Quick answer: AI cold calling is not banned in the UAE. Cabinet Resolution No. 56 of 2024 allows automated marketing calls by licensed, approved companies, but only from 9:00 am to 6:00 pm, from numbers registered to the company’s licence, never to Do Not Call Registry numbers and, on its wording, only to people who asked. Fines reach AED 150,000.
Is AI cold calling legal in the UAE?
AI cold calling means an unsolicited sales call in which the voice is generated by software. In the UAE it is governed by Cabinet Resolution No. 56 of 2024 Concerning the Telemarketing Regulations, in force since 27 August 2024, with penalties in Cabinet Resolution No. 57 of 2024. The Ministry of Economy supervises; the Telecommunications and Digital Government Regulatory Authority (TDRA) runs the Do Not Call Registry (DNCR) and fines individuals; licensing authorities, the Central Bank and the Securities and Commodities Authority (SCA) police companies in their sectors. Lead data falls under Federal Decree-Law No. 45 of 2021, the Personal Data Protection Law (PDPL).
So “is cold calling illegal in the UAE?” has a two-part answer. Telephone marketing by a licensed company is lawful, and may be automated, but only inside 13 company obligations and 9 call controls, one of which reads, on its face, as an opt-in rule: Article 4(4) requires a company to “Create a communication channel for Consumers interested in obtaining marketing information, and marketing communication is only made with these Consumers.” A call to someone who never came through that channel is the classic cold call, and the text does not support it.
That makes the UAE unusual in this series. In the UK the open question is whether AI speech is “live” (see whether AI cold calling is legal in the UK under PECR regulation 19); in India it is which number series the call travels on (see AI cold calling under India’s TRAI rules). The UAE answers the AI question in one sentence and puts the risk in the operating rules. The English texts are the portal’s translations, and the portal says the Arabic text prevails; sources were read on 10 October 2026; this is not legal advice.
Does the UAE allow automated or AI telemarketing calls?
Yes. Article 5(6) of Resolution No. 56 reads: “Automated communication systems may be used for marketing, advertising and promoting the products or services provided by the Company in accordance with the provisions of this resolution.” The Ministry of Economy’s briefing of 29 August 2024 restates it more tentatively, as “Automated communication systems are possibly used”, but the resolution’s own wording is permissive.
Neither resolution mentions artificial intelligence, synthesised voices or voice cloning; a search of both English texts for “artificial”, “intelligence”, “voice” and “robot” finds nothing, while “automat” finds Article 5(6). So the general provision governs: an AI voice agent is an automated communication system, and “in accordance with the provisions of this resolution” brings every other duty with it. Resolution No. 57 gives the automation clause its own fine row, number 16, for “Using automatic calling or marketing, promotion and advertisement of products or services provided by the company in violation of provisions of this Resolution”: AED 10,000, 25,000 and 50,000 for the first, second and third offence.
Three duties become the AI agent’s opening script. Article 4(11): identify the company and the purpose “at the beginning” of the call. Article 4(7): record the call, “informing the Consumer of this recording when the call begins.” Article 5(7): “Ask the Consumer whether he wants to continue the Phone Call or not before starting to market”. Only then the pitch.
We found no duty in either resolution to say the caller is an AI. That is a gap in the text, not a recommendation: Article 5(2) bans deception and misleading, so on our reading an agent that claims to be human when asked is exposed under the fraud row, at AED 25,000 for a first offence.
In one sentence: the UAE permits AI telemarketing by licensed companies, and fines the AI call for every rule a human call would break.
What “cold” calling the UAE rules do not allow
The boundary sits in three places.
People who never asked. Article 4(4) limits marketing communication to consumers who came through the company’s channel for people “interested in obtaining marketing information”. The resolution defines “Unwanted Marketing Phone Calls” as calls made in violation of its provisions, and says they “do not include Marketing Phone Calls made at the request of the Consumer.” The clean case is a requested call; the weak case is a bought or scraped number. What cuts the other way: Resolution No. 57’s 18 fine rows cite Article 4 clauses 1, 2, 3, 5, 6, 7, 8, 11 and 12, and none cites Article 4(4). Calling outside the opt-in channel is still a breach, open to Resolution No. 57’s general penalties (warning, suspension for 7 to 90 days, licence cancellation), but it has no listed fine of its own.
