One federal statute, nine state rulebooks stacked on top — the mini-TCPA map for outbound teams, tracked and cited.
State Mini-TCPA Laws: The 2026 Tracker
State mini-TCPA laws are state telemarketing statutes that stack stricter rules on top of the federal TCPA — broader autodialer-consent triggers than 47 U.S.C. § 227, 8 p.m. curfews instead of 9, three-call-per-24-hour caps, and private lawsuits at $500 to $1,500 per violation. Florida started the wave in 2021; Oklahoma (2022), Connecticut (2023), and Maryland (2024) followed, Washington and Virginia run their own variants, and Texas, Arizona, and New Jersey police outbound calling through registration and no-call regimes instead. Here is the tracker, as of July 2026.
This page is education, not legal advice. A dialer is a tool — compliance depends on how you use it. Enzo does not scrub lists against national or state DNC registries — run every list through a third-party scrubbing service before uploading it, and keep signed consent records wherever a state requires them. Have telemarketing counsel confirm every state you call into.
What Makes a Law a “Mini-TCPA”
After Facebook v. Duguid (2021) read the federal autodialer definition down to equipment using a random or sequential number generator, states began writing their own — broader — triggers. The statutes that followed share four recurring parts: a state consent trigger (prior express written consent, PEWC, before calls made with an “automated system” for selecting or dialing numbers, or playing a recorded message); tighter hours and frequency caps (8 p.m. cutoffs instead of the federal 9 p.m.; three calls per 24 hours in Florida, Oklahoma, and Maryland); area-code presumptions (a call to an in-state area code is presumed to reach an in-state resident); and their own damages — direct $500-per-violation private rights with treble multipliers in some states, consumer-protection-act enforcement with five-figure per-violation penalties in others.
The Tracker: Nine States, Verified Row by Row
Only verified rules appear below; where a state’s chapters set no hours rule, the row says so. States not listed default to federal law plus whatever appears in the 50-state directory.
| State (law) | Autodialer / consent standard | Hours & frequency | Private suit | Cite |
|---|---|---|---|---|
| Florida (FTSA, 2021; amended May 25, 2023) | PEWC for automated selection and dialing or recorded message | 8 a.m.–8 p.m.; 3 calls/24 h same subject (Telemarketing Act) | $500 or actual damages; treble to $1,500 for willful/knowing | Fla. Stat. §§ 501.059, 501.616(6) |
| Oklahoma (Telephone Solicitation Act, eff. Nov. 1, 2022) | PEWC for automated selection or dialing or recorded message | 8 a.m.–8 p.m.; 3 calls/24 h same subject | $500 or actual damages; up to treble for willful/knowing | 15 O.S. §§ 775C.1–775C.6 |
| Maryland (Stop the Spam Calls Act, eff. Jan. 1, 2024) | PEWC for automated selection or dialing or recorded/artificial voice — calls, texts, voicemail | 8 a.m.–8 p.m.; 3 solicitations/24 h same subject | Indirect — via Maryland Consumer Protection Act (actual damages + fees) | Md. Com. Law §§ 14-4501–14-4503 |
| Connecticut (PA 23-98, eff. Oct. 1, 2023) | PEWC default for telephonic sales calls — live, automated, recorded, soundboard, text — with wide carve-outs | 9 a.m.–8 p.m.; 10-second disclosure and hang-up rules | Indirect — via CUTPA; fines up to $20,000 per violation | Conn. Gen. Stat. §§ 42-284, 42-288a |
| Washington (Robocall Scam Protection Act, 2022) | No consent trigger; 30-second identification, 10-second hang-up, 1-year DNC honor | 8 a.m.–8 p.m. | $1,000 per individual violation, for repeated violations | RCW 80.36.390; RCW 19.158.040 |
| Virginia (Telephone Privacy Protection Act) | Texts to Virginia numbers covered; first-and-last-name identification; 31-day national-registry scrub | 8 a.m.–9 p.m. | Greater of actual damages or $500 (1st), $1,000 (2nd), $5,000 (each later) | Va. Code §§ 59.1-510 to 59.1-518 |
| Texas (chs. 302–305; SB 140 eff. Sept. 1, 2025) | No consent trigger; registration ($200 + $10,000 security) + combined no-call list; texts included since Sept. 1, 2025 | No general curfew in chs. 302–305 (separate Texas hour rules exist) | $500 per violation; up to $1,500/treble for knowing — includes federal TCPA violations | Tex. Bus. & Com. Code chs. 302–305 |
| Arizona (registration regime) | No state dialer or consent standard beyond federal law; annual registration + $100,000 bond | Federal default (8 a.m.–9 p.m.) | None in the act — Attorney General enforcement | A.R.S. §§ 44-1271 to 44-1278 |
| New Jersey (Do Not Call Law, 2003) | No consent trigger; registration + state list built from the national registry; outright ban on unsolicited sales calls to cell phones | No calls 9 p.m.–8 a.m. | No express private right — CFA suits require ascertainable loss | N.J.S.A. 56:8-119 to 56:8-135 |
“Selection AND Dialing” vs. “Selection OR Dialing”
The highest-stakes word on this page is a conjunction. Florida’s FTSA originally required consent for calls using an automated system for the “selection or dialing” of numbers; HB 761, effective May 25, 2023, narrowed the trigger to systems that do both — selection and dialing — and added a 15-day text-message safe harbor (reply “STOP”; suit lies only for texts sent after the 15-day window). For pre-amendment conduct, suits already on file may proceed under the older, broader standard; courts have differed.
