UAE Telemarketing Rules: How to Follow Up Leads Without Fines

A lead form fills in at 8:40 pm. A keen salesperson calls straight away from their own mobile. In the UAE, that one call can break three separate rules: it is outside permitted calling hours, it comes from a number that is not registered to the company’s licence, and nobody told the prospect the call was being recorded (or it was not recorded at all).

Since August 2024, phone and message follow-up in the UAE has been governed by two Cabinet Resolutions. This guide covers what they say, where the text is unclear, and how to redesign the path from a Meta or Google lead form to a call or WhatsApp conversation. It is practical guidance, not legal advice: check the current rules with your licensing authority or a UAE lawyer before you change your process.

What Resolutions 56 and 57 of 2024 actually require

Cabinet Resolution No. 56 of 2024 sets out the telemarketing rules, and Cabinet Resolution No. 57 of 2024 sets the penalties. Both were issued on 10 June 2024 and came into force 60 days after publication in the Official Gazette. Law firms reported publication on 28 June 2024 and an effective date of 27 August 2024 (Morgan Lewis, Al Tamimi). They apply to all licensed companies in the UAE, including free zone companies.

Two definitions in Article 1 matter most for sales teams. “Telemarketing” covers marketing calls to landlines and mobiles and expressly includes “marketing text messages and marketing messages through social media applications”. “Unwanted marketing phone calls” are calls that break the resolution, and they “do not include Marketing Phone Calls made at the request of the Consumer”. A consumer is defined as a natural person.

The core obligations, with the first-offence fine for a company under Resolution 57, are:

Fines are only part of the ladder. Resolution 57 also allows warnings, suspension of activity for 7 to 90 days, licence cancellation, removal from the commercial register and disconnection of numbers, and a repeat of the same violation within six months can go straight to the most severe penalty. Individuals who market products or services from numbers licensed in their own name face a separate scale, starting at AED 5,000 and disconnection of their numbers until the fine is paid.

The Ministry of Economy (now the Ministry of Economy and Tourism) has general oversight; the Central Bank covers banks, financial institutions and insurers, the SCA covers securities and commodities, and each emirate’s licensing authority covers most other companies. Your “competent authority” depends on where and how you are licensed.

Is your lead follow-up “telemarketing”?

The official text does not settle this, and we found no official guidance that does. The three points below are open questions, not settled rules: read them as a way to decide how cautious to be, not as legal advice, and confirm your position with a UAE lawyer.

Requested contact sits outside “unwanted” calls

The definition excludes calls “made at the request of the Consumer”. A person who fills in a form that says “Call me about a quotation” has arguably requested the call, though no authority has said how this exclusion applies to ad lead forms. Someone who downloaded a brochure or entered a giveaway has not clearly asked to be called. The difference lives in your form wording.

“Consumer” means a natural person

The resolution protects natural persons and does not set out a separate rule for business-to-business calls. A procurement manager is still a natural person, often on a personal mobile. Nothing in the text exempts B2B calls, so the safer working assumption is that your calls to individual buyers are covered.

Messages count, not only calls

Because the definition includes marketing messages through social media applications, an unsolicited WhatsApp promotion is inside the scope of the resolution even though nobody dialled a number. Note one difference between sources: DLA Piper’s data protection guide reads Article 4 as requiring consent before electronic marketing through social media messages. The official English text of Article 4.4 asks companies to create a channel for consumers interested in marketing information and to make marketing contact “only” with those consumers. Both readings point the same way in practice: message people who have asked to hear from you, and be able to show that they did.

Redesign the path from lead form to first contact

The rules do not stop speed; they move it into specific hours and channels.

1. Rewrite the form so the request is explicit. Ask how and when the person wants to be contacted: “Call me”, “WhatsApp me”, “Email the quotation”. Add a separate, unticked choice for receiving offers and news. Check which question and disclaimer fields your lead-form tool currently offers; the same form questions also filter out the fake and unreachable leads that waste call time.
2. Store the evidence with the lead. Pass the form name, consent wording, options chosen and timestamp into your CRM. Article 4.12 lets the authority ask for the source of a consumer’s number; “from a Meta form on 12 March, with the call-back option ticked” is a far better answer than “from a campaign”.
3. Route by time of day. Leads that arrive between 9:00 am and 6:00 pm go to a salesperson to call. Out-of-hours leads get an automatic acknowledgement on the channel they chose (“Thanks, our team will call you tomorrow from 9 am”) and a task in the next morning’s first call queue.
4. Check the DNCR before any promotional call. Your telecom provider gives business customers a way to check numbers against the registry; e&’s DNCR page for businesses, for example, describes checking through its business online portal and says a DNCR number should not receive promotional calls even if consent was given. That sits uneasily with the resolution’s exclusion for calls made at the consumer’s request, and the official text does not resolve it. Until your adviser confirms otherwise, treat a DNCR-listed lead as not callable for promotion and reply on the channel the lead chose in writing.
5. Make the first call a compliant one. Use a company number registered under the trade licence, through a system that records calls. The opening line names the company, states the reason (“you asked for a quotation for…”), says the call is recorded, and asks whether now is a good time to continue.
6. Log the outcome as a rule, not a note. “Not interested” closes call follow-up for that lead. “No answer” allows at most one callback a day and two a week. Let the CRM enforce this, not memory.

