Is it legal for a machine to cold-call a UAE phone number? The UAE telemarketing rules answer that question directly, and they do not mention artificial intelligence at all: they regulate the call and the data behind it, whoever or whatever is speaking. xAIa, the Dubai voice-AI company, sets out on its own compliance blog how it says its voice AI agents operate inside the UAE's existing telecoms, consumer-protection and data-protection law: Cabinet Resolution No. 56 of 2024, the Telecommunications and Digital Government Regulatory Authority's Do Not Call Registry, and the Personal Data Protection Law.
xAIa, which describes itself on its own site as “a PRO TECHnology Group company,” states its position plainly: “yes, voice AI is legal in the UAE. The rules that govern it are the rules that already govern every business phone call in the country…”
What the UAE telemarketing rules actually require
xAIa cites Article 5(6) of Cabinet Resolution No. 56 of 2024 on the Telemarketing Regulations, which it quotes as stating that “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.” That permission arrives bundled with conditions: a calling window of 9am to 6pm, a check against the TDRA's Do Not Call Registry before a number is dialled, a recording notice given at the start of the call, and a cap on unanswered retries. International law firm Morgan Lewis, reviewing the regulations shortly after they were issued, confirmed the same 9am-to-6pm calling window and listed warnings, administrative fines, suspension of activities and licence revocation among the possible penalties for violations.
The Do Not Call Registry has teeth
The TDRA runs the Do Not Call Registry, which lets a UAE resident opt out of telemarketing calls and messages. Enforcement is active: TDRA figures reported by The National show Dh19 million in fines, 9,433 disconnected phone numbers and 3,301 recorded violations accumulated since the rules took effect in August 2024, according to the newspaper's report published 6 August 2026. xAIa cites closely matching figures on its own compliance blog, describing them as TDRA data “as of June 2026.”
Where the Personal Data Protection Law comes in
A call recording is personal data under the UAE's Personal Data Protection Law, Federal Decree-Law No. 45 of 2021, which the UAE's own government portal describes as a law that “prohibits the processing of personal data without the consent of its owner, except for some cases” and that gives the data's owner the right to request corrections of inaccurate personal data and to restrict or stop its processing. xAIa says it applies that law to a voice AI deployment by masking personal identifiers, such as ID numbers, before a transcript is stored, and by processing calls in-region rather than sending the audio abroad for transcription.
The one place a UAE regulator has drawn a hard line
Not every consumer interaction is open to automation. The TDRA's own Consumer Protection Regulations, version 2.0, issued 25 July 2023, require licensed telecom operators to maintain enough trained staff to handle consumer complaints, and state that the obligation shall “preclude the use of non-human agents by Licensees in conversations with Consumers regarding Consumer Complaints.” xAIa, citing the same clause on its blog, notes that it binds telecom licensees specifically, not every UAE business, but calls it “the clearest signal of where a regulator draws the line.”
The honest limits
The deployment details and the compliance architecture xAIa describes, such as how it masks identifiers or routes a call in-region, are the company's own account of its own system, not an independent compliance audit. The UAE telemarketing rules themselves are public law, checked above against the TDRA's own regulation text and the UAE government's own description of the PDPL, but whether any given vendor's software actually satisfies them is a question a buyer has to verify on its own recorded calls, not take from a vendor's compliance blog.
Frequently asked questions
Are outbound AI calls legal in the UAE?
Yes. Cabinet Resolution No. 56 of 2024 permits automated communication systems for marketing calls, provided the call still follows the rest of the UAE telemarketing rules: Do Not Call Registry screening, the 9am-to-6pm calling window and a recording notice at the start of the call, among other conditions.
What happens if a company breaks the UAE's telemarketing or Do Not Call rules?
Penalties escalate with repeat violations. TDRA enforcement had produced Dh19 million in fines and 9,433 disconnected phone numbers over 3,301 violations, as reported by The National in August 2026, and Morgan Lewis's review of the regulations lists warnings, administrative fines, suspension of activities and licence revocation among the possible consequences.
Does the UAE's data protection law apply to an AI call recording?
Yes. A call recording, its transcript and any record built from it are personal data under the UAE's Personal Data Protection Law, Federal Decree-Law No. 45 of 2021, which took effect on 2 January 2022 and requires consent for processing except in listed cases.
Who is behind xAIa?
xAIa says on its own site that it is the AI consultancy and implementation arm of PRO TECHnology Group, and its website footer describes it as “a PRO TECHnology Group company.” PRO TECHnology describes itself as a Dubai-founded technology group operating across enterprise IT, distribution, digital printing, indoor air quality and enterprise AI since 1998.
Product details and capabilities in this article are as published by xAIa at the time of writing.
