Pennsylvania is making significant changes to its telemarketing law, and businesses have until October 18, 2026, to prepare.
Senate Bill 992 brings text messages more explicitly into Pennsylvania’s telemarketing framework while changing requirements around consent, calling hours, opt-outs, robocalls and registration.
There is a lot packed into the update.
For businesses calling or texting into Pennsylvania, though, the bigger question is whether those changes have made their way into the systems and processes running their outbound campaigns.
With the effective date approaching, here are some of the items worth checking.
First, Which Campaigns Count as Telephone Solicitations?
Before getting into individual requirements, it helps to start with what Pennsylvania now considers a telephone solicitation.
SB 992 defines a telephone solicitation to include a telephone call, voicemail, ringless voicemail or text message made to solicit the sale of consumer goods or services, or to collect information that may later be used for that purpose.
The inclusion of text messages is important. If calling and texting have historically lived in separate parts of your compliance program, Pennsylvania gives you a reason to look at them together.
However, not every communication falls within the definition of a telephone solicitation.
The law retains exclusions for certain communications involving an existing debt, contract, payment or performance, as well as communications involving an established business relationship within the previous 12 months. Certain communications made on behalf of qualifying tax-exempt organizations, congressionally chartered veterans organizations or their duly appointed foundations, and political candidates or campaigns are excluded as well. Communications made in response to a subscriber's prior express written consent also fall outside the definition.
It's important to understand the nuances here because the definition of a telephone solicitation affects which requirements apply.
Before changing anything, be certain you know which of your Pennsylvania campaigns actually fall within this updated definition.
“They Opted In” May Not Tell You Enough About Consent
Consent is another area where SB 992 gets much more specific.
The law defines “prior express written consent” as a written agreement between the called party and seller authorizing telephone solicitations, including robocalls or text messages.
That agreement needs to identify the telephone number the person has authorized for contact. It must clearly disclose that the person agrees to receive telephone solicitations from the seller and state that consent isn't a condition of purchasing property, goods or services. It also needs to be signed, although qualifying electronic and digital signatures can satisfy that requirement.
Prior express written consent is, by definition, documented consent. So, the question isn't simply whether a lead “opted in.” It's whether you have a record that shows what they agreed to.
If someone asks why a particular lead can be contacted, what documentation can you produce?
A CRM field that says “opted in” doesn't necessarily tell you what language the person saw, which number they authorized or which seller they agreed could contact them.
This is a good time to look at the full consent trail. Marketing forms, lead sources, CRM records and third-party lead documentation should give you a defensible picture of how consent was collected and what it covered.
Importantly, prior express written consent is one part of the amended framework. SB 992 does not say that every marketing call or text requires written consent. The law's other exclusions and requirements matter, which is why understanding how a campaign is classified comes first.
Pennsylvania Is Narrowing the Clock
This change is simpler, but it may require some of the most immediate operational work.
Beginning October 18, telephone solicitations cannot be initiated in Pennsylvania:
- Before 9:00 a.m.
- After 7:00 p.m.
- At any time on Sunday
A campaign can have the right audience, consent and messaging and still create a compliance problem if the dialer is operating on the wrong schedule.
For teams working across multiple states, a broad nationwide calling window hasn't been sufficient for some time. Pennsylvania's new window is notably restrictive, particularly with the addition of a full Sunday prohibition.
Those rules need to be reflected wherever campaign timing is actually controlled, whether that's an internal dialer, campaign workflow or third-party provider.
And don't overlook Sundays. An automated campaign that runs seven days a week today will need to know when a Pennsylvania number enters the queue.
An Opt-Out Doesn't Have to Say “STOP”
Texting workflows also deserve another look, particularly around the way opt-outs are identified and honored.
SB 992 specifically identifies several ways a recipient may communicate that they want telephone solicitation texts to stop:
STOP, QUIT, END, REVOKE, OPT OUT, CANCEL and UNSUBSCRIBE.
Most marketers are already very familiar with STOP. But systems also need to respond appropriately when someone uses one of the other terms Pennsylvania recognizes.
Does “CANCEL” trigger the same suppression workflow? What about “REVOKE” or “UNSUBSCRIBE”?
If the answer depends on someone manually noticing the response, there is likely a gap that needs to be addressed. Review your workflows to make sure the opt-out terms Pennsylvania recognizes are requests your messaging system knows how to process.
