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AI cold calling: mostly no.

Voice AI can make a lot of calls cheaply, which is exactly why telemarketing rules matter. In both markets we work in, unsolicited sales calls are now heavily restricted.

Short answer

In practice, unsolicited AI sales calls are not a viable channel in the UAE or the Netherlands. In the UAE, Cabinet Resolution No. 56 of 2024 on telemarketing, as summarised by law firms, requires approval and consent, restricts calling hours to 9:00 to 18:00, bars calls to numbers on the Do Not Call Register and requires records of calls. In the Netherlands, telemarketing to consumers has required prior consent since 1 July 2021, and from 1 July 2026 the exception for existing customers no longer applies to calls. Oravel does not build cold AI calling; voice agents answer inbound calls or call people who asked to be called.

Rules compared

UAE and the Netherlands.

TopicUAENetherlands
Main ruleCabinet Resolution No. 56 of 2024 on telemarketing (penalties in Resolution No. 57 of 2024), as reportedTelecommunicatiewet, art. 11.7; supervised by the ACM
ConsentConsent required for marketing calls, per law-firm summaries; respect the Do Not Call RegisterPrior consent required for calls to consumers since 1 July 2021
Existing customersCheck with your adviser; repeated calls to people who declined are restrictedFrom 1 July 2026, a customer relationship alone no longer allows sales calls
Hours and recordsCalls reported to be limited to 9:00–18:00; calls recorded and keptNo anonymous numbers; consent must be provable
ComplaintsConsumers can complain to the TDRAConsumers can complain to the ACM

Orientation only, based on the sources below; several UAE details come from law-firm summaries. Ask a lawyer before any outbound calling campaign.

What still works

Legitimate uses of voice AI.

Voice agents are useful where the person expects or asked for the call.

Answering inbound calls after hours and at peak times
Calling back people who requested a callback
Appointment reminders to patients or customers who agreed to them
Service calls about an existing order, not a sales pitch
The AI layer

Extra duties when the caller is a machine.

In the EU, a voice agent must make clear it is an AI system (Article 50 of the AI Act, from 2 August 2026). We apply the same disclosure in the UAE. The agent also needs a clean way to stop: a person who says no is added to your suppression list immediately.

Email follows different rules. In the Netherlands the existing-customer exception still exists for email to your own customers about similar products, with an opt-out in every message; it was removed only for telemarketing calls.

Note

Not legal advice.

This guide is general information, checked against the sources listed, and not legal advice. Rules change; check the current text or ask a lawyer before you rely on it. Checked November 2026.

FAQ

Common questions.

Can we use AI to call old leads who once gave us their number?

In the Netherlands, only if they gave consent to be called that you can prove. In the UAE, check consent, the Do Not Call Register and the call-hour rules with your adviser first. In most cases a WhatsApp or email follow-up on the channel they used is the safer route.

Does this apply to B2B calls?

The Dutch rules focus on consumers and, from 2026, small businesses are also covered in some respects; the UAE rules are written broadly. Check your situation with a lawyer.

Do you build outbound voice campaigns?

No cold calling. We build inbound voice agents, callbacks and reminder calls to people who agreed to them.

What about WhatsApp marketing?

Marketing templates only go to people who opted in, under Meta's policy and local consent rules.

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