TL;DR
- Sales staff must not use personal mobile numbers for telemarketing calls; reimbursing the bill does not change the number’s registered owner.
- A customer leaving a phone number does not prove an interest in receiving marketing calls and does not replace Do Not Call Registry (DNCR) screening.
- Before releasing a calling list, complete the activity classification and approval, company-number verification, DNCR screening, 9:00—18:00 calling window, frequency controls, opening script, recording notice, and evidence controls.
- If any critical condition is missing, pause outbound calls rather than allowing sales staff to call first and complete the formalities later.
A salesperson exports a prospect list to a personal phone and plans to make calls after work. The company has not checked where the numbers came from or whether they appear on the DNCR. It also has no approved opening script or central call records. What looks like a matter of convenience has removed the company’s control over number ownership, list eligibility, calling hours, refusal handling, and call evidence.
UAE telemarketing rules place responsibility on the company conducting the activity, not only on the individual salesperson. The practical task is therefore not to remind employees to “stay compliant.” It is to build controls that prevent an unapproved list from being dialled and stop a call process from continuing when critical records are missing.
Why Can’t Calls from Personal Mobile Numbers Be Treated as Individual Sales Activity?
When the purpose of a call is to market, advertise, or promote products or services to individual consumers, the company should first determine whether telemarketing requirements apply. The rules cover fixed and mobile calls, while the relevant definition also refers to marketing text messages and marketing messages sent through social media applications. Switching from a phone call to WhatsApp does not automatically take the activity outside the regulatory scope, subject to the latest official publication.
The UAE published UAE Cabinet Resolution No. 56 of 2024 in June 2024. It took effect on 2024-08-27 and applies to licensed companies in the UAE, including free zone companies, subject to the latest official publication. (Source: UAE Legislation, Cabinet Resolution No. 56 of 2024 Concerning Telemarketing Regulations, June 2024)
The responsible authority varies by industry. The Central Bank of the UAE oversees the relevant telemarketing regulation for banks, financial institutions, insurance businesses, and related professions; securities and commodities trading services involve the Securities and Commodities Authority. Other businesses must identify the competent authority based on their emirate, commercial licence, and specific activity, subject to the latest official publication.
⚠️ A response to a customer’s request for a quotation, a service notice to an existing customer, and an unsolicited call promoting a new product do not have the same purpose. Where the boundary is unclear, document the applicability assessment before releasing the list rather than allowing the salesperson to decide.
Which 7 Gates Must Be Passed Before Outbound Calls Begin?
Our recommendation is to make all seven gates prerequisites for creating a dialling task. If any gate is incomplete, the list should not be released.
1. Evidence That the Consumer Expressed an Interest in Marketing Contact
Possessing a phone number proves only that the company obtained contact details. It does not by itself prove that the consumer wants marketing calls. Each prospective record should identify the acquisition channel, the product or service in which the consumer expressed an interest, the permitted scope of contact, the time of that expression, and the location of the original form or communication record.
Trade-show scans, exchanged business cards, after-sales registrations, and website enquiries should not be placed indiscriminately into one calling list. If a record contains only a name and phone number, with no explainable source, purpose, or date, it should not enter the telemarketing pool.
2. Confirmation of the Competent Authority and Applicable Prior Approval
The company should identify the competent authority based on its commercial licence, business activity, emirate, and industry, and obtain any applicable prior approval. Approval records should cover the legal entity, activity, channel, number, or other applicable scope, as well as the validity period and review date. If the entity, product, or outbound model changes, recheck whether the existing approval still applies, subject to the latest official publication. (Source: UAE Legislation, Cabinet Resolution No. 56 of 2024 Concerning Telemarketing Regulations, June 2024)
3. Exclusive Use of UAE Local Numbers Registered to the Company
Telemarketing calls should use local numbers issued by UAE-licensed telecommunications providers and registered under the company’s commercial licence. A number obtained by an employee remains registered to that employee even if the company reimburses the bill; reimbursement does not turn it into a company number, subject to the latest official publication.
