es — AI voice agents can legally place calls in the EU, the US and the UAE, but each market adds conditions. From 2 August 2026, Article 50 of the EU AI Act requires people to be told they are talking to an AI unless that is obvious; since February 2024 the US FCC treats AI-generated voices as "artificial" voices under the TCPA, so prior express consent is needed; and in the UAE, Cabinet Resolution No. 56 of 2024 allows automated marketing calls only between 9 am and 6 pm, never to numbers on the Do Not Call Register, with the company and purpose stated at the start.
This guide summarises public regulatory texts and press reports as of 26 September 2026. It is general information, not legal advice — confirm your obligations with your regulator or counsel.
Key takeaways
- EU: AI systems that talk to people must be designed so that people are informed they are interacting with an AI, at the latest at the first interaction (Article 50(1) and (5) of Regulation (EU) 2024/1689). It applies from 2 August 2026, including to non-EU companies whose AI output is used in the EU.
- US: FCC Declaratory Ruling FCC 24-17 (adopted 2 February 2024) confirms that TCPA rules on "artificial or prerecorded voice" cover AI-generated voices, so AI calls need prior express consent and must identify the caller.
- UAE: Cabinet Resolution No. 56 of 2024 (the Telemarketing Regulations) explicitly permits automated communication systems for marketing — within its rules on hours, the DNCR, recording notices and caller identification. Resolution No. 57 of 2024 sets the penalties.
- The safest global script says who is calling, on whose behalf, why, that the caller is an AI, that the call is recorded, and asks whether the person wants to continue.
- Compliance has to run per call in software — DNC checks, calling windows, consent records and a kill switch — not in a policy document.
Must an AI voice agent say it is an AI?
In the EU, yes, unless it is obvious. Article 50(1) of the AI Act says providers "shall ensure that AI systems intended to interact directly with natural persons are designed and developed in such a way that the natural persons concerned are informed that they are interacting with an AI system, unless this is obvious from the point of view of a natural person who is reasonably well-informed, observant and circumspect". Article 50(5) adds that the information must be given "in a clear and distinguishable manner at the latest at the time of the first interaction or exposure". On a phone call, a natural-sounding synthetic voice is rarely obvious — so the disclosure belongs in the opening line.
In the US, the FCC's 2024 ruling does not add a separate "I am an AI" sentence, but it applies the existing artificial-voice rules: the message must state clearly the identity of the business at the beginning and a telephone number during or after the message (47 CFR 64.1200(b)). In the UAE, Resolution 56 requires the company and the purpose of the call to be identified at the beginning, the consumer to be told when the call is recorded, and the consumer to be asked whether they want to continue before any marketing starts. It has no clause specific to AI, so stating it plainly is good practice rather than a quoted legal duty.
When does EU AI Act Article 50 apply — and to whom?
Article 113 of Regulation (EU) 2024/1689 makes Article 50 applicable from 2 August 2026. The Digital Omnibus on AI, Regulation (EU) 2026/1744 of 8 July 2026, added a narrow grace period: providers of systems generating synthetic audio, image, video or text that were placed on the market before 2 August 2026 have until 2 December 2026 to meet the Article 50(2) duty to mark outputs as artificially generated in a machine-readable way. The disclosure duty in Article 50(1) is not deferred.
Location does not shield you. Article 2(1)(c) covers "providers and deployers of AI systems that have their place of establishment or are located in a third country, where the output produced by the AI system is used in the Union" — so a contact centre in Dubai or Manila calling people in the EU is in scope. Two further duties are worth knowing: Article 50(2) requires providers of synthetic-audio systems to mark outputs in a machine-readable, detectable way, and Article 50(4) requires deployers of deep fakes to disclose them. Breaches of Article 50 can be fined up to EUR 15 million or 3% of worldwide annual turnover, whichever is higher (Article 99(4)); for SMEs the lower of the two applies.
Article 50 is a transparency rule. Whether you may make a marketing call at all is still decided by national telemarketing, consent and data-protection law in each member state.
Are AI-generated voices an "artificial voice" under the TCPA?
Yes. In Declaratory Ruling FCC 24-17, adopted on 2 February 2024 and released on 8 February 2024, the FCC concluded that the TCPA's restrictions on "artificial or prerecorded voice" encompass current AI technologies that generate human voices, and therefore require the prior express consent of the called party. For telemarketing, the existing rules require prior express written consent. Announcing the ruling, FCC Chairwoman Rosenworcel noted that State Attorneys General can use it to pursue the bad actors behind these robocalls.