People on the Do Not Call Registry. Article 4(5) says “Do not call for marketing products or services to Consumers whose numbers are listed on the DNCR.” It states no consent exception. The operator e&, in its DNCR guidance for business customers, updated August 2026, goes further in its own words: telemarketers may not contact DNCR-listed individuals “even if prior consent has been obtained”. Calling a DNCR number is fined at AED 50,000, then 75,000, then 150,000.
People calling from their own number. Article 3(2) bars natural persons from making marketing calls “using a fixed or mobile number licensed in their name”, and Article 4(3) requires companies to use local numbers issued by UAE-licensed telecom companies and “registered under the commercial licence of the Company licensed in the State.” A company’s AI agent on an overseas DID or a personal SIM fails Article 4(3); an individual running one from a number in their own name is caught by Article 3(2).
On scope, Article 3(1) covers “all companies licensed in the State, including those located in free zones”, and says nothing about an unlicensed foreign company calling in. The route the text provides is a UAE-licensed entity with approval and numbers registered to its licence; e& tells businesses with teams abroad it is their responsibility “to abide by the rules and regulations of the regulatory framework in the U.A.E.”
The boundary in one sentence: a lawful UAE AI marketing call comes from a licensed, approved company’s registered number, to a person who asked for it and is not on the DNCR.
The UAE Call-Permission Grid: what an AI campaign may and may not do
Find what your AI campaign does and read across. Each row is one clause of Resolution No. 56 with its company fine from Table No. 1 of Resolution No. 57. Rows G and R are permitted; row Q has no fine row. Table 1’s three company-level rows (staff training, the call register and periodic reports, each AED 10,000 for a first offence) are in the checklist further down.
| Row | What the AI campaign does | Clause | Verdict | 1st fine (AED) | 2nd (AED) | 3rd (AED) |
|---|---|---|---|---|---|---|
| A | Company has no prior approval from its competent authority to practise telemarketing | Res 56 Art 4(1) | Not permitted | 75,000 | 100,000 | 150,000 |
| B | Calls from a number that is not a local number registered under the company’s commercial licence (a personal SIM, an overseas DID, a borrowed line) | Art 4(3), 4(13) | Not permitted | 25,000 | 50,000 | 75,000 |
| C | Calls a number listed on the Do Not Call Registry, with or without earlier consent | Art 4(5) | Not permitted | 50,000 | 75,000 | 150,000 |
| D | Calls at 8:30 am or 6:15 pm | Art 5(3) | Not permitted (window is 9:00 am to 6:00 pm) | 10,000 | 25,000 | 50,000 |
| E | Calls back a person who rejected the product or service on the first call | Art 5(4) | Not permitted | 10,000 | 25,000 | 50,000 |
| F | Redials a person who did not answer or ended the call: a second time the same day, or a third time in the same week | Art 5(5) | Not permitted (cap: once a day, twice a week) | 10,000 | 25,000 | 50,000 |
| G | Redials a non-answer once on Monday and once on Thursday | Art 5(5) | Permitted, if every other row is met | – | – | – |
| H | Starts pitching before asking whether the person wants to continue the call | Art 5(7) | Not permitted | 10,000 | 20,000 | 30,000 |
| I | Does not record the call | Art 4(7) | Not permitted | 10,000 | 25,000 | 50,000 |
| J | Records but does not tell the person at the start of the call | Art 4(7) | Not permitted | 10,000 | 20,000 | 30,000 |
| K | Does not name the company and the purpose of the call at the start | Art 4(11) | Not permitted | 10,000 | 20,000 | 30,000 |
| L | Runs on an automated system in breach of any of the other provisions | Art 5(6) | Automation itself permitted; breach fined separately | 10,000 | 25,000 | 50,000 |
| M | Puts unjustified pressure on the person to accept the product or service | Art 5(1) | Not permitted | 10,000 | 25,000 | 50,000 |
| N | Deceives or misleads about the product or service | Art 5(2) | Not permitted | 25,000 | 50,000 | 75,000 |
| O | Cannot say where it got the number or the person’s data when the authority asks | Art 4(12) | Not permitted | 25,000 | 50,000 | 75,000 |
| P | Discloses a person’s data without consent, or trades lead data for reprocessing into marketing calls | Art 6(4) | Not permitted | 50,000 | 75,000 | 150,000 |
| Q | Calls a person who never came through your channel for people interested in marketing information | Art 4(4) | Not permitted on the text; no Table 1 fine row | No row | No row | No row |
| R | Calls a person who asked you to call them | Art 1, “Unwanted Marketing Phone Calls” | Permitted, if every other row is met | – | – | – |
The grid in one sentence: an AI call in the UAE is permitted only when it clears every row at once, and the three most expensive rows (A, C and P) concern approval, the registry and the data, not the AI.
