Yes — with strict conditions. Here is what Cabinet Resolutions 56 and 57 of 2024, the TDRA's Do-Not-Call Registry, and the UAE's recording laws actually require of anyone making sales calls — human or AI.
AI calling is legal in the UAE, but it is regulated exactly like human telemarketing. The rules are technology-neutral: prior approval from your licensing authority, calls only between 9:00 am and 6:00 pm, screening against the TDRA's Do-Not-Call Registry, mandatory call recording with notice, and dialing from a number registered to your company. Fines run from AED 10,000 to AED 150,000 per violation.
Written by Ayman Sheik Ali, founder of Lumaa, in Dubai · Published , last updated · Sources · For real estate brokers
UAE telemarketing is governed by Cabinet Resolution No. 56 of 2024 (the Telemarketing Regulations) and its companion Cabinet Resolution No. 57 of 2024 (the penalties schedule). Resolution 56 was issued on 10 June 2024, published in the Official Gazette on 28 June 2024, and came into force on 27 August 2024.
The scope is broad: the regulations apply to all companies licensed in the UAE — including free-zone companies — and to individuals. "Telemarketing" covers any phone call made to consumers to market a product or service.
Crucially for AI: neither resolution carves out or separately restricts automated or AI-generated calls. The definition of a marketing call is technology-neutral, so law firms treat AI voice-agent calls as falling under the same regime as human calls — same approvals, same hours, same registry, same fines. The UAE has no standalone federal AI statute; AI calling is governed by these telemarketing rules together with the Personal Data Protection Law, the Cybercrimes Law, and the non-binding UAE AI Charter (2024).
Cabinet Resolution 57 of 2024 sets escalating administrative fines. The headline rows:
| Violation | 1st | 2nd | 3rd |
|---|---|---|---|
| Telemarketing without prior approval | AED 75,000 | AED 100,000 | AED 150,000 |
| Calling a number on the DNCR | AED 50,000 | AED 75,000 | AED 150,000 |
| Trading or disclosing consumer data without authorisation | AED 50,000 | AED 75,000 | AED 150,000 |
| Calling from numbers not registered to the company | AED 25,000 | AED 50,000 | AED 75,000 |
| Not disclosing company name or call purpose | AED 10,000 | AED 20,000 | AED 30,000 |
| Calling outside the 9am–6pm window | AED 10,000 | rising to AED 50,000 on repetition | |
| Failing to train staff on conduct and DNCR use | AED 10,000 | AED 25,000 | AED 50,000 |
| Marketing calls from a personal number (individuals) | AED 5,000 + line suspension | AED 20,000 + 3-month suspension | higher fines + longer suspension |
Beyond fines, regulators can issue written warnings, suspend telemarketing activity for 7 to 90 days, disconnect phone lines, and ultimately cancel the commercial licence. Penalty decisions can be appealed within 15 days; the authority must decide within 30 days. Consumers report violating calls to the TDRA; one published channel is texting REPORT plus the caller's number to 1012. Both that code and 2211 are live, and 2211 is TDRA's current national route.
One row sits outside that table and matters more than any row inside it for an AI calling operation. The Ministry of Economy publishes the penalty schedule in English, and Table 1, Row 16 covers automatic or automated calling at AED 10,000 to AED 50,000. If you run an outbound AI voice agent, that is the row written for you.
Enforcement totals need handling with care. The figures in circulation are Dh19 million in fines and 9,433 line disconnections. Three caveats belong with them. We could not trace either number to a published TDRA statement. Gulf Today reported a conflicting figure of 97,248 for what appears to be the same programme. And that enforcement stream runs against individuals under Table 2 of the penalty schedule rather than against licensed corporate calling campaigns, so it is weak evidence of how a company-run campaign gets treated. We repeat them here with those caveats attached, and we would not put them in a board pack without a primary source.
A new penalty scheme for business voice lines took effect on 1 September 2026, and the public record for it is thin enough that the wording here has to be careful. e& sets the scheme out on its own DNCR page. We went looking for the regulation behind that page and did not find one: nothing on tdra.gov.ae, nothing on u.ae, and nothing in the legislation register at uaelegislation.gov.ae. du's DNCR page says nothing about it. Summaries circulating online cite a "TDRA Voice Spam Policy" as though it were a named regulation with a published text; no document under that name is findable on any of those three official sites. What follows is what the carrier says applies to the lines it provides. It is not a regulation we can point you to.
e& describes a points scheme attached to the calling line, with two thresholds. Five points puts the line on the DNOR register, and 25 points reaches the licence. Those two figures are the only numbers on this scheme that appear anywhere we could check. Per-violation point values are quoted confidently in several blog posts and we could not source one of them, so this page publishes no points table. If a campaign depends on knowing the schedule, ask your operator account manager for it in writing.
A second dated claim needs correcting, and the correction runs the opposite way to most of the reporting. You will read that from 2026 a DNCR registration overrides any consent a consumer gave you earlier, and that a number must be verified against the registry immediately before it is dialled. Both duties are real. Neither is new. du documents both and dates them to August 2023. They are widely reported as a 2026 change, and that reporting is wrong. An operation that was waiting for 2026 to adopt them has been three years late.
Inside the telemarketing regime the recording question inverts: recording is mandatory, and so is telling the consumer at the start of the call. The two duties travel together.
Real estate is the one sector in the UAE carrying a second rulebook on top of Resolution 56, and the second one is stricter than the federal regime.
The Dubai Land Department issued circular 02-2026 on 26 February 2026, reference DLD/OUT/2026/0001641. Its translated title is "Regulations Governing Communication with Property Owners and the Prohibition of Cold Callings". It prohibits brokerage offices from obtaining owner data by unlawful means and from contacting owners for marketing purposes. The penalties named are AED 50,000, three months' suspension, and permanent striking off for repeat offences, and they apply to the brokerage office and to the individual broker. There is a narrow exception for a documented existing client relationship.
