Quick answer
Businesses making marketing calls in the UAE must follow Cabinet Resolution No. 56 of 2024, whether a person or an AI makes the call. Key points reported by law firms include calling only between 9am and 6pm, using a company-registered local number, respecting the Do Not Call Registry, and recording calls after telling the person.
Which rules apply to telemarketing in the UAE?
Cabinet Resolution No. 56 of 2024 regulates telemarketing, and a companion resolution, No. 57 of 2024, sets out penalties. According to a summary by law firm Clyde & Co, the rules took effect on 27 August 2024 and apply to all licensed companies in the UAE, including those in free zones. Published extracts of the resolution indicate that automated communication systems may be used for marketing, subject to its rules, so an AI agent needs to meet the same standards as a person.
What should you check before an outbound campaign?
- Approval: confirm your company has any prior approval required for telemarketing.
- Calling hours: marketing calls are restricted to between 9am and 6pm.
- Frequency: if a call goes unanswered, summaries report a limit of once a day and twice a week. Check the exact wording.
- Consent: one law firm summary says to obtain the consumer's consent at the start of each call, before any marketing.
- Rejection: if someone rejects the product or service, do not call them again.
- Phone numbers: use local numbers registered under your company's commercial licence, not personal numbers.
- Do Not Call Registry: consumers can register to avoid marketing calls, so check every list before calling.
- Recording: record marketing calls, and tell the person at the start of the call that it is being recorded.
- Records: keep detailed call records, as companies may need to report them to the authorities, including where numbers came from.
- Conduct: no undue pressure, misleading promises or sharing of a consumer's data without consent.
These points come from published summaries by law firms Clyde & Co and Paoletti. They word some limits differently, so treat the official resolution as the final authority.
Why does recording need special care?
Beyond telemarketing, recording a private conversation without the other person's consent can be a criminal matter in the UAE, even if you are part of the conversation. A clear notice at the start of every call is therefore essential, whether a person or an AI is speaking.
What about personal data?
A contact list is personal data. The UAE's Personal Data Protection Law, Federal Decree-Law No. 45 of 2021, is the main law to review for onshore businesses, and its detailed regulations have been slow to arrive, so check the latest status. The DIFC and ADGM free zones have their own data protection laws, and customers in other countries may bring other laws into play. Know where each contact came from, what they agreed to, how long you keep their details and who can see them. Transcripts and recordings need the same care.
How do you build these rules into an AI agent?
The advantage of AI is that rules can be built into the system and applied on every call:
- Block calls outside permitted hours automatically.
- Check lists against the registry before a campaign starts.
- Count attempts per contact and stop at the limit.
- Mark a contact as do-not-call the moment they ask or reject the offer.
- Open each call with clear AI disclosure and the recording notice.
BrandSparkX builds AI voice agents with clear AI disclosure, consent-aware call recording and scrubbed lists for outbound calling in the UAE. Responsibility for lawful campaigns is still shared, so agree who does what before going live.
AI Voice & CallingAI voice agents that answer calls 24/7, make outbound calls within permitted hours and log every call in your CRM.This article is general information. It is not legal, tax or financial advice, and rules can change. Please check the current requirements for your business.
