose of encouraging the customer to contribute to an organization that is not a tax-exempt organization, or to purchase, lease, or otherwise agree to pay consideration for money, goods, or services". The term does not include four kinds of calls:

• "telephone calls made in response to a request or inquiry by the called customer";
• "telephone calls made by or on behalf of a tax-exempt organization, an organization incorporated as a nonprofit organization with the State of Vermont, or an organization in the process of applying for tax-exempt status or nonprofit status";
• "telephone calls made by a person not regularly engaged in the activities listed in subdivision (A) of this subdivision (8)"; and
• "telephone calls made to a person with whom the telephone solicitor has an established business relationship."

The statute does not define "established business relationship."

A "Telephone solicitor" is "any person placing telephone solicitations, or hiring others, on an hourly, commission, or independent contractor basis to conduct telephone solicitations." A "Telemarketer" is "any telephone solicitor." But the term "does not include any telephone solicitor who is otherwise registered or licensed with, or regulated or chartered by, the Secretary of State, the Public Utility Commission, the Department of Financial Regulation, or the Department of Taxes". It also excludes certain financial institutions subject to federal privacy regulations.

One wrinkle applies to solicitors registered with the Department of Taxes only for withholding, sales and use, or meals and rooms tax. They are not exempt from the jurisdictional requirement. They "shall provide to the Secretary of State an address and agent for the purpose of submitting to the jurisdiction of the Vermont courts in any action brought for violations of this section."

Section 2464 uses a separate, broader definition for payment rules. There a "Telemarketer" is "any person who initiates telephone calls to, or who receives telephone calls from, a consumer in connection with a plan, program, or campaign to market goods or services." That definition has its own exclusions, including debt collection calls and "any company registered with and regulated by the Public Utility Commission".

The Superior Court has held that the two definitions are independent. In State v. Electronic Media Marketing Group (Vt. Super. Ct. 2018), the court noted that "As each section, § 2464 and § 2464a, expressly asserts, its definitions are for its own purposes." Whether a company is a telemarketer under § 2464 is therefore "irrelevant to the charged failure to register."

2. Registration and bonding

Registration comes before any call. Section 2464a(b)(1) provides: "No telemarketer shall make a telephone solicitation to a telephone number in Vermont without having first registered in accordance with section 2464b of this title."

Under § 2464b(a), "Every telemarketer shall register with the Secretary of State, on a form approved by the Secretary." For calling operations, only the top-level entity registers. Where a telemarketer hires others to make calls, "only the person who causes others to conduct telephone solicitations need register." The Secretary may adopt rules, including "a requirement of notice to the Secretary by the telemarketer when the telemarketer ceases to do business in Vermont."

Every registrant must name an agent. The Secretary "shall require that each telemarketer designate an agent for the purpose of submitting to the jurisdiction of the Vermont courts in any action brought for violations of section 2464a of this title."

The fees are:

• "Registration: $125.00."
• "Statement of change of designated agent or designated office, or both: $25.00, not to exceed $1,000.00 per filer per calendar year."

Vermont requires no bond. The statute does not set a renewal period, and we have not confirmed the Secretary of State's current renewal practice.

Unregistered calling is a crime. Under § 2464a(d), a telemarketer who solicits without registering "shall be imprisoned for not more than 18 months or fined not more than $10,000.00, or both." The statute gives small operators a narrow defense. It "shall be an affirmative defense, for a telemarketer with five or fewer employees, that the telemarketer did not know and did not consciously avoid knowing that Vermont has a requirement of registration of telemarketers." Also, "Each telephone call shall constitute a separate solicitation under this section."

3. Calling hours

Vermont has no separate calling-hours statute. The federal 8 a.m. to 9 p.m. window still applies under 47 C.F.R. § 64.1200(c)(1) and 16 C.F.R. § 310.4(c).

Section 2464a(b)(2) incorporates only the federal do-not-call provisions, not the time-of-day rule. Section 2464e, however, reaches any "automatically dialed or prerecorded telephone call" made in violation of the TCPA, the Telemarketing Act "and the regulations adopted pursuant to those Acts". So an autodialed or prerecorded call outside the federal hours may also be a Vermont violation. That reading has not been tested in a reported decision.

4. Call frequency

Vermont sets no numeric limit on how often a telemarketer may call. Repeat calls matter in two ways:

• Each prohibited call is a separate violation under §§ 2464a(c) and 2464e(c)(2).
• Under § 2464c, statutory damages rise from $500 for the first violation to $1,000 for each subsequent violation.

