⚖️ AI Outbound Calling: The Compliant Way (GoHighLevel + Vapi)

The purpose of this SOP is to outline how to use AI to do outbound cold calls in a compliant way. I hope this is helpful!

The Reality of AI Cold Calling

As of January 2025, AI cold calling without explicit prior consent is illegal in the USA under FCC regulations. The FCC has classified AI-generated calls as robocalls, requiring consent before contact.

Because of this, people are moving away from traditional AI cold calling and finding AI-powered workarounds, which are often better.

You cannot just put 1,000 leads into your database and start power dialing. If you do this, I am 500% confident that there will be severe repercussions.

You need consent to autodial any cell phone, including a business cell phone. This is true even if the business owner publishes their cell phone number online. And if you robocall a line thinking it's a business line, but it's also used for private purposes, you are at risk of being sued for violating DNC or other consumer protection laws.

This is the time when regulators are going to want to make examples out of people. Think BIG fines. Big legal cases.

Top Compliant AI Outbound Strategies

The main focus point here is that we need to get explicit permission to reach out to people. Anyway, here are compliant workarounds that I can recommend.

Consent-Based AI Systems

• Only call numbers that explicitly opted in

• Use lead magnets, forms, and existing relationships

• Document all consent with timestamps

Inbound AI Handling

• AI answers calls prospects initiated

• No consent required - they called you

• Can qualify and transfer to humans

Here are the main use cases

1. Pay-Per-Lead Platforms (Google LSA, Angie's, Thumbtack) Consumer searches for services → platforms connect them with providers

• Compliance: Consumer initiates contact and expects calls

2. Paid Ads to Lead Magnets PPC ads drive traffic to valuable content requiring contact info

• Compliance: Explicit consent provided for follow-up

3. SEO/Content Marketing Organic content attracts prospects who contact you voluntarily

• Compliance: Person discovers your content and self-initiates contact

Beyond these three strategies, the only legal AI outbound approaches involve contacting people who have already provided explicit consent for that specific communication method (calls, texts, emails). There are no magic workarounds for true cold outbound AI contact without consent.

This approach is 100% legal and more effective than traditional cold calling methods. It focuses on a "value-first" (i.e., Lead magnets) strategy where leads actively provide consent before being contacted, thereby avoiding unsolicited calls, which are the core problem with traditional cold calling.

Technical Implementation Using GoHighLevel + Vapi

Here’s the Breakdown & Tool Requirements

• GoHighLevel (Pro plan) - CRM, workflow builder, phone/SMS. $97/mo per sub-account

• Vapi (Growth tier) - Voice-AI platform & call API. $99/mo + $0.02/min outbound

Total base cost: ≈$198/month plus usage fees

Step 1: Create Lead Magnet

A valuable resource (e.g., "insider buyer guide," "seller success checklist,” “Free Revenue Estimate,” “<Service> Tips & Tricks”) promoted via:

• Facebook ads or other campaigns

• Website integration

• Cold email campaigns

Step 2: Build Lead Capture Form

This form collects:

• Name, Business Email, Phone Number

• Interest (e.g., "looking to buy a home in Santa Monica")

• Must include explicit consent language: "I consent to receive automated calls, including those using AI-generated voices, at the phone number provided. I understand I can revoke this consent at any time." (Something like this.)

• Store consent timestamp and IP address for compliance documentation

Step 3: Set Up Vapi Assistant

1. Create a new assistant in Vapi Dashboard

2. Configure:

   • Assistant's name and greeting

   • Voice settings and model

   • Working hours and timezone

   • System Prompt Example:

You are a helpful lead qualification assistant. Your goal is to:

1. Greet the prospect by name: "Hi {{firstName}}, this is about the {{interest}} guide you requested..."

2. Qualify their specific needs and timeline

3. Determine budget and decision-making authority

4. If qualified, offer to schedule an appointment

5. If not interested, politely end the call

Always be conversational and helpful. Use the information provided:

• Name: {{firstName}} {{lastName}}

• Address: {{streetAddress}}

• Interest: {{interest}}

NOTE: This is connected to your calendar, FAQs, and other knowledge that you upload. That is how we make the agent intelligent.

Step 4: Configure GoHighLevel Workflow

1. Navigate to Automations → Create Workflow

2. Set Trigger: Form submission

3. Add Phone Number Formatter (E.164 standard)

4. Add Custom Webhook Action:

   • Method: POST

   • URL: https://api.vapi.ai/call

   • Add the correct Webhook headers & payload

Header Example

Authorization: Bearer YOUR_VAPI_API_KEY

Content-Type: application/json

Body (JSON):

{

"phoneNumberId": "YOUR_VAPI_PHONE_NUMBER_ID",

"customer": {

"number": "{{contact.phone}}",

"name": "{{contact.first_name}} {{contact.last_name}}"

},

"assistantId": "YOUR_ASSISTANT_ID",

"assistantOverrides": {

"variableValues": {

"firstName": "{{contact.first_name}}",

"interest": "{{contact.interest}}",

"streetAddress": "{{contact.address}}"

}

}

}

Step 5: Lead Magnet Delivery

• Add SMS Action to end-of-call workflow

• Conditional Logic: Based on qualification results

• Dynamic Content: Send appropriate lead magnet

• Delivery: SMS with download link

Step 6: Follow-Up Automation with Opt-Out Handling

If Call Not Answered:

• Check opt-out status before each attempt

• Wait 2 hours → Trigger another Vapi call

• Wait 1 day → Trigger final Vapi call

• Send SMS with calendar booking link and opt-out instructions

Best Practices

Compliance Documentation: If you go down this route, we want to make an emphasis on documentation. You never know when you’ll need it.

• Store consent records with timestamp, IP, and exact language

• Maintain all your call logs

• Take opt-outs seriously

• Regular DNC registry updates

Overview

You now have a plug-and-play SOP for outbound AI calling that removes manual dialing, keeps you 100% compliant, increases your speed to lead, automates nurturing, and is very cost-effective.

The system offers huge cost savings. You do not need to go through the whole hiring, training, managing, and firing process with staff to do this. It is very quick to set up.

Hand this guide to your virtual assistant, and they can set this up. I hope this is thought-provoking!

Contact Us — Virtual Assistant Services for AI Implementation

Our virtual assistants help companies set up AI-powered outbound systems. We handle the complete setup process, including lead skiptracing, data prep, GoHighLevel configuration (Automations & Workflows), integrations, and AI agent deployment across different channels (voice, SMS, email).

What we handle:

• AI agent configuration for voice, SMS, and email outbound

• GoHighLevel API integrations and webhook setup

• Lead generation infrastructure, including skiptracing

• Paid advertising setup on Google and Facebook platforms

• Ongoing technical administration of GHL environments

Would love to chat and introduce you to the team: https://www.csoutsource.com/why-cs-outsource/