Oklahoma and Maryland kept the disjunctive: under 15 O.S. § 775C.3(A) and Md. Com. Law § 14-4502(a)(3), an automated system for the selection or dialing of numbers triggers the written-consent requirement — no random-or-sequential-generator element at all. No appellate court has authoritatively construed how far “automated system” reaches beyond the federal ATDS definition, so these statutes may cover list-based and predictive dialing that federal law leaves alone; courts have not settled the boundary — ask counsel.
Florida: The Template
Florida gets the full treatment at Florida telemarketing laws; the short version: under Fla. Stat. § 501.059(1)(g), valid consent is a signed written agreement clearly authorizing automated or recorded sales calls to a specified number, with a disclosure that signing is not a condition of purchase (e-signatures count), and the § 501.059(10) private right pays the greater of $500 or actual damages, trebled up to $1,500 for willful or knowing violations.
Two things commonly get misfiled under the FTSA. The 8 a.m.–8 p.m. window and 3-call/24-hour cap actually live in the Florida Telemarketing Act, § 501.616(6), enforced primarily by FDACS and the Attorney General — the FTSA’s $500 private right attaches to § 501.059 violations. And Florida runs its own FDACS Do Not Call list, separate from the national registry: solicitors must screen against the current quarterly listing (consumer registration is free), and FDACS can impose civil penalties of up to $10,000 per violation.
Texas: Registration, a Combined List, and SB 140
Texas polices outbound calling through three chapters, covered in depth at Texas telemarketing laws. Chapter 302 requires a registration certificate per business location before soliciting from Texas or to a purchaser located in Texas — a $200 filing fee plus $10,000 in security, renewed annually; knowingly soliciting without it is a Class A misdemeanor, each violation a separate offense, alongside civil penalties of up to $5,000 per violation. Chapter 304 runs a combined no-call list — state registrants plus the Texas slice of the national registry — republished quarterly, with a 60-day rule: no calls to a number more than 60 days after it appears.
The realistic private hook is § 305.053: anyone who receives a communication violating 47 U.S.C. § 227, an FCC regulation under it, or the Texas chapter may sue for the greater of $500 per violation or actual damages, increased up to the greater of $1,500 or treble actual damages for knowing conduct. (Chapter 304’s own no-call action is heavily conditioned — second violation, prior notice, verified complaint within 30 days, 120 days of agency inaction — so do not model it as a $500-per-call remedy.) SB 140, effective September 1, 2025, folded text and image messages into “telephone solicitation” and made no-call violations Deceptive Trade Practices Act violations — for conduct on or after that date only. One caution: chapters 302–305 set no general voice-call curfew; Texas hour limits live in separate provisions — see calling hours by state.
Oklahoma, Maryland, Connecticut, Washington, Virginia
The table carries the windows, caps, and damages; here is what it can’t hold:
- Oklahoma has two regimes — do not merge them. The 2022 Telephone Solicitation Act (15 O.S. §§ 775C.1–775C.6) carries the consent trigger, area-code presumption, private right, and 26 exemptions; the older Telemarketer Restriction Act (15 O.S. § 775B.3) has the Attorney General run a separate state DNC registry covering calls and texts, and the § 775C private right does not attach to § 775B registry violations.
- Maryland’s Stop the Spam Calls Act reaches calls, texts, and voicemail alike. Enforcement runs through the Maryland Consumer Protection Act — civil penalties up to $10,000 for a first violation and $25,000 for repeats under that act, plus a private action for actual damages and attorney’s fees; the telemarketing subtitle itself sets no fixed statutory damages.