5. Autodialers, prerecorded messages and Facebook v. Duguid

Section 2464e is Vermont's robocall statute. Its intent clause reads: "It is the intent of the General Assembly in adopting this section to create State law prohibition on the placement of robocalls to Vermont consumers that is coextensive with the federal limitations created in the Telephone Consumer Protection Act, the Telemarketing and Consumer Fraud and Abuse Prevention Act, the regulations adopted under those Acts, and the judicial construction of these laws."

The operative ban: "A person shall not initiate an automatically dialed or prerecorded telephone call to a Vermont consumer in violation of the federal Telephone Consumer Protection Act, 47 U.S.C. § 227". The ban also covers violations of the federal Telemarketing and Consumer Fraud and Abuse Prevention Act and "the regulations adopted pursuant to those Acts, as amended."

The statute does not define "automatically dialed." Because it ties itself to the federal statutes and "the judicial construction of these laws," the narrow federal definition of an automatic telephone dialing system (ATDS) from Facebook, Inc. v. Duguid (U.S. 2021) appears to govern autodialed calls under § 2464e. Under Duguid, the equipment must use a random or sequential number generator. Prerecorded and artificial-voice calls are covered whatever equipment places them. Unlike Florida, Oklahoma or Maryland, Vermont has no broader state autodialer definition.

The Vermont Attorney General's Office raised this point in a January 13, 2023 report to the General Assembly's commerce committees. The report said Duguid "has the potential to significantly increase unwanted robocalls because few automated dialers actually incorporate random or sequential number generators." It proposed that the Legislature "could strengthen Vermont's mini TCPA by defining an" autodialer more broadly, "excluding capacity for random or sequential number generation, and applying these rules to both telemarketers and non-telemarketers". The report also noted a gap: "Although it is coextensive with the TCPA, Section 2464e does not prohibit U.S. companies from" assisting illegal robocallers in the way the federal Telemarketing Sales Rule (TSR) does. We found no enacted amendment carrying out either recommendation.

6. Text messages

Neither § 2464a nor § 2464e mentions text messages. The § 2464a definitions speak of "solicitation by telephone" and "telephone calls," and no Vermont decision we found applies them to texts.

Section 2464e is meant to track federal law and its "judicial construction." Federal rules and decisions treat text messages as calls for TCPA purposes, so autodialed marketing texts that violate the TCPA likely also violate § 2464e. That conclusion is an inference from the coextensive language, not an express statutory rule.

7. Caller ID

Section 2464a(b)(3)(A) requires caller ID transmission for both commercial and charitable calls. "A person who places a telephone call to make a telephone solicitation or to induce a charitable contribution, donation, or gift of money or other thing of value shall transmit or cause to be transmitted to a caller identification service in use by the recipient of the call". The caller must transmit "the caller's telephone number" and, "if made available by the caller's carrier, the caller's name."

A substitute is allowed: "a caller may substitute for its own name and number the name and the number, which is answered during regular business hours, of the person on whose behalf the caller places the call."

Two points are worth noting:

• The caller ID rule uses "person," not "telemarketer." It therefore reaches charitable calls, even though § 2464a's definition of telephone solicitation excludes tax-exempt organizations.
• The rule reaches callers who would otherwise be exempt from registration.

8. Disclosures and opt-out

Vermont's telemarketing sections do not script an opening disclosure. Federal disclosure rules apply directly: 47 C.F.R. § 64.1200(d)(4) and 16 C.F.R. § 310.4(d).

The federal company-specific do-not-call rules are incorporated by § 2464a(b)(2). These include the duty to honor opt-out requests: under 47 C.F.R. § 64.1200(d)(6), "A do-not-call request must be honored for 5 years from the time the request is made." Section 2464e also incorporates federal disclosure rules for prerecorded calls.

Misrepresentations during a sales call can be unfair or deceptive acts under § 2453(a), which declares that "unfair or deceptive acts or practices in commerce are hereby declared unlawful." When courts construe that provision, § 2453(b) directs them to be "guided by the construction of similar terms contained in Section 5(a)(1) of the Federal Trade Commission Act".

Section 2464d places a separate notice duty on carriers. "Local exchange carriers shall provide notices at least annually to residential customers of the availability of telephone callers' do not call lists under federal law and of the federal Do Not Call Registry, and a description of how to register."