Four cells need care. Row F is two caps joined by “and”: no call back to a person who “does not answer the call or ends the call, more than once a day and a maximum of twice a week.” Row G is our reading: a non-answer redialled on two different days of one week. Row D’s window has no time-zone wording and no rule for weekends or public holidays. And row L: the resolution does not say whether the automation fine stacks with the specific row an AI call breaks.
Repeat offenders lose the ladder: an authority may impose “the most severe administrative penalty” if a company repeats a violation within six months of an earlier penalty for it. Appeals run 15 days from notice; an appeal not decided within 30 days is treated as rejected.
Planning AI outbound into the UAE? Zian AI runs phone, SMS, email and WhatsApp sales agents in 30+ languages, with SmartReach AI™ orchestrating message, channel and timing by country, industry and profile, and intelligent follow-up pacing. Zian is in partnership-application beta.
What does a non-compliant AI campaign cost? A worked example
Take one AI campaign with four configuration defects: an unscrubbed list, a dialling window past 6:00 pm, an opening that skips the recording notice, and a short variant that drops the company name and purpose. Adding the Table No. 1 fine for each:
| Defect in the AI script or dialler | First time | Second time | Third time |
|---|---|---|---|
| Calls DNCR-listed numbers (row C) | 50,000 | 75,000 | 150,000 |
| Calls after 6:00 pm (row D) | 10,000 | 25,000 | 50,000 |
| No recording notice at the start (row J) | 10,000 | 20,000 | 30,000 |
| No company name or purpose at the start (row K) | 10,000 | 20,000 | 30,000 |
| Total if one fine per violation type | 80,000 | 140,000 | 260,000 |
Two limits. Resolution No. 57 does not say whether a fine attaches per call, per campaign or per violation type, so these totals assume one per type. And they leave out Article 3’s other penalties, which can hurt a calling business more: suspension for 7 to 90 days, or licence cancellation, deletion from the commercial register and cut communications services.
Operators add a layer. e& says that from 1 September 2026 numbers collect black points under its Voice Spam Policy – DNCR; at 5 black points the line enters a Do Not Originate Register with outgoing calls barred, removal costs AED 5,000 per number, and at 25 black points the trade licence cannot buy or activate telecom services. For an AI stack calling over a pool of numbers on one licence, that last threshold reaches every number on the licence, not just the campaign’s.
For a natural person, TDRA applies Table No. 2 of Resolution No. 57:
| Offence (natural person, Res 57 Table 2) | Fine | Plus |
|---|---|---|
| First violation | AED 5,000 | All fixed and mobile numbers registered in the person’s name cut until the fine is paid |
| Repeat within 30 days of the first penalty | AED 20,000 | All numbers in the person’s name cut for three months |
| Repeat within 30 days of the second penalty | AED 50,000 | Barred from any service of UAE-licensed telecom companies for twelve months |
Enforcement is real. The National reported on 6 August 2026 that TDRA had issued more than Dh19 million in fines and disconnected 9,433 numbers since August 2024, from 92,748 reported numbers and 3,301 violations: TDRA’s figures as reported, as we could not open TDRA’s own announcement.