- Connecticut makes PEWC the default but carves out consumer inquiries, purchasers within the prior 12 months, existing customers absent an opt-out, B2B contacts, and noncommercial calls. Its state list is, by statute, the National DNC Registry — and PEWC is required to telemarket to any mobile number not on it.
- Washington violations are per se Consumer Protection Act violations on top of the fine, and the private action requires repeated violations, at $1,000 per individual violation — not a Florida-style per-call right.
- Virginia requires honoring the national registry with a version no more than 31 days old — it keeps no separate state registry — and its Attorney General can seek up to $5,000 per violation on top of the tiered private damages.
The Registration States: Arizona and New Jersey
Arizona imposes no autodialer-consent standard, hours, or frequency cap beyond federal law. Its regime is registration: a verified statement filed with the Secretary of State before soliciting from or into Arizona (annual, expiring June 30), a $100,000 surety bond, and a 3-business-day consumer cancellation right, enforced by the Attorney General. Arizona treats unregistered telephone solicitation as a criminal offense (reported as a class 5 felony).
New Jersey requires annual registration with the Division of Consumer Affairs, may require a bond of not less than $25,000, and builds its state no-call list from the FTC’s national registry. It adds a 30-second identification rule, a 9 p.m.–8 a.m. no-call window — and one standout, N.J.S.A. 56:8-130’s outright ban on unsolicited telemarketing sales calls to cell phones. Violations draw Consumer Fraud Act penalties up to $10,000 for a first offense and $20,000 after, with a written-procedures safe harbor; there is no express private right, and CFA suits require an ascertainable loss.
State Do-Not-Call Registries Stack on Top
Industry compliance charts, current as of late 2025, list eleven states operating their own do-not-call registries in addition to the national list: Colorado, Florida, Indiana, Louisiana, Massachusetts, Mississippi, Missouri, Oklahoma, Pennsylvania, Tennessee, and Texas — treat that roster as a starting point and confirm on each state’s official portal. Connecticut’s and New Jersey’s statutory lists are defined as, or built from, the national registry; Virginia points entirely to it; and Wyoming — which several charts still list as an own-registry state — officially directs consumers to the national registry instead. Access fees are published on each state’s portal; the only statutory caps verified here are Texas’s ($75 per list distribution to telemarketers; consumer registration capped at $3, free online), while Florida’s FDACS sells its quarterly list “for a fee” set administratively.
Running One Program Under Nine Rulebooks
The operational translation is shorter than the statutes:
- Set each campaign’s window to the strictest state on its list — 8 p.m. cutoffs for Florida, Oklahoma, Maryland, and Washington; a 9 a.m. start for Connecticut.
- Cap attempts at three per 24 hours on the same subject wherever Florida, Oklahoma, or Maryland numbers appear.
- Build consent records to the Florida definition — signed, number-specific, with the not-a-condition-of-purchase disclosure — and they travel well in the “or” states.
- Scrub state lists, not just the national registry, through a third-party service before any list touches a dialer — the area-code presumptions mean a 954 or 405 number is presumed in-state.
- Keep your master suppression file outside the dialer and re-apply it to every new campaign.
Enzo’s part is deliberately narrow: campaign scheduling holds whatever window you give each campaign, and campaign-level internal DNC keeps a marked contact out of that campaign — per-campaign only; marks do not carry across campaigns, and Enzo does not scrub against national or state registries. The dialer itself is compliant as a tool; whether your calling program is compliant depends on your lists, your records, and the windows you set.
See how campaign scheduling and per-campaign DNC handle a multi-state list — book a free discovery call.
Not legal advice. This guide is general information for outbound calling teams, not legal advice. Rules change and apply differently by state, industry, and call type — confirm your program with qualified telemarketing compliance counsel.
State statutes cited inline — Fla. Stat. §§ 501.059, 501.616; Tex. Bus. & Com. Code chs. 302–305 and SB 140 (2025); 15 O.S. §§ 775B–775C; Md. Com. Law §§ 14-4501–14-4503; Conn. Gen. Stat. §§ 42-284, 42-288a; RCW 80.36.390; Va. Code §§ 59.1-510 to 59.1-518; A.R.S. §§ 44-1271 to 44-1278; N.J.S.A. 56:8-119 to 56:8-135 — as of July 2026. Educational only, not legal advice.