9. Do-not-call

Vermont keeps no state list. It makes violations of the federal lists violations of state law. Section 2464a(b)(2): "No person shall make any telephone call to a telephone number in Vermont that violates the Federal Trade Commission's Do Not Call Rule, 16 C.F.R. subdivision 310.4(b)(1)(iii), or the Federal Communication Commission's Do Not Call Rule, 47 C.F.R. subdivision 64.1200(c)(2) and subsection (d), as amended from time to time."

This incorporation has several consequences:

• The National Do Not Call Registry. Under 47 C.F.R. § 64.1200(c)(2), "Such do-not-call registrations must be honored indefinitely, or until the registration is cancelled by the consumer or the telephone number is removed by the database administrator." The federal safe harbor applies, including the FTC requirement to use a registry version obtained "no more than thirty-one (31) days prior to the date any call is made" (16 C.F.R. § 310.4(b)(3)(iv)).
• Company-specific lists and written policies. These come in through 47 C.F.R. § 64.1200(d) and 16 C.F.R. § 310.4(b)(1)(iii)(A).
• Scope. Section 2464a(b)(2) covers "any telephone call to a telephone number in Vermont" by any "person." The federal rules decide which calls are covered. The § 2464a definition of telephone solicitation and its exclusions limit who counts as a "telemarketer" for registration, but they do not appear in subdivision (b)(2) itself.

Compliance programs count when the court sets a penalty. Under § 2464a(c), "the court may consider, among other relevant factors, the extent to which a telephone solicitor maintained and complied with procedures designed to ensure compliance with the rules of the Federal Communications Commission and the Federal Trade Commission."

10. Contract, payment and cancellation rules

Home solicitation sales by telephone. Section 2451a(4) defines a home solicitation sale to include a sale or lease of goods or services "with a purchase price of $5.00 or more" that is "solicited or consummated by a seller wholly or in part by telephone with a consumer at the residence or place of business or employment of the consumer."

There are exclusions, including:

• sales "Conducted and consummated entirely by mail and without any other contact between the consumer and the seller prior to delivery of the goods or performance of the services";
• small cash sales; and
• real estate, insurance, registered securities and commodities sales.

Under § 2454(a)(1), the consumer "may cancel a home solicitation sale until midnight of the third business day after the day on which the consumer has signed an agreement or offer to purchase relating to such sale, or has otherwise agreed to buy consumer goods or services from the seller."

The seller must give a "fully completed receipt or copy of any contract." That document must carry, in boldface type of at least 10 points, a statement "in substantially the following form": "You, the buyer, may cancel this transaction at any time prior to midnight of the third business day after the date of this transaction. See the attached notice of cancellation for an explanation of this right."

Cancellation is informal. Notice "shall be sufficient if it indicates the intention of the consumer not to be bound."

Payment by check or electronic funds transfer. Section 2464(b) makes it an unfair and deceptive act for any telemarketer, directly or through an agent, to do the following:

• Couriers. Use "any third-party delivery, courier, or other pickup service" to collect payment unless the goods are delivered at the same time.
• Checks and drafts. Submit a check or draft "without the consumer's prior written authorization or to dispose of the written authorization until at least four years after the authorization".
• Electronic funds transfers. Take an electronic funds transfer unless (i) the consumer called the telemarketer, or the parties "have a current written agreement for the provision of goods or services or the consumer has purchased goods or services from the telemarketer within the previous two years", and (ii) the telemarketer "has obtained the consumer's express oral authorization to the transfer prior to initiating the debit."

Express oral authorization has strict content and record requirements. The telemarketer must clearly state that the consumer is authorizing the transfer, and must state:

• the consumer's name;
• a description of the goods or services;
• any material terms;
• the debit date;
• the amount;
• a telephone number for consumer inquiries; and
• the date of the authorization.

The telemarketer must then either keep a recording of the entire call or send a written confirmation before settlement. Either one must be kept "until at least four years after" the authorization or the notice.

Payment processors and others are covered too. Section 2464(c) and (e) regulate payment processors. Under § 2464(d), it is an unfair and deceptive act "to provide substantial assistance to a telemarketer in violation of subsection (b) of this section when the person or the person's authorized agent knows or consciously avoids knowing that the telemarketer is engaging in an unfair or deceptive act or practice in commerce."

