What the NZ Unsolicited Electronic Messages Act means for AI agents

Short answer

The Unsolicited Electronic Messages Act 2007 applies to commercial texts and emails with a New Zealand link, whether a person or an AI agent sends them. Commercial messages need consent, must identify the sender, and must include a working unsubscribe that's honoured within 5 working days. Agentline goes further for SMS: it allows only transactional, one-to-one messages and blocks marketing outright.

Who it applies to

The Act covers commercial electronic messages (email, SMS, MMS and instant messages) with a New Zealand link. It doesn't matter that software wrote or sent the message: the person or business behind the agent is responsible. The Department of Internal Affairs (DIA) enforces it.

What counts as commercial

A message is commercial if it markets or promotes goods, services, land, or a business or investment opportunity. Some messages aren't treated as commercial even when a business sends them, such as a quote or estimate the person asked for, or a message that confirms or completes a transaction they've already agreed to. Most of what a well-behaved assistant sends (replies, booking confirmations, reminders someone requested, codes) falls on the non-commercial side, but the content decides, not the sender.

The three rules for commercial messages

Consent. Express consent, consent that can reasonably be inferred from an existing relationship, or an address published for business contact where the message is relevant.
Identify the sender. Say who the message is from and how to contact them.
Working unsubscribe. Every commercial message needs a free way to opt out, honoured within 5 working days.

How Agentline applies it

SMS: transactional and assistant messages only (replies, bookings, confirmations, reminders people asked for, codes). Promotional texts are blocked automatically, even with consent.
STOP: a reply of STOP (or UNSUBSCRIBE, CANCEL, QUIT and similar) opts the person out immediately, and further texts to them are refused. START opts them back in, and HELP gets a reply saying the number is operated by an AI agent through Agentline, with how to opt out and report abuse.
Content checks: link shorteners, phishing patterns and impersonation are refused before a text leaves.
Email: marketing email is allowed only to people who opted in, with sender details and an unsubscribe.
New accounts: Free and trial accounts can message only the owner, so nobody can sign up and start texting strangers.

Practical rules for your agent

Tell it to text only people who contacted you or asked to hear from you.
Have it introduce itself as your assistant and say who it's acting for.
Don't ask it to send promotions by SMS at all; Agentline will refuse them.

This is a summary, not legal advice. See our compliance page and the Act itself.

Common questions

Does the UEMA apply to messages an AI agent writes?

Yes. The Act looks at the message, not who or what wrote it. The person or business the agent acts for is responsible for its commercial messages.

Can my agent send promotional texts through Agentline?

No. Agentline SMS is for transactional and assistant messages only, and promotional texts are blocked even if the recipient consented. Marketing email is allowed only to people who opted in, with an unsubscribe.

What happens when someone replies STOP?

They're opted out immediately and Agentline refuses further texts to them from that account. If they reply START, they're opted back in.

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