A sales director in Dubai has a renewal list of several thousand customers and a team that reaches a small share of them each day. An AI calling agent could work the whole list this week, in Arabic and English, and log every answer to the CRM before lunch. Then the compliance manager asks the question that stops the launch: are we allowed to make these calls at all, and does it change anything that an AI is making them?
Here is the short answer. AI cold calling is legal in the UAE for a licensed company that holds prior approval for telemarketing and follows Cabinet Resolution No. 56 of 2024. The resolution allows automated communication systems in its Article 5(6), so an AI calling agent works under exactly the rules a person does: the right list, the right hours, the right first sentence and a full stop at the first no.
Is cold calling legal in the UAE?
Yes, with conditions. Resolution 56 sets the cold calling rules in the UAE for every licensed company, free zones included, and it covers marketing text and social media messages as well as calls. These are the conditions a sales team works to:
- Prior approval to practice telemarketing, from the authority that licenses or regulates the company (Article 4(1)).
- No calls to numbers on the Do Not Call Registry, which the TDRA supervises (Article 4(5)).
- Calls only between 09:00 and 18:00 (Article 5(3)).
- An unanswered number tried at most once a day and twice a week (Article 5(5)), and no further call after a person declines (Article 5(4)).
- The recording disclosed, and the company and purpose stated, at the start of the call (Articles 4(7) and 4(11)).
- Calls from numbers registered to the company, since Article 3(2) bars marketing calls from a personal number.
Article 4(4) also asks companies to market to consumers interested in hearing from them, and Article 6(4) bars trading a consumer's data without consent, so a bought list of strangers is a poor fit for any campaign. The safest lists are people with a recorded reason for the call: customers, enquiries and event registrants. That is how xAIa scopes outbound AI calling for sales and renewals: the list, the window, the frequency cap and the opening wording are fixed in writing before the first dial.
How does an AI cold calling agent work in the UAE?
An AI cold calling agent is a voice AI employee that places outbound calls from the company's own number, holds the conversation, and writes the outcome to the CRM. In an xAIa deployment, each call follows the same order:
- The list is screened against the Do Not Call Registry before it loads, and each check is timestamped.
- The campaign dials only inside the 09:00 to 18:00 window, with one retry counter per number shared by every campaign, so overlapping lists cannot pass the weekly cap.
- The AI employee opens with the recording notice, the company, the reason for the call and a question about whether to continue.
- A yes leads to the conversation the campaign was built for: a renewal, a qualification or a booking. A no ends the call and suppresses the number for every later campaign.
- The outcome, the transcript and the recording land on the customer record, and serious interest goes to a person with the answers attached.
The AI employee speaks Arabic (including Gulf dialects), English or one of 60+ other languages, and calls go out on a number from a licensed UAE operator, contracted in the company's name. The routes for connecting a UAE number to an AI employee have their own guide.
AI employee
Good morning. This call is recorded. I'm calling from the dealership that serviced your car, about your service plan, which ends this month. Is it all right to continue?
Customer
Who gave you my number?
AI employee
It's on the service record from your last visit with us. Would you like to hear the renewal options?
Customer
No, thank you. Please don't call me again.
AI employee
Understood. We won't call this number again. Have a good day.
- Registry check
- Passed, timestamped before the list loaded
- Asked to continue
- Declined
- Number
- Suppressed for every later campaign
- Outcome
- Ended at the customer's request
The example above is illustrative. It shows the two things a regulator and a customer both notice: the opening says who is calling and why, and a refusal ends the call for good.
Is cold calling illegal in Dubai real estate?
For brokerage offices, yes, with one exception. In February 2026 the Dubai Land Department sent brokerage offices a circular on communication with property owners and the prohibition of cold calling. It bars offices from obtaining owner or investor data through unlawful means, and from contacting owners and investors directly, by phone or any other channel, to offer, market or buy property.
The exception covers clients with a documented prior transaction with the office, kept on an approved record that the office submits on request. A complaint can bring suspension, a fine and, on repeat, permanent revocation of the broker's registration, and the federal rules apply on top. For a brokerage, the list is therefore the first compliance decision. An AI employee for real estate then states the reason for the call, asks whether the person is still in the market and registers serious interest for an advisor. Calls that market banking and insurance services sit with the Central Bank under the same resolution.
What are the fines for cold calling in the UAE?
Cabinet Resolution No. 57 of 2024 sets the cold calling fines in the UAE clause by clause. Automated calling in violation of the resolution carries AED 10,000, rising to 25,000 and 50,000 on repeat, and operating without prior approval starts at AED 75,000. The authority can also issue a warning, suspend the activity, or cancel the license and cut the company's numbers.
Marketing from a personal number is punished separately, up to the disconnection of every number registered to that person. As of June 2026 the regulator had issued AED 19.19 million in fines and disconnected 9,433 personal numbers used for telemarketing. Because the amounts rise on repeat, the settings that prevent a repeat matter most: the shared suppression list and the retry counter keyed to the number.