11. Exemptions

The main exemptions come from § 2464a's definitions:

• Excluded calls. Inquiry responses, tax-exempt and Vermont nonprofit callers, persons not regularly engaged in solicitation, and established business relationship calls are excluded from "telephone solicitation."
• Licensed or regulated callers. Callers registered, licensed, regulated or chartered by the Secretary of State, the Public Utility Commission, the Department of Financial Regulation or the Department of Taxes are excluded from "telemarketer." So are financial institutions under federal privacy rules.

These exclusions shape the registration duty. They do not obviously carry over to § 2464a(b)(2) or to § 2464e, which use "person" and incorporate the federal exemptions instead.

The caller ID duty under § 2464a(b)(3) also uses "person" and expressly covers charitable solicitations.

12. Private right of action, damages and limitations

Section 2464c. "Any person who receives a telephone call in violation of subsection 2464a(b) of this title may bring an action in Superior Court for damages, injunctive relief, punitive damages in the case of a willful violation, and reasonable costs and attorney's fees."

The damages rule: "The court may issue an award for the person's actual damages or $500.00 for a first violation, or $1,000.00 for each subsequent violation, whichever is greater."

Compliance procedures can reduce punitive damages. The court may consider "the extent to which a telephone solicitor maintained and complied with procedures designed to ensure compliance with the requirements of sections 2464a and 2464b of this title."

The section is cumulative: "This section shall not limit any other claims the person may have under applicable law."

The § 2464c action covers three kinds of violation:

• unregistered solicitation under (b)(1);
• federal do-not-call violations under (b)(2); and
• caller ID violations under (b)(3).

Section 2464e(c)(3). "A person who receives a telephone call in violation of this section may bring an action in Superior Court for damages or a civil penalty, injunctive relief, punitive damages in the case of a willful violation, and reasonable costs and attorney's fees." The court "may issue an award for the greater of a person's damages or a civil penalty of $500.00 for a first violation and $1,000.00 for each subsequent violation."

Section 2461(b). The general consumer remedy covers deceptive telemarketing. A consumer who contracts in reliance on prohibited practices, or is damaged by them, may recover "the amount of his or her damages, or the consideration or the value of the consideration given by the consumer, reasonable attorney's fees, and exemplary damages not exceeding three times the value of the consideration given by the consumer."

Personal jurisdiction. In Escano v. Pro Custom Solar (Vt. Super. Ct. 2018), the court denied an out-of-state solar company's motion to dismiss for lack of personal jurisdiction. The company's telemarketer had placed prerecorded calls that reached the plaintiff in Vermont. The plaintiff's cell phone had a New Jersey area code.

The court pointed to the § 2464c remedy. It described "a civil penalty of $500 for the first offense and $1,000 for each subsequent offense." It reasoned that declining jurisdiction "would, as a practical matter, make it impossible for Vermont residents to obtain any relief from such offenses, if they had to sue telemarketers in the foreign states or countries where the telemarketers are located".

The court dismissed the claims against two individual officers without prejudice. It explained that "The mere fact that Souritzidis and Christensen are executive officers, owners and managers of PCS is not enough to impose liability upon them for PCS's acts or omissions." The complaint did not allege that they made, directed or knew of the calls.

Statute of limitations. None of §§ 2464a, 2464c or 2464e sets a limitations period. The general civil statute, 12 V.S.A. § 511, provides that a civil action "shall be commenced within six years after the cause of action accrues and not thereafter." Whether that period, or a shorter penalty limitations period, applies to the statutory-penalty awards under §§ 2464c and 2464e has not been decided in any case we found. The federal TCPA claim is governed by the four-year federal catch-all period.

13. Attorney General and agency enforcement

Violations are Consumer Protection Act violations. Under § 2464a(c), a violation "shall constitute a violation of section 2453 of this title. Each prohibited telephone call shall constitute a separate violation." Section 2464e(c)(1) says the same for robocalls.

Attorney General remedies. The Attorney General, or a State's Attorney with the Attorney General's authorization, may sue for injunctions under § 2458(a). Under § 2458(b), the court may award:

• "the imposition of a civil penalty of not more than $10,000.00 for each unfair or deceptive act or practice in commerce";
• restitution; and
• reimbursement of investigation and prosecution costs.

Violating an injunction carries a further civil penalty "of not more than $10,000.00 for each violation" (§ 2461(a)).

