Dubai AI Calling Laws: Cabinet Resolution 56 & 57 (2026 Guide)

Automated AI voice calling and outbound telemarketing in Dubai and the United Arab Emirates are strictly regulated under Cabinet Resolution No. 56 of 2024 Concerning Telemarketing Regulations and Cabinet Resolution No. 57 of 2024 (Violations and Administrative Penalties). Enforced jointly by the Ministry of Economy and the Telecommunications and Digital Government Regulatory Authority (TDRA), all commercial calls must originate from locally registered trade-licensed numbers, verify against the national Do Not Call Registry (DNCR), operate strictly between 09:00 AM and 06:00 PM GST, and adhere to strict frequency caps under threat of administrative fines up to AED 150,000.

┌────────────────────────────────────────────────────────────────────────────────────────┐
│                        UAE TDRA TELEMARKETING MANDATES (2024-2026)                     │
├────────────────────────────────────────────────────────────────────────────────────────┤
│ 1. Mandatory Pre-Approval: Trade license must include registered telemarketing activity │
│ 2. Registered Local CLI: Calls must originate from local fixed/mobile numbers only    │
│ 3. DNCR Scrubbing: Real-time verification against the UAE Do Not Call Registry (DNCR)  │
│ 4. Restricted Hours: Dialing permitted strictly between 09:00 AM and 06:00 PM GST     │
│ 5. Frequency Caps: Max 1 call/day, max 2 calls/week if unanswered. Once rejected = stop │
│ 6. Recording & Disclosure: Immediate statement of identity, purpose, and recording notice│
│ 7. Penalty Exposure: Fines up to AED 150,000 + permanent telecom resource disconnection│
└────────────────────────────────────────────────────────────────────────────────────────┘

1. The Core Legal Statutes: Cabinet Resolution No. 56 and 57 of 2024

In mid-2024, the UAE federal government enacted comprehensive telemarketing regulations to eliminate unverified outbound cold calling, aggressive real estate lead generation, and offshore automated dialers.

Under Cabinet Resolution No. 56 of 2024:

• Technology-Neutral Application: The law explicitly covers human telemarketers, pre-recorded IVR systems, and interactive artificial intelligence voice agents. Using an AI voice model does not exempt an organization from telemarketing rules.
• Prior Commercial Authorization: Companies cannot initiate marketing or sales calls without obtaining prior official licensing and authorization from the competent licensing authority (such as the Dubai Department of Economy and Tourism (DET), or the relevant Free Zone authority, in coordination with the TDRA).
• Strict Prohibition on Personal SIM Dialing: Marketing calls from individual personal SIM cards or unregistered numbers are completely illegal. Penalties for individuals dialing commercial calls from personal lines reach AED 50,000 alongside line termination.

2. Permitted Calling Hours: The 09:00 AM to 06:00 PM GST Window

Under Cabinet Resolution No. 56, commercial outbound calling is legally restricted to a narrow daytime window:

• Permitted Hours: 09:00 AM to 06:00 PM Gulf Standard Time (GST), Monday through Saturday.
• Prohibited Hours: Any outbound telemarketing initiated before 09:00 AM or after 06:00 PM is an automatic violation.
• Public Holidays: Outbound commercial calls on official UAE national holidays are strictly prohibited.

3. The UAE Do Not Call Registry (DNCR) & Frequency Caps

The UAE operates a centralized federal Do Not Call Registry (DNCR) managed under the oversight of the TDRA and telecom operators (e& / Etisalat and du).

1. Mandatory Scrubbing: AI calling platforms must scrub prospect lists against the DNCR prior to dialing. Contacting any registered consumer without documented, verifiable prior consent is strictly prohibited.
2. Frequency Limitations on Unanswered Calls: If a consumer does not answer, the automated system cannot call them back more than once in a single day, and no more than two times in a single week.
3. The Immediate Rejection Suppression Rule: If a consumer explicitly declines an offer, states they are not interested, or asks not to be contacted, the AI agent must terminate the call immediately. The enterprise is legally barred from contacting that individual regarding that product or service again.

4. Caller ID (CLI) and In-Call Disclosure Mandates

The TDRA enforces strict identity requirements for every call terminating on UAE telecom networks:

• Registered Local Numbers Only: Outbound calls must originate from local UAE landlines (e.g., 04 for Dubai, 02 for Abu Dhabi) or approved corporate mobile numbers registered under the commercial trade license of the deploying entity. The use of international VoIP numbers, Skype-out pools, or spoofed caller IDs triggers immediate carrier-level blocking.
• Mandatory Initial Disclosure: Within the first 10 seconds of the call, the AI agent must clearly announce:
  1. The legal name of the enterprise.
  2. The commercial objective of the call.
  3. A formal disclosure that the call is being recorded.
• Mandatory Call Recording: Under Article 6 of Resolution 56, all commercial calls must be recorded and stored for audit compliance by the licensing authorities.

5. Administrative Penalties Under Cabinet Resolution No. 57 of 2024

Cabinet Resolution No. 57 establishes a graded schedule of administrative financial fines and operational sanctions for non-compliance:

In addition to monetary penalties, repeated violations result in the immediate revocation of commercial trade licenses and a minimum one-year ban on enterprise directors operating telemarketing infrastructure in the UAE.

6. Data Sovereignty: UAE Personal Data Protection Law (PDPL)

Deploying AI voice bots that process, transcribe, and analyze consumer phone calls intersects directly with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL):

• Explicit Purpose-Specific Consent: Organizations must possess a lawful basis or documented consent to collect and process consumer voice telemetry.
• Data Residency & Cross-Border Transfer: Voice recordings containing personally identifiable information (PII) must comply with national data localization frameworks. Utilizing offshore cloud AI APIs that store audio buffers without enterprise encryption or data sovereignty agreements violates UAE PDPL compliance.

Frequently Asked Questions

Can AI voice bots cold call real estate prospects in Dubai?

Only if the real estate brokerage holds an authorized telemarketing license from the Dubai Department of Economy and Tourism (DET), uses registered local UAE phone numbers, scrubs against the federal DNCR, calls strictly between 09:00 AM and 06:00 PM GST, and ceases communication immediately if the prospect declines.

Are inbound AI customer service bots subject to telemarketing hours?

No. Inbound virtual assistants that answer calls initiated by customers (such as airline booking inquiries, bank balance checks, or medical clinic appointments) are classified as customer service and are exempt from telemarketing hour restrictions and DNCR scrubbing.

What is the penalty for using a personal mobile SIM for AI sales calls in Dubai?

Under Resolution No. 57 of 2024, individuals using personal SIM cards for commercial telemarketing face fines starting at AED 10,000 up to AED 50,000, alongside the immediate and permanent disconnection of all telecommunication numbers registered under their Emirates ID.

Does the AI agent have to announce that the call is recorded in the UAE?

Yes. Under Resolution No. 56, companies are legally required to notify the recipient that the call is being recorded at the very beginning of the conversation.

Authoritative References & Legal Standards

• UAE Ministry of Economy: Cabinet Resolution No. 56 of 2024 on Telemarketing Regulations
• Telecommunications and Digital Government Regulatory Authority (TDRA): Telemarketing Regulations & DNCR Framework
• UAE Data Protection Authority: Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL)
• Auto Interview AI Research: Voice AI Latency Benchmarks & Sales Simulation Architectures