How the Do Not Call Registry works for AI callers
Resolution No. 56 defines the DNCR as “The unified national registry supervised by TDRA to protect Consumers from unwanted Marketing Phone Calls,” and Article 6(5) lets any consumer register. At the 2024 briefing TDRA’s Deputy Director General said it lets recipients “opt out of receiving marketing calls from specific sectors or all sectors.”
Three facts from e&’s business page shape an AI dialler. Registration “will never expire” unless the number is deactivated and reassigned or the person asks to be removed, so an old scrub is not a current one. From September 2026 organisations “must regularly verify” numbers before promotional calls, free through e&’s Business Online Portal. And earlier consent does not unlock a listed number. We read e&’s page only; TDRA’s own DNCR page returned an error to our network.
The registry in one sentence: scrub every UAE list against the DNCR before each campaign, because a registration never lapses and consent does not override it.
Does the UAE PDPL apply to the lead list behind AI cold calls?
Yes. Federal Decree-Law No. 45 of 2021 covers the personal data of anyone residing or doing business in the UAE, including when processed from abroad, and has been in force since 2 January 2022. Article 4 opens: “It is prohibited to process Personal Data without the consent of its owner.” It lists 11 exceptions, the last being “Any other cases set out in the Executive Regulations”; the two a seller might reach for are narrow: data that “has become available and known to all by an act of the Data Subject”, and processing “necessary to perform a contract to which the Data Subject is a party, or to take measures at the request of the Data Subject”. None of the ten the decree itself spells out is a general legitimate-interests basis, so a bought list is weak ground.
Article 6 requires consent you can prove, in “clear, simple, unambiguous and easily accessible” terms, with an easy right to withdraw. Article 17(1) lets a person object to processing “for the purposes of direct marketing, including profiling related to direct marketing.”
Among its exclusions, Article 2(2)(g) removes free-zone companies that have their own personal data protection legislation (a DIFC or ADGM company is our example, not the decree’s wording). Penalties are left to a Cabinet decision (Article 26), and controllers get six months after the executive regulations to regularise (Article 29); the portal’s page for the decree, archived 5 January 2026, lists no executive regulations among its related legislation, and we could not confirm their status from a live official source. Separately, Resolution No. 56 Article 6(4) bars disclosing a consumer’s data without consent or trading it for reprocessing into marketing calls, fined at AED 50,000 to 150,000. For the Spam Act, TCPA and GDPR equivalents, see our AI outreach compliance overview across Australia, the US and the UK.
Status as at 10 October 2026: which UAE rules are in force
| Instrument | Made | Status |
|---|---|---|
| Cabinet Resolution No. 56 of 2024 (telemarketing regulations) | Issued 10 June 2024; Official Gazette No. 778, 28 June 2024 | Effective 27 August 2024; listed “Active”, last update 10 June 2024 (portal page archived 8 July 2025) |
| Cabinet Resolution No. 57 of 2024 (violations and penalties) | Issued 10 June 2024; Official Gazette No. 778, 28 June 2024 | Effective 27 August 2024; listed “Active”, last update 10 June 2024 (portal page archived 17 February 2026) |
| Federal Decree-Law No. 45 of 2021 (PDPL) | Issued 20 September 2021 | In force from 2 January 2022; listed “Active”, no executive regulations among its related legislation (portal page archived 5 January 2026) |
| e& Voice Spam Policy – DNCR measures | Published by e& as updated August 2026 | Black points, Do Not Originate Register and AED 5,000 per number effective 1 September 2026 (e& page read 10 October 2026) |
We read Resolutions 56 and 57 from Internet Archive copies because the legislation portal refused our requests on 10 October 2026, and found no amending instrument; check the live portal before relying on a clause.
How to check an AI calling plan against the UAE rules
- Confirm the entity. Calls must come from a UAE-licensed company (mainland or free zone) with prior approval for telemarketing from its competent authority (Article 4(1)), and staff trained on conduct and the DNCR (Article 4(2)). Banking, finance and insurance sales answer to the Central Bank and securities to the SCA (Article 9); we did not review their separate rules.