Per-call penalties. In State v. Electronic Media Marketing Group, the defendant argued that civil penalties are available only for violating an injunction. The Superior Court rejected that argument. It held that § 2458(b)(1) and § 2461(a) "authorize civil penalties for two different purposes." It also observed that § 2464a(c) makes each prohibited call a separate violation. On the merits, the court found that phoning prospective Vermont customers to sell website directory listings, including free-trial offers later invoiced, was telephone solicitation. The court found that "The undisputed business activity at issue in this case plainly is encompassed by this definition of telephone solicitation and falls under none of the exemptions." It granted the State partial summary judgment on the failure-to-register count.

Robocall duties. Section 2464e(e) directs the Attorney General "to work cooperatively with other state and federal government entities to identify callers who initiate robocalls to consumers in violation of this section and to enforce the provisions of this section regardless of the location of the caller." The Attorney General's 2023 report describes:

• a Robocall Enforcement Team created in 2021;
• Vermont's participation in the multistate Anti-Robocall Litigation Task Force; and
• two enforcement actions against U.S. providers that relayed foreign robocalls.

Criminal penalties. "A person who commits a knowing and willful violation of this section shall be imprisoned for not more than 90 days or fined not more than $1,000.00 per violation, or both" (§ 2464e(d)(1)). The registration offense under § 2464a(d) carries up to 18 months or $10,000.

How Vermont law differs from federal law

The federal baseline consists of the TCPA (47 U.S.C. § 227), the Federal Communications Commission (FCC) rules at 47 C.F.R. § 64.1200, and the Federal Trade Commission (FTC) Telemarketing Sales Rule (TSR) at 16 C.F.R. Part 310.

Where Vermont is stricter.

• Registration. Vermont requires registration before calling and attaches a criminal penalty of up to 18 months. Federal law has nothing similar.
• Damages. The private remedy escalates to $1,000 for each violation after the first, adds punitive damages for willful violations, and shifts costs and attorney's fees. The federal TCPA gives $500 per violation, trebled only for willful or knowing conduct, with no fee shifting.
• Do-not-call remedy. Section 2464c gives a private claim for any call that violates the federal do-not-call rules. That claim is not limited to the federal requirement of more than one call in 12 months under 47 U.S.C. § 227(c)(5). Whether a Vermont court would read that federal threshold into the incorporated rules is open.
• Caller ID. The caller ID rule expressly covers charitable solicitations.
• Payments and cancellation. The payment and four-year record rules in § 2464 and the three-day telephone cancellation right in § 2454 have no general federal counterpart.

Where Vermont is the same.

• The do-not-call rules are the federal rules.
• The robocall rule is expressly "coextensive" with the TCPA, the Telemarketing Act and their judicial construction, Duguid included.
• Calling hours and disclosure scripts follow federal law.

Where Vermont is looser or silent.

• Vermont has no broader state autodialer definition, no state calling-hours rule, and no state-specific text message rule.
• The § 2464a definition of telephone solicitation excludes calls to anyone with an "established business relationship," with no time limit. That exclusion matters mainly for registration, since the do-not-call rules incorporate the federal relationship windows.
• Section 2464e does not adopt the TSR's "substantial assistance" theory for robocalls, as the Attorney General's 2023 report noted.

Case law

• State v. Electronic Media Marketing Group, Inc., No. 325-6-17 Wncv (Vt. Super. Ct., Washington Unit, Feb. 27, 2018). A business that phoned Vermont prospects to sell website listings was a telemarketer under § 2464a(a)(7) and had to register under § 2464b. The § 2464 definition did not control registration. The court also held that the State may seek civil penalties under § 2458(b)(1) for each prohibited call, not only for injunction violations, and granted partial summary judgment to the State. The court's posted text notes that it "is unofficial" and "has been reformatted from the original."
• Escano v. Pro Custom Solar, LLC, No. 765-8-17 Cncv (Vt. Super. Ct., Chittenden Unit, May 3, 2018). A Vermont court may exercise personal jurisdiction over an out-of-state seller whose telemarketer placed prerecorded calls received in Vermont. The court relied in part on the state interest reflected in § 2464c. Claims against individual officers were dismissed without prejudice for lack of alleged personal involvement.

Both are trial-court decisions. They have no precedential weight beyond their persuasive value. We found no Vermont Supreme Court decision or federal decision construing §§ 2464a, 2464c or 2464e.