Don't forget that recognition is only the first step. The opt-out also needs to make its way into any system that could initiate the next message.
Automated and Artificial-Voice Outreach Needs Its Own Review
SB 992 also makes several changes involving robocalls.
Under the amended law, a robocall is a telephone solicitation using an automated dialing system to deliver prerecorded or artificial voice calls or messages.
Pennsylvania generally prohibits initiating a robocall to a residential, business or wireless telephone line without prior express written consent unless the communication is for emergency purposes or is otherwise exempt under the law.
The legislation also prohibits unfair or deceptive practices used to obtain consent and the use of technology or synthetic or computer-generated messaging to defraud, deceive or mislead subscribers.
That last provision is particularly relevant as more businesses experiment with AI and synthetic voice technology, but it shouldn't be read as a blanket prohibition on using AI in outbound outreach. The language specifically addresses technology used to defraud, deceive or mislead.
Robocalls also come with their own opt-out requirements. The law requires an automated interactive voice- or key-press-activated mechanism that allows the called party to make a do-not-call request and remain able to opt out throughout the call. Additional requirements apply to robocalls left on answering machines or voicemail services.
In other words, reviewing the technology itself is only part of the job. Consent and opt-out functionality need to work alongside it.
Don't Assume Your Registration Analysis Is Unchanged
Registration may be easier to overlook because SB 992 reorganizes parts of the existing law rather than adding a new rule.
Several provisions that previously appeared as exclusions from the definition of “telemarketer” now appear as exemptions from the telemarketer registration requirement.
The amended law preserves a number of registration exemptions, including certain business-to-business activity and businesses or occupations licensed, registered or otherwise authorized by a federal or Pennsylvania agency while acting within the scope of that regulated business.
It also includes an exemption for a person or business that isn't engaged in telemarketing because its calls or messages don't meet the requirements of a telephone solicitation.
If your organization has relied on an existing exclusion or exemption, this is not a section to skim past. Confirm that the reasoning supporting your current registration status still works under the amended structure.
Your Vendors Are Part of the Compliance Program Too
There is a common thread running through nearly every change in SB 992: a policy doesn't accomplish much if the technology executing the campaign doesn't follow it.
Maybe your marketing team knows not to contact Pennsylvania consumers on Sundays. Does your dialer?
Your compliance team may recognize all seven text opt-out terms. Does your messaging provider?
You may have the correct consent language on your own forms. Can the same be said for leads entering your database from somewhere else?
That is why vendor and platform reviews belong alongside the legal review.
SB 992 also expressly prohibits deceptive or abusive telemarketing practices that violate the FTC's Telemarketing Sales Rule, federal caller ID law or FCC caller ID requirements.
Pennsylvania's caller ID provisions prohibit certain actions intended to prevent the transmission of a telemarketer's identifying information, falsely identify its name or telephone number, or circumvent technologies subscribers use to screen calls or messages.
For organizations using third parties for dialing, messaging, lead generation or caller ID management, understanding what actually happens after a campaign leaves your hands matters.
October 18 Is the Deadline. The Work Happens Before Then.
Pennsylvania SB 992 doesn't change just one part of outbound compliance.
It can affect how a campaign is classified, how consent is documented, when outreach is permitted to happen, how text opt-outs are processed, how automated calls operate and whether a business needs to register.
That makes the weeks before October 18 a good time to trace a Pennsylvania campaign from beginning to end.
Where did the contact come from?
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Why is the business permitted to contact them?
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What happens before the number enters a dialer or messaging platform?
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Which scheduling and suppression rules are applied?
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What happens if the person opts out?
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Which vendors touch the campaign along the way?
Those questions connect the law on paper to the outreach consumers actually receive.
State telemarketing requirements continue to change, and keeping up with them requires more than knowing that a new law passed. The requirements have to reach the systems deciding who gets contacted, how they're contacted, when they're contacted and when that contact needs to stop.
With SB 992 taking effect October 18, Pennsylvania gives outbound teams a clear deadline to make sure these requirements aren't just understood, but reflected in the campaigns reaching consumers.
Need help reviewing your outbound program?
Contact Center Compliance helps outbound teams apply DNC requirements, state-specific calling restrictions and other pre-contact compliance checks before outreach begins.
And with integrations into major dialing platforms, those compliance controls can become part of the workflows your team is already using.
The rules will keep changing. We're here to make compliance easier as they do.
Talk with our team about simplifying your outbound compliance.