Each number should be linked to the commercial licence, telecommunications-provider evidence, activation date, assigned team, and deactivation date. Rotating among multiple personal numbers does not solve the ownership problem. It also undermines central frequency controls and complaint tracing.
4. DNCR Screening Even After Interest Evidence Passes Review
Consumer interest and DNCR status are separate checks. A previous enquiry does not allow the company to skip DNCR screening, and the absence of a number from the DNCR does not prove that the consumer wants marketing calls, subject to the latest official publication.
Screen every batch before it is released, and retain the batch identifier, screening time, result, and blocked-record log. A historical screening result should not be treated as permanently valid, and sales staff should not rely on memory to decide whether a number may be called.
5. System-Enforced Calling Hours and Contact Frequency
Telemarketing calls must be restricted to UAE local time 9:00—18:00. Put this restriction into the dialling system rather than leaving it only in an employee handbook or team message, subject to the latest official publication. (Source: UAE Legislation, Cabinet Resolution No. 56 of 2024 Concerning Telemarketing Regulations, June 2024)
After a consumer first expressly rejects the relevant product or service, the company should not call again. Where a call is unanswered or the consumer ends it, enforce a limit of no more than one call per day and two calls per week, subject to the latest official publication. (Source: UAE Legislation, Cabinet Resolution No. 56 of 2024 Concerning Telemarketing Regulations, June 2024)
Frequency controls should operate at the consumer-number level, not separately for each salesperson or outbound number. Otherwise, different salespeople can call from different numbers without triggering the system limit even though the consumer receives repeated calls.
6. An Opening That States Identity and Purpose and Asks Whether to Continue
An approved script should do at least three things: identify the company, explain the marketing purpose of the call, and ask whether the consumer wishes to continue before the sales presentation begins. It should also prohibit misleading statements and unreasonable pressure, subject to the latest official publication.
Sales staff may speak naturally without changing the meaning, but they should not omit the identity, purpose, or request to continue. Release scripts centrally and retain their revision history so that individual team members do not use unapproved versions.
7. Operational Recording Notices, Call Records, and Evidence Exports
Installing recording software is not the same as implementing a compliance control. The company should notify the consumer of the recording arrangement at the start of the call and retain telemarketing call records as required by the competent authority. Confirm the specific retention period, reporting format, and retrieval requirements with the applicable authority before launch, subject to the latest official publication.
At a minimum, the system should connect the outbound number, consumer number, call time, list source, DNCR screening batch, script version, call outcome, refusal record, and recording. If a complaint arises, the company should be able to reconstruct who communicated what, when, from which number, and on the basis of which list entry. Logs that cannot be linked or exported will rarely form a complete evidence chain.
How Can the 7 Gates Become an Operational Release Checklist?
Training tells sales staff what they should do. A release checklist determines which tasks may enter the system. Each requirement should have a responsible owner, a system control, retained evidence, and a defined no-release condition.
| Release requirement | Primary owner | System control | Required evidence | No-release condition |
|---|---|---|---|---|
| Consumer marketing interest | Business, compliance | Reject records with missing critical fields | Channel, scope, time, original record | Phone number only; no interest evidence |
| Activity classification and approval | Management, compliance | Approval-expiry alert | Classification note, approval document, applicable scope | Competent authority unclear or approval missing |
| Company-registered number | IT, telecom administrator | Outbound-number allowlist | Commercial licence, provider and ownership evidence | Personal number or unknown number source |
| DNCR screening | Compliance, IT | Pre-dial block | Batch, time, result, exception record | No screening or untraceable result |
| Calling hours and frequency | IT, sales manager | Hard time and frequency limits | Configuration, test, and change records | Controls can be bypassed manually |
| Script and permission to continue | Compliance, sales manager | Release approved versions only | Script version, training, and sample-check records | Identity, purpose, or confirmation missing |
| Recording and call records | IT, compliance | Recording notice and linked logs | Recording, outcome, complaint, and export records | Notice, retention, or retrieval cannot be completed |
The release outcome can fall into three categories. Launch may proceed when all seven controls have supporting evidence and have passed system testing. A limited pilot should be considered only where the competent authority permits it, the approval scope is clear, and the list remains controlled. The activity must not launch if consumer-interest evidence, an applicable approval, a company-registered number, DNCR blocking, or recording and recordkeeping capability is missing.