Recent amendments

• 2021, No. 183 (Adj. Sess.), § 57, effective July 1, 2023. Added § 2464e (robocalls). Section 58 of the same Act directed the Attorney General to review federal robocall law and report. The report was delivered January 13, 2023.
• 2017, No. 66, § 1, effective June 8, 2017. Amended §§ 2464a and 2464c.
• 2013, No. 72, § 2. Amended § 2464b (registration fees).
• 2003, No. 89 (Adj. Sess.), effective April 7, 2004. Amended §§ 2464a, 2464c and 2464d to tie Vermont law to the federal Do Not Call Registry.
• 2001, No. 120 (Adj. Sess.). Enacted §§ 2464a through 2464d.
• Introduced, no further action: H.829 (2026). "An act relating to notification of robocalls that use an artificial voice." Read the first time and referred to the Committee on Energy and Digital Infrastructure on January 29, 2026. The official status page shows no further recorded action, and we found no enactment.

Compliance checklist

1. Register with the Vermont Secretary of State before placing any solicitation to a Vermont number, unless a § 2464a(a)(7) or (a)(8) exclusion clearly applies. Designate an agent and file changes. Only the entity that causes others to call needs to register.
2. Scrub every call to a Vermont number against the National Do Not Call Registry, using a version no more than 31 days old. Honor company-specific requests for five years, and keep written do-not-call policies. These federal duties are enforceable under Vermont law with per-call penalties.
3. Get prior express written consent for prerecorded telemarketing and for autodialed calls to wireless numbers. Treat every TCPA or TSR violation by an autodialed or prerecorded call to a Vermont consumer as a § 2464e violation.
4. Transmit your telephone number and, where available, your name on every commercial and charitable solicitation. If you substitute the seller's name and number, make sure that number is answered during regular business hours.
5. Keep federal calling hours (8 a.m. to 9 p.m. local time) and federal disclosure scripts.
6. For payment by electronic funds transfer, use express oral authorization with every required element. Record the full call or send written confirmation before settlement, and keep the record for four years. Get prior written authorization for checks and drafts.
7. Treat telephone sales of $5 or more as home solicitation sales unless an exclusion applies. Deliver the boldface three-business-day cancellation notice and honor any notice that shows the consumer's intention not to be bound.
8. Document compliance procedures. Courts may weigh them in setting civil penalties and punitive damages.
9. Vet lead sources, vendors and payment processors. Section 2464(d) imposes liability for knowing substantial assistance, and Vermont courts will hear claims against out-of-state sellers whose calls reach Vermont.

References

• 9 V.S.A. chapter 63: https://legislature.vermont.gov/statutes/chapter/09/063
• 9 V.S.A. § 2451a: https://legislature.vermont.gov/statutes/section/09/063/02451a
• 9 V.S.A. § 2453: https://legislature.vermont.gov/statutes/section/09/063/02453
• 9 V.S.A. § 2454: https://legislature.vermont.gov/statutes/section/09/063/02454
• 9 V.S.A. § 2458: https://legislature.vermont.gov/statutes/section/09/063/02458
• 9 V.S.A. § 2461: https://legislature.vermont.gov/statutes/section/09/063/02461
• 9 V.S.A. § 2464: https://legislature.vermont.gov/statutes/section/09/063/02464
• 9 V.S.A. § 2464a: https://legislature.vermont.gov/statutes/section/09/063/02464a
• 9 V.S.A. § 2464b: https://legislature.vermont.gov/statutes/section/09/063/02464b
• 9 V.S.A. § 2464c: https://legislature.vermont.gov/statutes/section/09/063/02464c
• 9 V.S.A. § 2464d: https://legislature.vermont.gov/statutes/section/09/063/02464d
• 9 V.S.A. § 2464e: https://legislature.vermont.gov/statutes/section/09/063/02464e
• 12 V.S.A. § 511: https://legislature.vermont.gov/statutes/section/12/023/00511
• H.829 (2026) bill status: https://legislature.vermont.gov/bill/status/2026/H.829
• Vermont Attorney General, Recommendations for robocall legislation (January 13, 2023): https://legislature.vermont.gov/assets/Legislative-Reports/2023.01.13-Report-re-Robocalls-FINAL.pdf
• State v. Electronic Media Marketing Group, Inc. (Vt. Super. Ct. 2018): https://www.vermontjudiciary.org/media/12185
• Escano v. Pro Custom Solar, LLC (Vt. Super. Ct. 2018): https://www.vermontjudiciary.org/media/11149
• 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.