Scope. Outbound calls to property owners with whom the brokerage has no documented prior business relationship are, in Dubai, banned by DLD Circular 02-2026. Where a brokerage does have a documented prior relationship, the call still falls under UAE Cabinet Resolution 56/2024: 09:00–18:00 only, caller ID and purpose and recording notice up front, DNCR screening before every dial, retry caps of 1 per day and 2 per week, and instant suppression on request. Res. 56/2024 applies equally to automated systems, which it expressly permits when they follow its rules.
1. DLD Circular 02-2026 who you may call
Issued by Dubai Land Department on 26 February 2026, the Circular prohibits licensed Dubai brokerages from contacting property owners and investors with whom they have no documented prior business relationship. It targets the practice of calling property owners sourced from leaked lists, scraped portals, or purchased databases.
What is allowed. Contacting owners the brokerage has a documented prior transaction with past buyers, past sellers, past landlords and past tenants, or owners who have signed a representation agreement with the brokerage.
Penalties. A 3-month suspension of the brokerage, an AED 50,000 fine, and revocation of the brokerage licence on repeat breaches.
The primary source is published by DLD at: dubailand.gov.ae, Regulations Governing Communication with Property Owners (PDF).
2. Cabinet Resolution 56 of 2024 how you may call
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, and applies to automated calling systems, which the Resolution expressly permits where they follow its rules.
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, and state the purpose of the call.
- Disclose that the call is recorded, before any marketing content.
- Cap retries to the same number at no more than 1 call per day and 2 calls per week.
- 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.
Administrative fines are set by Cabinet Resolution No. 57 of 2024 and run from AED 10,000 to AED 50,000 per breach, scaling with repetition. In serious or repeated cases the competent authority may suspend the entity's telemarketing activity.
3. 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.
4. 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.
5. 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.
6. 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.
7. 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, a lawful-basis field on every contact that is checked before a row is ever claimable, and an audit trail that can be produced on inspection.
How EstateEngine Voice implements these controls at the database layer is documented in the reference implementation.
Primary sources
- DLD Circular 02-2026, Regulations Governing Communication with Property Owners and the Prohibition of Cold Callings (26 Feb 2026): dubailand.gov.ae, Circular 02-2026 (PDF).
- UAE Cabinet Resolution No. 56 of 2024 on Regulating Telemarketing Calls: uaelegislation.gov.ae, Resolution 56/2024.
- UAE Cabinet Resolution No. 57 of 2024 on Administrative Violations and Fines (AED 10,000–50,000 per breach): uaelegislation.gov.ae, Resolution 57/2024.
- 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, resolution or circular is authoritative. Confirm current fine schedules and procedural details with the competent authority before relying on them for a brokerage's compliance programme.