Scope. A cold call to a property owner who never enquired is outbound telemarketing under UAE law. That puts it inside the scope of the 2024 Cabinet Resolution on regulating telemarketing calls, the TDRA registration and calling-window rules, and the PDPL notice-and-consent requirements for recording. Buyer callbacks from a portal enquiry are inbound and fall outside this scope.
1. Cabinet Resolution 56 of 2024
Cabinet Resolution No. 56 of 2024 concerns regulating telemarketing calls in the UAE. It was issued in June 2024 and took effect on 27 August 2024. It applies to any telemarketing call made from a UAE-licensed entity to a consumer inside the UAE, including calls placed to lease or acquire real-estate listings.
Under the Resolution, licensed establishments must:
- Only place telemarketing calls from numbers registered with the competent authority for that purpose.
- Only call between 09:00 and 18:00, UAE local time.
- Not call any number listed on the Do Not Call Registry.
- Identify the caller and the represented entity at the start of the call.
- Honour a request to be removed from the calling list immediately, and not call that consumer again.
- Retain records of consent, call outcomes and complaints for inspection by the competent authority.
Penalties escalate for repeat violations. The Resolution provides for administrative fines on the licensed entity; in serious or repeated cases the competent authority may suspend the entity's telemarketing activity. The exact schedule of fines is published by the competent authority.
2. TDRA registration and the DNCR
The Telecommunications and Digital Government Regulatory Authority (TDRA) operates the UAE's Do Not Call Registry (DNCR). A brokerage that wants to place outbound telemarketing calls must, before starting, register with its licensing authority as a telemarketer and use numbers approved for that purpose.
A consumer can add their number to the DNCR through the TDRA channels published at tdra.gov.ae/en/dncr. Once a number is on the registry, calling it is a violation of the Resolution regardless of any prior relationship, unless the consumer has given specific, recorded consent.
3. Calling window (Asia/Dubai)
The calling window is 09:00 to 18:00 UAE local time. No telemarketing calls on official public holidays. The window is a hard rule, being one minute early or one minute late is still a breach. Practically, this means dialer software must be time-zone aware and refuse to place a call outside the window rather than trying to catch it later.
4. PDPL, notice, purpose, and recording
Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the PDPL) governs how personal data is collected and processed. For a telemarketing call, the relevant obligations are:
- Notify the data subject that the call is being recorded, before recording begins.
- Disclose the purpose of the call and the identity of the controller at the point of collection.
- Provide a mechanism for the data subject to withdraw consent, and honour it without delay.
"Remove me" on a call must halt processing across the controller, not only in the campaign that placed the call. The right applies to the entity, not to one workflow inside it.
5. RERA disclosure
Dubai Law No. 85 of 2006 regulating the real estate brokers register requires a brokerage to identify itself by its registered name when acting in a brokerage capacity. On request from the consumer, the broker must provide the ORN (Office Registration Number) of the agency.
6. What is not enough
A prompt is not a control. A verbal instruction to a telemarketer to "stay inside 9 to 6" is not a control. The Resolution assumes the licensed entity has controls in the system that placed the call. A schedule that refuses to dial outside the window, a suppression list that is scrubbed at claim time, an audit trail that can be produced on inspection.
How EstateCaller implements these controls at the database layer is documented in the reference implementation.
Sources
- UAE Cabinet Resolution No. 56 of 2024 on Regulating Telemarketing Calls. Official UAE government portal: u.ae, regulating telemarketing calls.
- Telecommunications and Digital Government Regulatory Authority (TDRA), Do Not Call Registry: tdra.gov.ae/en/dncr.
- Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL). Official UAE government portal: u.ae, data protection laws.
- Dubai Law No. 85 of 2006 concerning Regulating the Real Estate Brokers Register in the Emirate of Dubai. Dubai Land Department: dubailand.gov.ae/en/legislation.
This page is a working reference, not legal advice. The official Arabic text of any UAE law or resolution is authoritative. Confirm current fine schedules and procedural details with the competent authority before relying on them for a brokerage's compliance programme.