💡 The checklist replaces dependence on individual judgement with system authorisation. Sales staff execute only released tasks; they do not build private lists, switch to personal numbers, or interpret the regulatory boundary themselves.
What Remediation Sequence Can the Company Follow This Week?
- Pause new marketing calls from personal numbers. Inventory the current numbers, list sources, scripts, and recording methods.
- Clean the prospective-contact list. Add the acquisition channel, scope of marketing interest, time of expression, and original evidence. Exclude records that contain only a phone number.
- Confirm the competent authority and approval route. Use the commercial licence, industry, and emirate to verify approvals, retention periods, reporting formats, and additional requirements.
- Configure one outbound system. Connect company-registered local numbers, DNCR screening, the 9:00—18:00 window, refusal and unanswered-call frequency controls, and the recording notice.
- Run a controlled test. Verify that blocks work, records link correctly, and evidence can be exported. Business, compliance, and IT should then sign the release checklist together.
- Establish complaint handling and periodic sample checks. Continue checking lists, scripts, recordings, call frequency, and remediation of exceptions.
Clean up the interest evidence and number ownership before discussing higher call volumes. If the order is reversed, every additional call increases the company’s evidence gap.
Frequently Asked Questions
Q: Can a Customer Who Previously Left a Phone Number Bypass DNCR or Frequency Limits?
No. Leaving a number does not show that the consumer expressed an interest in receiving marketing calls, nor does it create indefinite permission to make contact. The company should still verify the acquisition channel, scope of interest, time of expression, and original evidence, and apply DNCR screening and frequency controls, subject to the latest official publication.
Q: Does Reimbursing a Salesperson’s Personal Number Make It a Company Number?
No. Who pays the bill does not change the registered owner. Telemarketing calls should use a UAE local number registered under the company’s commercial licence, subject to the latest official publication.
Q: Are WhatsApp Marketing Messages Outside the Telemarketing Rules?
That conclusion should not be assumed. The relevant resolution’s telemarketing definition refers to marketing messages sent through social media applications. The company should still determine the applicable boundary based on the specific channel, business activity, and competent authority requirements, subject to the latest official publication.
Q: Does Outsourcing the Call Centre Remove the Original Company’s Responsibility?
A transfer of responsibility should not be assumed. Before launch, clarify both parties’ licensing, number ownership, list basis, DNCR screening, scripts, recording, recordkeeping, and complaint-handling responsibilities. Document them in the contract and ongoing audit arrangements.
Action Checklist: If the Release Conditions Are Incomplete, Do Not Call Yet
- Confirm the source of each number, the scope of marketing interest, and the time it was expressed.
- Define the activity, competent authority, approval scope, and validity period.
- Stop using personal mobile numbers and standardise on local numbers registered to the company.
- Put DNCR screening, calling hours, and refusal and unanswered-call frequency controls into the system.
- Fix the approved script version, recording notice, call records, and evidence-export process.
- Release the list only after business, compliance, and IT sign together.
If your business needs to map the competent authority, approval route, and outbound controls against its commercial licence, activities, and emirate, Schedule a 30-minute complimentary assessment to confirm the applicable boundary before deciding how to launch.
Last updated: September 2026. This content is for informational purposes only and does not constitute legal or tax advice. For professional consultation, please contact the MIRISE team.