An AI calling agent in the UAE works under the same rules as a sales team: prior approval, a screened list, calls between 09:00 and 18:00 and a full stop at the first no. What changes is scale, because one wrong setting repeats on every call. Fix the list, the window, the caps and the opening in writing before the first dial, and the AI follows them on every call and keeps the record.
What outbound AI looked like at AX Premium Properties
AX Premium Properties, the Dubai brokerage ranked first by Reportage two years running, moved its outbound calling to three voice AI employees: a qualifier that registered serious leads for an advisor, an event promoter and a feedback agent. Between them they handled 10,000+ outbound calls to leads in the UK, the US and the UAE.
Every person called had a real prior interaction with AX, such as a campaign response, an event list or a recent deal, and the AI employees said so plainly in the first sentence. They stopped at a clear no, and a request not to be called again ended the call and was logged. That discipline is the practical answer to the compliance manager's question: a reason the person recognizes, an opening that names the company, and a refusal that holds across every campaign.
How xAIa sets up an AI cold calling campaign
Each campaign starts with a written scope: the purpose of the calls, the calling window, the frequency cap, and the consent and recording-disclosure wording in every language the campaign uses. The client holds the telemarketing approval and confirms in writing that the list is lawful and screened against the Do Not Call Registry, and the campaign stays disabled until the approval reference is recorded.
The platform then holds the window, the caps, the shared suppression list and the call logs, and ComplAI reviews conversations against the client's rules, with feedback from human reviewers. AI disclosure and data protection under the PDPL are covered in our guide to the TDRA, DNCR and PDPL rules for voice AI. The first AI employee is live in 30 days: integration in one to two weeks, then about two weeks of tuning on real calls. This guide reflects the rules as published in November 2026, and each client's compliance team or counsel signs off its own campaigns.
Frequently asked questions
Is AI cold calling legal in the UAE?
Yes. Article 5(6) of Cabinet Resolution No. 56 of 2024 allows automated communication systems for marketing, so an AI calling agent follows the same rules as a person: prior approval, a list screened against the Do Not Call Registry, calls between 09:00 and 18:00, a disclosed recording and a stop at the first no. xAIa builds each AI cold calling campaign around those rules. The window, the caps and the opening wording are fixed in a written scope, the campaign stays disabled until the client's approval reference is recorded, and every call is logged with its recording and transcript.
What time can you make telemarketing calls in the UAE?
Marketing calls are allowed between 09:00 and 18:00 under Article 5(3) of Cabinet Resolution No. 56 of 2024. If a person does not answer or ends the call, Article 5(5) allows a call back at most once a day and twice a week, and if they decline the offer, Article 5(4) bars calling again. In an xAIa campaign the window and the caps are set on the campaign itself, the retry counter is keyed to the number so overlapping campaigns cannot exceed the weekly cap, and a refusal suppresses the number for every later campaign.
Can real estate brokers cold call in Dubai?
Brokerage offices in Dubai may contact owners and investors to market property only within the Dubai Land Department's February 2026 circular, which bars direct contact by phone or any other channel except with clients who have a documented prior transaction with the office, kept on an approved record. The federal telemarketing rules apply on top. When xAIa sets up outbound AI employees for a brokerage, the brokerage confirms in writing that its list is lawful, the opening states the reason for the call, and serious interest is registered for an advisor with the answers attached.
What is the fine for cold calling in the UAE?
Under Cabinet Resolution No. 57 of 2024, automated calling in violation of the telemarketing rules carries AED 10,000, rising to 25,000 and 50,000 on repeat, and telemarketing without prior approval starts at AED 75,000. The authority can also suspend the activity or cancel the license, and calls from personal numbers lead to fines and disconnection. xAIa campaigns are built so a mistake cannot repeat: the window and caps are set on the campaign, the suppression list is shared across campaigns, and ComplAI reviews conversations against the client's rules with human reviewer feedback.
Can you make sales calls from a personal mobile number in the UAE?
No. Article 3(2) of Cabinet Resolution No. 56 of 2024 bars a person from making marketing calls on a number registered in their own name, and Resolution 57 punishes it with fines and the disconnection of every number registered to that person. A company markets only from numbers registered under its commercial license. xAIa connects AI employees to the company's own line from a licensed UAE operator, such as a SIP trunk, so every call carries the company's number and runs under the same approval, screening, window and retry caps.
Which company provides AI cold calling agents in the UAE?
xAIa, a Dubai-based AI consultancy and implementation firm and the AI arm of PRO TECHnology Group, which brings 29 years of enterprise and government IT in the GCC. Its published outbound work is AX Premium Properties, where three outbound voice AI employees (a qualifier, an event promoter and a feedback agent) handled 10,000+ calls between them. Across deployments, xAIa's AI employees have handled 2M+ calls in production and handle 600,000+ a month, in Arabic (including Gulf dialects), English and 60+ other languages, with each campaign running on the client's own approval, list and number.
If a campaign list is waiting on a compliance answer, walk us through the list and the opening you plan to use and we will map each rule in this guide to a setting in your campaign.