The rest of the TCPA toolkit applies to AI calls as it does to any other. Telephone solicitations may not be made before 8 am or after 9 pm at the called party's location (47 CFR 64.1200(c)(1)). Private plaintiffs can recover $500 per violation, and a court may treble that for wilful or knowing violations (47 U.S.C. 227(b)(3)). One change to note: the FCC's 2023 "one-to-one consent" rule never took effect — the Eleventh Circuit vacated it in January 2025 and the FCC restored the prior definition, effective 29 August 2025. For the consent basics see what TCPA compliance means and what a DNC list is; for caller-ID authentication see our STIR/SHAKEN guide.
Is AI cold calling legal in the UAE, and at what hours?
Automated marketing calls are allowed, inside the Telemarketing Regulations. Cabinet Resolution No. 56 of 2024, issued on 10 June 2024 and in force sixty days after publication (state media reported it in force from 27 August 2024), says "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". Its definition of telemarketing includes marketing text messages and marketing messages on social media apps, not only voice.
- Scope: companies licensed in the UAE, including free-zone companies; natural persons may not make marketing calls from personal numbers.
- Prior approval from the competent authority to practise telemarketing — the Central Bank for banks and insurers, the SCA for securities, local authorities for everything else.
- Only local numbers registered under the company's commercial licence.
- Calls only from 9:00 am to 6:00 pm; never to numbers on the Do Not Call Register (DNCR) supervised by the TDRA.
- No call-back after the consumer rejects the offer; unanswered or ended calls may be retried no more than once a day and twice a week.
- Identify the company and the purpose at the beginning, tell the consumer the call is recorded, and ask whether they want to continue before marketing.
- Keep a record of marketing calls and submit periodic reports to the competent authority.
Penalties sit in Cabinet Resolution No. 57 of 2024. The Ministry of Economy describes it as listing 18 types of administrative violations with fines ranging from AED 10,000 to AED 150,000, and escalating fines of AED 5,000, AED 20,000 and AED 50,000 with service suspension for individuals who make unauthorised marketing calls. For SMS-specific rules see UAE SMS regulations and our explainer on UAE Cabinet Resolution No. 56 of 2024.
The rules side by side
| EU — AI Act Article 50 | US — TCPA and FCC 24-17 | UAE — Cabinet Resolutions 56 and 57 of 2024 | |
|---|---|---|---|
| Applies from | 2 Aug 2026 (50(2) marking for systems already on the market: 2 Dec 2026) | Ruling adopted 2 Feb 2024 | In force 60 days after publication; reported 27 Aug 2024 |
| AI disclosure | Required unless obvious, at the latest at first interaction | Identify the business at the start and give a phone number | Identify company and purpose at the start; no AI-specific clause |
| Consent / lists | Set by national telemarketing and data-protection law | Prior express consent; written consent for telemarketing | No calls to DNCR numbers; stop after a rejection |
| Calling hours | Set nationally | 8 am – 9 pm called party's local time (solicitations) | 9 am – 6 pm |
| Recording notice | Set nationally | Set by state law | Inform the consumer when the call begins |
| Penalties | Up to EUR 15m or 3% of worldwide turnover | $500 per violation, up to treble if wilful; FCC and state AG enforcement | AED 10,000 – 150,000 per violation type |
What should an AI disclosure script say?
A good opening line satisfies all three regimes at once. The examples below are illustrations, not legal templates — adapt them to your market and counsel's advice.
- Outbound service call: "Hello, this is Layla, an AI assistant calling on behalf of [Company] about your delivery booked for tomorrow. This call is recorded. Is now a good time to continue?"
- Collections reminder: "Good afternoon, this is an automated AI assistant from [Company] calling about your account. This call is recorded. Would you like to continue, or would you prefer a call from a member of our team?"
- Marketing call to a consented contact: "Hi, this is [Company]'s AI assistant. You asked us to call you about [product]. The call is recorded. Shall I continue?"
- Always offer a human hand-off, a way to stop future calls, and a call-back number that reaches your business.
Compliance checklist for AI calling campaigns
- Map each campaign to the jurisdictions of the people you call, not where your agents sit.
- Record the consent basis per contact (prior express consent, written consent for US telemarketing) and honour revocations on the next attempt.
- Scrub every attempt — not every import — against DNC registries such as the UAE DNCR.
- Enforce calling windows in the called party's time zone: 9 am – 6 pm in the UAE, 8 am – 9 pm in the US for solicitations.
- Open every call with AI disclosure, company, purpose and recording notice, and ask whether to continue.
- Cap retries: in the UAE, no more than once a day and twice a week for unanswered or ended calls, and none after a rejection.
- Use local, company-registered caller IDs where required and sign calls where STIR/SHAKEN applies.
- Keep recordings, transcripts and an audit trail of every override, and a kill switch that stops one agent, one campaign or all AI calling.
