Hawaii Quarterly Law Update: 110 Million Robocalls, $1,000 UDAP Minimums, and Why Island Time Does Not Apply to the TCPA

By Christopher Prosser, BA AA, CLA • September 10, 2026

State-by-State Updates

Hawaii is the lowest complaint-rate state in this ten-pack — 393 Do Not Call complaints per 100,000 in 2025 — and that is the trap. Callers treat the islands as a rounding error. YouMail still counted 110,042,400 robocalls in 2025 and 69,068,800 already in 2026.

2025 DNC complaints: 5,675, up 9.2%.

Federal floor: TCPA, 47 U.S.C. § 227 — $500 per illegal call or text, $1,500 if knowing or willful. Four-year clock.

Hawaii layer:

  • Telemarketing Fraud Prevention Act, HRS ch. 481P — abusive telemarketing is an unfair or deceptive practice.
  • HRS § 480-2 / § 480-13 (UDAP). A consumer harmed by an unfair or deceptive act may recover no less than $1,000 or treble damages, whichever is greater, plus attorney’s fees. Elderly consumers get extra protection. Class actions are allowed. No pre-suit demand required.

What changed: No 2026 mini-TCPA. Hawaii joined the 49-AG FCC letters on carrier “know your customer” rules. The live private dollars are still TCPA plus 480-13 if the pitch itself was deceptive.

Left on the table: 5,675 × $500 ≈ $2.8 million. × $1,500 ≈ $8.5 million. Stack a $1,000 UDAP floor on a deceptive sales call and the same file grows. One hundred ten million estimated robocalls means the real gap is larger if even a sliver were illegal autodialed or DNC hits.

Register at donotcall.gov. Log date, time, number, and what they sold. File with the Hawaii Office of Consumer Protection. Use the Hawaii Playbook.

This is a Q3 2026 TeleJustice Academy quarterly law update. Figures: YouMail Robocall Index (estimated volume); 2025 DNC complaint counts and per-capita rates from the FTC Data Book cycle. “Money left on the table” is complaint count × TCPA statutory minimums — an illustration, not a prediction. Robocall indexes include legal recorded calls. Only documented illegal calls and texts support a claim. Educational only. Not legal advice. TeleJustice Academy is not a law firm. Protect the file: donotcall.gov · state list where one exists · call log with date, time, number · screenshots · your state Playbook at telejusticeacademy.com and telejusticepro.com.


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Disclaimer: TeleJustice Academy, LLC is not a law firm. We provide educational and informational materials only. Nothing on this website constitutes legal advice, creates an attorney-client relationship, or guarantees any outcome. Always consult a licensed attorney for advice specific to your situation.

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