- Get the numbers right. Local numbers from UAE-licensed telecom companies, registered under the company’s commercial licence (Article 4(3)); no personal SIMs, no overseas caller IDs.
- Build the opt-in channel. A form or inbound route for people who want marketing information; call only them (Article 4(4)). Keeping each request on file is our suggestion, not a clause.
- Scrub every list against the DNCR before each campaign (Article 4(5)), and drop listed numbers even where you hold consent.
- Hard-code the window and caps. Dial only from 9:00 am to 6:00 pm; never call back after a first-call rejection; redial non-answers at most once a day and twice a week (Article 5(3) to 5(5)).
- Script the opening. Company name and purpose, recording notice, then ask whether the person wants to continue (Articles 4(11), 4(7) and 5(7)). No pressure, nothing misleading (Article 5(1) and 5(2)).
- Record and log. Record every call, keep the call register in the competent authority’s form until the period it specifies has expired, file periodic reports on time, and know where each number came from (Article 4(6), 4(8) and 4(12)). Sign the authority’s code of professional conduct if it issues one (Article 4(9)), and check for further controls set by the Minister or your competent authority (Article 5(8) and 5(9)).
- Record the data basis for each lead under the PDPL, or the free-zone law that applies to you.
The do-it-yourself cost is configuration and record-keeping: approval, numbers, a scrub per campaign, an opening script, a call log. At volume the risk is the redial cap and the registry, because one unscrubbed list or a retry rule of “three times a day” breaks rows C and F across a whole campaign at once. A platform with follow-up pacing still needs the UAE caps written in as rules. If you also call the US, see whether AI cold calling is legal in the US under the TCPA.
Frequently asked questions about AI cold calling in the UAE
Is cold calling illegal in the UAE?
Not as such, but true cold calling is hard to do lawfully. Cabinet Resolution No. 56 of 2024 allows marketing calls by approved, UAE-licensed companies from licence-registered numbers, 9:00 am to 6:00 pm, never to Do Not Call Registry numbers, and Article 4(4) says marketing contact is “only made with” consumers who came through a channel for people interested in marketing information. Read Resolution No. 56 of 2024 on the UAE legislation portal.
Is cold calling legal in Dubai?
Dubai follows the same federal rules: Resolution No. 56 of 2024 applies to every company licensed in the State, including in free zones. Only the regulator changes: the Central Bank for banks, financial institutions and insurers, the Securities and Commodities Authority for securities and commodities trading, and the company’s licensing authority, mainland or free zone, for everything else.
Can an AI voice agent make telemarketing calls in the UAE?
Yes. Article 5(6) of Resolution No. 56 says “Automated communication systems may be used for marketing, advertising and promoting the products or services provided by the Company in accordance with the provisions of this resolution.” Every other rule still applies: hours, registered numbers, the Do Not Call Registry, recording with notice, naming the company and purpose, and asking whether the person wants to continue.
What are the telemarketing hours in the UAE?
Article 5(3) of Resolution No. 56 of 2024 allows marketing calls “only during the period from 9:00 am to 6:00 pm”. The text sets no separate rule for weekends or public holidays. Calling outside the window carries a fine of AED 10,000 the first time, AED 25,000 the second and AED 50,000 the third, under Table No. 1 of Resolution No. 57 of 2024.
What is the fine for telemarketing violations in the UAE?
Resolution No. 57 of 2024 lists 18 company violations fined from AED 10,000 to AED 150,000, rising on repeat, alongside warnings, suspension for 7 to 90 days or licence cancellation. The Ministry of Economy’s briefing of 29 August 2024 gives the same figures. A person using a personal number faces AED 5,000, then 20,000, then 50,000.
Can my AI agent call a number on the DNCR if the person gave consent?
