Do you have to tell callers they’re speaking to an AI?

Published October 14, 2026

Does Quebec law require you to say you are an AI?

Not in those words, according to the texts consulted on October 14, 2026. The Act respecting the protection of personal information in the private sector, in the version current to August 12, 2026, contains neither the expression “artificial intelligence” nor an announcement rule specific to conversational robots. A call is still a collection of personal information: name, number, reason for calling, voice. Section 8 therefore applies.

At collection, the business must tell the person the purposes for which the information is collected, the means used, their rights of access and rectification, and their right to withdraw consent. Where applicable, it also names the third party on whose behalf the collection is made, the third parties or categories of third parties to whom the information is communicated, and the possibility that it is communicated outside Quebec, all in simple and clear terms. For a call taken by an AI voice agent, one of the means of collection is an automated system: stating it is the surest way to give complete information.

What does section 12.1 say about automated decisions?

Section 12.1 covers a decision based exclusively on automated processing of personal information. The business must inform the person no later than when it communicates the decision. On request, it states the information used, the reasons and main factors behind the decision, and the right to have the information corrected. The person must also be able to submit observations to a staff member able to review the decision. The Commission d’accès à l’information gives as examples granting credit, assessing a financial support application or assigning a priority to a request.

An agent that takes a message or offers a slot does not, on its own, make a decision of that kind. If yours refuses a service or ranks requests by priority without human involvement, get advice before putting it online.

What do official bodies recommend?

Two federal texts go further than Quebec law, without being laws. The Office of the Privacy Commissioner of Canada, in its generative AI principles (December 7, 2023, modified May 6, 2025), asks that, when a generative AI tool is public-facing, people interacting with it be aware that they are interacting with a generative AI tool and be informed about privacy risks. The Voluntary Code of Conduct of Innovation, Science and Economic Development Canada (modified June 4, 2026) includes ensuring that systems that could be mistaken for humans are clearly and prominently identified as AI systems. That code is voluntary and changes no legal obligation.

How do you say it without losing the caller?

Say it up front, in two sentences, then move on to the request. The announcement also serves the recording notice, which the ATOM Assistant agent plays at the start of every call and which you configure. The greeting is configurable too: the cloned voice sounds natural, one more reason not to let callers think it is a person.

• Name the business, then say it is an AI, in the first sentence
• Announce the recording and the reason for it in a few words
• Offer a person right away: transfer, callback or message
• Avoid a human first name and phrases like “let me check with my colleague”

What if the caller does not want to speak to an AI?

Plan another path before putting the agent online: a transfer to a person during business hours, or a message with a callback. The guide AI voice agents and Law 25 recalls that consent is requested for each purpose and in clear terms, and that a refusal must leave another way open. Also plan who on your side reviews transcripts and answers access requests.

Which privacy policy should you publish?

Section 8.2 requires publishing, on the business’s website, a privacy policy in simple and clear terms when it collects personal information by technological means. In our reading, an AI voice agent is one. Naming the voice agent, its subcontractors and where voice, audio and transcripts are processed makes the call announcement consistent with the policy. If voice, audio or transcripts leave Quebec, section 17 calls for a privacy impact assessment before the communication. The Commission d’accès à l’information reminds businesses that they always remain responsible for the personal information entrusted to them, even when a provider handles the call. The definition of Law 25 gives the framework.