On July 20, 2026, Pennsylvania Governor Josh Shapiro signed into law Senate Bill 992 (“SB 992”), which significantly amends the Pennsylvania Telemarketer Registration Act (the “Act”), 73 P.S. §§ 2241 et seq. The legislation has important implications for companies that engage in telemarketing, SMS/text message marketing, customer outreach campaigns, and other consumer-facing communications with Pennsylvania residents.
Effective October 18, 2026, SB 992 modernizes Pennsylvania’s nearly three-decade-old telemarketing law by expanding its coverage beyond traditional telephone calls to text messages, voicemails, ringless voicemails, and certain automated communications. The law also introduces new consent, opt-out, calling-hour, and compliance obligations that may increase regulatory and litigation risk for businesses operating in Pennsylvania.
Expanded Scope of Pennsylvania’s Telemarketing Law
Among the most significant changes, SB 992 broadens the Act’s coverage beyond traditional telemarketing calls. The law replaces the term “telephone solicitation call” with the broader term “telephone solicitation,” which now encompasses:
- Telephone calls;
- Voicemails;
- Ringless voicemails;
- Text messages (SMS and similar messaging technologies).
The expansion aligns Pennsylvania’s telemarketing framework more closely with evolving communication technologies and reflects increased regulatory scrutiny of text message marketing and automated outreach practices.
New Consent Standard for Telemarketing and Text Message Marketing
SB 992 also establishes a new statutory consent standard. To qualify as valid consent, a consumer’s agreement must:
- Be signed by the consumer;
- Identify the telephone number that may be contacted;
- Clearly and conspicuously disclose that the consumer agrees to receive telephone solicitations, including robocalls and text messages; and
- State that consent is not a condition of purchasing property, goods, or services.
Importantly, communications sent to consumers who have provided valid consent generally fall outside the Act’s definition of “telephone solicitation.”
Businesses should evaluate whether their current online lead-generation forms, website disclosures, SMS marketing programs, customer intake processes, and consent records satisfy these new statutory requirements.
New Compliance Obligations and Enforcement Risk
SB 992 imposes several operational requirements on businesses conducting telephone solicitations in Pennsylvania.
Among other things, the law:
- Prohibits telephone solicitations on Sundays;
- Restricts solicitations between 7:00 p.m. and 9:00 a.m.;
- Requires businesses to honor text message opt-out requests using common keywords such as “STOP,” “QUIT,” “CANCEL,” or “UNSUBSCRIBE”;
- Strengthens restrictions on caller ID spoofing and misleading caller identification practices; and
- Prohibits unfair or deceptive acts used to obtain a consumer’s consent.
The potential exposure for noncompliance is significant. A violation of the Act constitutes a violation of Pennsylvania’s Unfair Trade Practices and Consumer Protection Law (“UTPCPL”), 73 P.S. § 2246(a). Businesses may face enforcement actions by the Pennsylvania Attorney General, including civil penalties of up to $1,000 per willful violation. The law also creates potential exposure to private litigation under the UTPCPL, including claims for actual damages or $100 plus attorneys’ fees. 73 P.S. § 201-9.2(a).
Key Takeaways for Businesses
With the October 18, 2026 effective date approaching, businesses should take proactive steps to assess their telemarketing and consumer communications compliance programs. In particular, companies should review:
- Consent collection and recordkeeping practices;
- SMS and text message marketing programs;
- Website lead-generation forms and disclosures;
- Calling and outreach procedures;
- Opt-out mechanisms and suppression processes;
- Vendor and marketing service provider agreements; and
- Use of artificial intelligence, automated dialing technologies, prerecorded messages, and other automated communication tools.
Because Pennsylvania’s new requirements overlap with federal telemarketing laws, including the Telephone Consumer Protection Act (TCPA), businesses should carefully evaluate how their existing compliance programs address both federal and state obligations.
Squire Patton Boggs’ Data Disputes team has significant experience defending consumer privacy and telemarketing claims and in helping businesses navigate the overlapping requirements of federal and state telemarketing laws. Stay tuned to Privacy World to be kept in the loop on further developments.