How DialerBee supports compliant AI calling
DialerBee, BroadNet's AI contact-centre platform, puts these checks on every call attempt rather than on the list upload. Its Compliance Autopilot checks each attempt against the current DNC list, the calling window for the jurisdiction, the consent record, caller-ID ownership, a frequency limit and the phone format, with jurisdiction packs for UAE TDRA, KSA CITC, Jordan TRC and Bahrain TRA and US time zones taken from the number. Overrides are recorded with an audit trail, and consent revocation takes effect on the next attempt.
Its AI voice agents, Layla and Moaz, answer from documents you upload, speak only prices from your catalogue, handle interruptions, and leave a recording, transcript and outcome in your CRM after every call; supervisors can stop one agent, one campaign or all AI calling. Arabic is handled as dialects rather than one flattened language. DialerBee describes these as compliance-supporting controls: they help you meet obligations under frameworks such as TCPA and GDPR, and do not replace your own counsel. For the product and ROI view, read our AI outbound dialer guide; for network-side protection, see robocall mitigation and programmable voice.
Frequently asked questions
Are AI phone calls legal?
Yes, in the EU, the US and the UAE, provided you meet each market's conditions: AI disclosure in the EU from 2 August 2026, prior express consent and caller identification under the US TCPA, and the UAE Telemarketing Regulations' rules on hours, the DNCR, recording notices and caller identification.
Must an AI voice agent say it is an AI?
Under EU AI Act Article 50, yes — people must be informed they are interacting with an AI unless it is obvious, at the latest at the first interaction. US and UAE rules require the caller to identify the business at the start; saying the agent is an AI is good practice there too.
When does EU AI Act Article 50 apply?
From 2 August 2026. Regulation (EU) 2026/1744 gives providers of synthetic-content systems already on the market before that date until 2 December 2026 for the Article 50(2) marking duty only; the duty to tell people they are talking to an AI is not deferred.
Does the EU AI Act apply to non-EU companies calling EU residents?
Yes. Article 2(1)(c) covers providers and deployers located outside the EU where the output produced by the AI system is used in the Union, so an AI call to a person in the EU is in scope wherever the caller is based.
Are AI-generated voices an "artificial voice" under the TCPA?
Yes. FCC Declaratory Ruling FCC 24-17, adopted on 2 February 2024, holds that TCPA restrictions on artificial or prerecorded voice encompass AI technologies that generate human voices, so these calls require the called party's prior express consent.
Is AI cold calling legal in the UAE, and at what hours?
Cabinet Resolution No. 56 of 2024 allows automated systems for marketing calls by UAE-licensed companies with prior approval, using company-registered local numbers, between 9 am and 6 pm only, and never to numbers on the Do Not Call Register.
What are the UAE telemarketing fines?
Cabinet Resolution No. 57 of 2024 lists administrative violations with fines from AED 10,000 to AED 150,000, according to the Ministry of Economy. Individuals making unauthorised marketing calls face AED 5,000, AED 20,000 and AED 50,000 for repeat violations within 30 days, plus service suspension.
Do I need consent for AI collections calls?
In the US, AI voices are artificial voices under the TCPA, so calls to mobile numbers need the called party's prior express consent, whatever the purpose. In the EU and UAE, check the national rules for debt-collection calls and always disclose the AI and the purpose at the start.
Sources
- Regulation (EU) 2024/1689 (Artificial Intelligence Act), Articles 2, 50, 99 and 113: eur-lex.europa.eu (accessed 26 September 2026).
- Regulation (EU) 2026/1744 (Digital Omnibus on AI), 8 July 2026, published 24 July 2026: publications.europa.eu.
- European Commission — Transparency obligations under Article 50 AI Act, FAQ: digital-strategy.ec.europa.eu (accessed 26 September 2026).
- FCC — Declaratory Ruling FCC 24-17, CG Docket No. 23-362, adopted 2 February 2024: docs.fcc.gov; announcement: fcc.gov.
- 47 CFR 64.1200 (identification and calling-time rules): ecfr.gov; 47 U.S.C. 227: law.cornell.edu.
- FCC Order DA 25-621 (14 July 2025) on the vacated one-to-one consent rule: docs.fcc.gov.
- UAE Cabinet Resolution No. 56 of 2024 on the Telemarketing Regulations (10 June 2024) and the Ministry of Economy briefing on Resolutions 56 and 57 (29 August 2024): moet.gov.ae.
- Aletihad — UAE's new telemarketing regulations come into force, 27 August 2024: en.aletihad.ae.
- DialerBee — Compliance Autopilot and AI Voice Agent feature pages: dialerbee.com (accessed 26 September 2026).