UAE Implements Telemarketing Rules for Financial Institutions

The UAE has introduced a comprehensive set of rules governing telemarketing by licensed financial institutions, setting new standards for the use of technologies like robocalling and artificial intelligence (AI). These regulations, issued by the UAE Central Bank in February and published in the country's Official Gazette on March 31, aim to enhance consumer protection and improve accountability in telemarketing practices.

Stricter Controls on Automated Technologies

The new regulations specifically address the use of automated dialling technologies, including robocalls and AI-powered tools. Financial institutions utilizing such systems are required to ensure that customers are connected to a call within two seconds of answering. Additionally, unanswered calls must be disconnected within 15 seconds or four rings, and the equipment used must be capable of generating relevant statistics for monitoring and compliance.

For AI-driven telemarketing, institutions must comply with existing laws and regulations governing AI in the UAE. Customers are also given the option to choose their preferred method of interaction - whether through human agents, robocalls, or AI-based agents.

A cornerstone of the new framework is the emphasis on obtaining explicit and detailed customer consent. Financial institutions are now required to secure prior express consent from customers before initiating telemarketing. This consent must outline the customer’s preferred language, communication channels, and the specific products or services they wish to receive marketing about.

The rules mandate that terms and conditions related to consent be "clear, direct, unambiguous, readily understandable, and provided in the customer’s preferred language." Customers also have the right to withdraw their consent at any time and can add their numbers to a ‘do not call’ registry. Telemarketers are obliged to cross-reference this registry to ensure compliance.

Commenting on the significance of these changes, Dubai-based technology law expert Martin Hayward of Pinsent Masons said: "Telemarketing consent requirements have long existed, under the Central Bank consumer protection regulations and elsewhere, but this regulation fundamentally raises the bar. Financial institutions now need granular consent, down to language, channel, product type and whether AI agents are used, and need to be able to report on meeting these consent requirements. That’s a significant step forward."

Operational Limits and Oversight

These new rules also impose limits on the frequency and timing of telemarketing calls. Financial institutions can only call customers between 9 a.m. and 6 p.m., with a maximum of one call per day and two calls per week per customer.

Marie Chowdhry, an expert in financial regulation and fintech at Pinsent Masons in Dubai, highlighted the shift in regulatory focus: "Under the old regime, telemarketing was largely regulated through general consumer protection and data rules. What’s changed now is explicit regulatory recognition of AI-driven marketing; with clear constraints around speed of connection, abandoned calls and monitoring."

She added, "Automation may be efficient, but the Central Bank is making it clear that the use of technology cannot come at the expense of customer experience or accountability."

Compliance Deadlines and Additional Requirements

While the rules officially took effect on March 31, financial institutions have until June 29, 2026, to implement the necessary measures to comply with the regulation. Institutions are required to maintain a comprehensive log of telemarketing activities, storing the data for at least five years. Annual audits must be conducted to ensure compliance, and all data use must adhere to applicable data protection laws.

The regulations also require telemarketers to complete a minimum of 15 hours of training on topics such as ethical principles, data privacy, and customer protection. Furthermore, board-level approval must be obtained for all telemarketing activities.

Notably, the framework clarifies that outsourcing telemarketing activities does not absolve institutions of their regulatory obligations. Both financial institutions and third-party telemarketers must comply with the new requirements.

A New Era for Telemarketing in the UAE

By introducing these regulations, the UAE Central Bank sets a higher standard for telemarketing practices within the financial sector. The new framework aims to balance technological efficiency with the need for greater consumer protection and respect for customer preferences. As Hayward noted, this marks "a significant step forward" in ensuring accountability and transparency in the use of emerging technologies for marketing purposes.

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