Do not plan on it. Article 4(5) of Resolution No. 56 bars marketing calls to Do Not Call Registry numbers with no consent exception, and the operator e&’s DNCR guidance, updated August 2026, says so “regardless of prior consent”. A call made at the consumer’s own request is outside the resolution’s definition of an unwanted marketing call, but Article 4(5) itself states no exception for requested calls.
Do the UAE telemarketing rules apply to B2B calls?
The resolution defines a consumer as a natural person and telemarketing as calls to a consumer, and we found no business-to-business exemption in its text. A call to a named person at a company is a call to a natural person, so treat B2B lists like consumer lists.
Does the UAE PDPL apply to AI cold calling?
Yes, to the lead data. Federal Decree-Law No. 45 of 2021 prohibits processing personal data without consent except in 10 listed cases plus any the executive regulations add, and none of the ten is a general legitimate-interests basis, and Article 17 lets a person object to processing for direct marketing. Among its exclusions are free-zone companies with their own data protection legislation.
Running AI sales across several countries? Zian AI’s phone, SMS, email and WhatsApp agents work in 30+ languages, support voice cloning, and integrate with HubSpot, Salesforce, HighLevel and Zapier; private model deployment on your own infrastructure is available. Zian is in partnership-application beta.
Where every figure on this page comes from
| Figure | Who published it | Link | Date read |
|---|---|---|---|
| 9:00 am to 6:00 pm window; once a day, twice a week redial cap; no call back after a first-call rejection; Art 5(6) automated systems; Art 4(1)–(13) duties; consumer = natural person; free-zone scope; 60 days to commencement | UAE Cabinet, Resolution No. 56 of 2024 (English text; Arabic prevails) | uaelegislation.gov.ae, legislation 2519 (read via the Internet Archive copy of the PDF, as the portal refused our requests) | 10 October 2026 |
| Issued 10 June 2024, Gazette No. 778 of 28 June 2024, effective 27 August 2024, status Active | Ministry of Cabinet Affairs, UAE legislation portal | Resolution 56 page and Resolution 57 page (archived 8 July 2025 and 17 February 2026) | 10 October 2026 |
| 18 company violations; every Table 1 fine (AED 10,000 to 150,000); suspension 7 to 90 days; six-month repeat rule; natural-person fines AED 5,000, 20,000, 50,000, 3 months, 12 months, 30 days; appeal 15 and 30 days | UAE Cabinet, Resolution No. 57 of 2024 (English text) | uaelegislation.gov.ae, legislation 2523 (read via the Internet Archive copy of the PDF) | 10 October 2026 |
| 18 types of violation and AED 10,000 to 150,000 range (official confirmation); TDRA manages the DNCR; opt-out from specific sectors or all sectors; regulator split | UAE Ministry of Economy (now Ministry of Economy & Tourism), media briefing dated 29 August 2024 | moet.gov.ae news item | 10 October 2026 |
| PDPL: 11 exceptions to consent (Art 4); direct-marketing objection (Art 17); free-zone exclusion (Art 2(2)(g)); in force 2 January 2022; six months to regularise after executive regulations (Art 29) | UAE Federal Decree-Law No. 45 of 2021 (English text) | uaelegislation.gov.ae, legislation 1972 (read via the Internet Archive copy of 7 September 2026) | 10 October 2026 |
| DNCR since September 2022; “regardless of prior consent”; 5 black points to the DNOR; AED 5,000 per number; 25 black points trade-licence restriction; effective 1 September 2026 | e& (Etisalat), DNCR page for business customers, updated August 2026 | eand.ae DNCR page | 10 October 2026 |
| More than Dh19 million in fines, 9,433 numbers disconnected, 92,748 numbers reported, 3,301 violations since August 2024 | TDRA figures, as reported by The National on 6 August 2026 (TDRA’s own post not opened) | thenationalnews.com | 10 October 2026 |
| Worked totals AED 80,000, 140,000 and 260,000 | Zian AI, sum of the four Table 1 rows named, one fine per violation type assumed | This page | 10 October 2026 |
General information as read on 10 October 2026, not legal advice; for a specific campaign, ask a UAE-qualified lawyer and your licensing authority.