Two things about that circular you should hear from us rather than discover later. It is published as a scanned Arabic PDF, and its clause numbering could not be recovered reliably, so this page publishes no numbered penalty schedule for it. We also found no English-language media reporting on it whatsoever. Read the Arabic original with your compliance officer before you rely on this summary or anyone else's.
Enforcement in this sector is not hypothetical. RERA fined a brokerage AED 50,000 and suspended nine brokers for cold calling to promote real estate services. The federal exposure stacks on top of the DLD circular: calling a DNCR-registered number starts at AED 50,000 under Resolution 57, and the Ministry of Economy's Table 1 Row 16 covers automatic calling at AED 10,000 to AED 50,000. A brokerage running an unscreened AI dialler is exposed under two regimes at once, and both of them reach the individual agent as well as the office.
Can you call a Bayut or Property Finder enquiry? This is genuinely unsettled. Every competitor page we read asserts a clean yes, and the text does not support one. It turns on two provisions of Resolution 56. The first is the definition of a marketing call, which covers any call placed to market a product or service; whether returning a portal enquiry about a specific listing is marketing, or is servicing a request the consumer initiated, has not been tested in anything we can cite. The second is the DNCR rule, under which a registration overrides consent given earlier; read plainly, that bars the call even though the enquirer typed their own number into the portal. Our working position is that a fast callback about the exact listing someone enquired on is the strongest ground available, and that a DNCR-registered number is not worth dialling whatever the enquiry says. That is a position, not an answer, and this paragraph changes the day a published decision gives us one.
One point about our own product while we are here. Lumaa has no native integration with Bayut or Property Finder. Lead lists are imported as CSV or XLSX files. A vendor telling a Dubai brokerage that their dialler is wired straight into the portals should be asked to show it working.
What an AI voice agent actually does for a brokerage day to day sits on the Lumaa real estate page.
Resolution 56 regulates marketing calls. It does not reach a call to a customer about something they have already bought, booked, or asked you about. Nearly every compliance question we are asked comes down to one thing: which side of that line is this call on? The line is drawn by the purpose of the call rather than by the label on the campaign, and a service call that ends in an offer has become a marketing call. Here is where the line sits in each sector we build for. Send the borderline cases to your licensing authority before they reach a dialler.
Service reminders, recall notices, parts availability, and a call about a car already in your workshop are service calls to your own customer. A new-model launch call to a purchased or scraped list is marketing, and it needs the prior approval, the DNCR screen, and the 9am–6pm window. The common failure is the middle case: a service-due call that turns into a trade-in pitch has become a marketing call, and it is judged on what was said, not on what the campaign was named. Lumaa for automotive dealerships.
Appointment confirmations, reschedules, and post-treatment follow-ups to existing patients are service calls. A promotion sent to a lapsed-patient list is marketing. The Personal Data Protection Law does extra work in this sector, because health information is sensitive personal data: keep an automated call to scheduling, and do not have it name a treatment on a line that a family member may answer. Lumaa for clinics.
Booking confirmations, pre-arrival calls, and post-stay feedback follow the guest relationship and read as service. A past-guest list called about a seasonal offer is marketing. Worth flagging for hotels: the 9am–6pm window is fixed by the regulation and takes no account of your front desk running around the clock or of the guest being on another timezone. Lumaa for hotels and hospitality.
A renewal call on a live policy sits on the service side. Cross-selling a different product to the same policyholder is marketing. Insurance also changes who grants the prior approval in obligation one: the Central Bank supervises the sector, so the competent authority is your sector regulator rather than the Ministry of Economy, and approval obtained from the wrong body is not approval. Lumaa for insurance.
Returning an enquiry someone submitted is service. Approaching a person you have identified as having a claim is a marketing call under Resolution 56 and separately a conduct question for the authority that licenses the practice. The safe use of an automated voice agent in a law firm is intake and scheduling on enquiries that came to you. Lumaa for law firms.
Calling a candidate about the role they applied to is service. Calling a passive candidate pulled from a scraped database, or calling employers to sell the agency, is marketing. Recruitment is also where the database-disclosure duty bites hardest, because you can be asked to state where a number came from, and "a list we bought" is an answer that leads somewhere expensive. Lumaa for recruitment agencies.
Inbound is the cleanest position on this page. The consumer placed the call, so on a plain reading of Resolution 56 it is not a marketing call at all, and the calling-hours rule does not reach it. The recording notice still applies under the general laws, so an inbound agent should announce recording at the start. Outbound callbacks are judged by their purpose like everything else. Lumaa as an AI receptionist.
Callbacks on an open ticket, delivery updates, and outage notifications are service calls. A satisfaction survey to your own customers is generally service too. Attaching an offer to the end of the survey converts the whole call into marketing, which is the single most common way a support operation walks into the regime without noticing. Lumaa for customer support.
Lumaa is an AI calling platform built in Dubai for UAE businesses, so the regulation's mechanics are design inputs, not afterthoughts:
Compliance questions we haven't covered here? Ask us on a demo call — or compare how UAE platforms approach this on our Dubai AI calling platforms comparison.
Sourcing note: where a claim could not be traced to a primary document, this page says so instead of filling the gap. That applies to the 1 September 2026 carrier scheme, the enforcement totals, and the clause numbering of DLD circular 02-2026. This guide is general information for sales and operations teams, not legal advice. Regulations change; verify current requirements with your legal counsel and your licensing authority. Figures reflect published sources as of .
Hear Maya place a real, in-window, fully recorded call on a Dubai lead — then decide.