If every lead goes to a shared phone, the fix is campaign design as much as sales discipline: build the form, the WhatsApp inquiry flow and the tracking together as one performance marketing setup, so the lead arrives with the consent record attached. Why out-of-hours leads cool so fast is covered in our article on WhatsApp inquiries going cold.

WhatsApp follow-up without creating a second problem

WhatsApp has its own rules on top of the UAE’s. The WhatsApp Business Messaging Policy (last updated 23 September 2026) says you may only contact people on WhatsApp if they have given you their number (or username) and you have received opt-in permission confirming that they wish to receive messages from you. It also requires you to respect every request to stop, on or off WhatsApp. It recommends an opt-in that covers the categories of messages you will send.

Three habits follow:

• Separate service from marketing. Sending the quotation the lead asked for is service. Sending next month’s promotion to the same number is marketing and needs the separate permission you collected on the form.
• Do not import numbers into broadcasts. Numbers from an exhibition, a bought database or an old spreadsheet carry no opt-in, and trading consumer data for marketing without consent carries one of the highest UAE fines.
• Treat “stop” as final across channels. If a lead asks you to stop on WhatsApp, record it so nobody calls them the next day either.

For the sequence of touches after a quotation, see our guide to sales follow-up automation.

The call script and team rules your sales director should own

A compliant opening, in Arabic and English

Write the first 20 seconds of every follow-up call as a fixed script in both languages: company name, the reason tied to the lead’s request, the recording notice and a question about continuing.

Company numbers only

Resolution 56 requires local numbers registered under the company’s commercial licence (Art. 4.3) and bars marketing from numbers the company does not own or have registered (Art. 4.13); separately, Article 3.2 bars individuals from marketing their products or services through numbers licensed in their own name. Move sales follow-up off personal SIMs and personal WhatsApp accounts onto company-registered lines and a business messaging setup the company controls (see WhatsApp Business app or API for when a shared app inbox stops being enough).

Approval, training and records

Confirm with your licensing authority whether you need telemarketing approval, and file the evidence. Train everyone who calls or messages leads on the script, the DNCR and the callback limits, record the training, and keep call logs and recordings for the period your authority sets.

Sales messaging, scripts and WhatsApp flows are part of our sales enablement service; we draft them, your team approves them, and your compliance adviser signs off on the regulated wording.

Enforcement is already happening

On 25 February 2025, the Dubai Corporation for Consumer Protection and Fair Trade, part of Dubai’s Department of Economy and Tourism, said it had warned 174 companies and then fined 159 companies AED 50,000 each, working with the Ministry of Economy and the TDRA, which manages the DNCR (Gulf Today, Dubai Eye). The reports did not break the fines down by violation; they reminded companies of three key rules: no calls to DNCR numbers, calls only between 9:00 am and 6:00 pm, and telling customers at the start when a call is recorded. AGBI put the total at about AED 8 million and noted that cold calls from real estate, trading and crypto firms remain a common complaint.

In August 2026, The National reported TDRA figures covering the period since August 2024: more than AED 19 million in fines, 9,433 numbers disconnected, 92,748 numbers reported by the public and 3,301 violations detected.

Financial firms have an extra layer. The Central Bank’s Telemarketing Regulation (Circular 3/2026), shown in its rulebook as in force from 31 March 2026, requires licensed financial institutions to obtain prior express consent before telemarketing and keeps calls to 9:00 am to 6:00 pm (Gulf News, April 2026). If you are a bank, insurer or finance company, check that text as well.

A one-page checklist for sales and marketing

If your process depends on calling everyone immediately from whatever phone is nearest, fix the form and the routing first. The script and the CRM rules follow from there. Rules and enforcement practice change, so check the current text with your competent authority before relying on any point here.