Skip to content

Compliance

CBUAE's 2026 Telemarketing Rules: What Banks and Insurers Must Know About AI Calls

Anam Jalal

Founder & CEO, MAJ Leads

Updated 27 Jul 2026 · 10 min read

Quick answer

The CBUAE Telemarketing Regulation took effect 19 February 2026, with compliance required by 29 June 2026. It applies only to CBUAE-licensed banks, insurers, and other licensed financial activities, not the general economy. Article 16 requires automated dialers to connect a human within two seconds, and consent must now capture whether contact is by human agent, AI agent, or robocall.

What is the CBUAE Telemarketing Regulation?

It is a sector-specific telemarketing regulation issued by the Central Bank of the UAE, taking effect on 19 February 2026. It sits alongside, not instead of, the economy-wide framework in Cabinet Resolution No. 56 of 2024 and Cabinet Resolution No. 57 of 2024. Article 9(2) of Resolution 56 already reserved this ground: it assigns telemarketing oversight for banks, financial institutions, and insurance companies to the Central Bank, “in the manner stipulated in this resolution and the regulations issued by the Central Bank in this regard.” The 2026 circular is the Central Bank exercising that reserved power for the first time.

CBUAE Telemarketing Regulation at a glance
ItemDetail
Effective date19 February 2026
Compliance deadline29 June 2026
ScopeCBUAE-licensed banks, insurers/reinsurers, other licensed financial activities
Automated/AI dialer ruleConnect the customer to a human telemarketer within 2 seconds of answer (Art. 16)
Marketer trainingMinimum 15 hours
Record retentionMinimum 5 years

One honest caveat before going further: secondary legal sources don't agree on the circular's exact instrument number. CMS Law cites it as Circular 3/2026. Gulf News cites it as Circular No. 2032/2026. The Central Bank's own Rulebook portal wasn't accessible to independently confirm which is correct at the time of writing, so this guide cites the regulation by name and effective date rather than asserting a single circular number as settled.

Who does the CBUAE regulation apply to?

Only CBUAE-licensed financial institutions: banks, insurance and reinsurance companies, and other activities licensed by the Central Bank. It does not touch the general economy. A clinic, a real-estate brokerage, or an e-commerce business making outbound calls is still governed purely by the original Cabinet Resolution 56 of 2024 and Cabinet Resolution 57 of 2024. No amendment to those two resolutions themselves has been found as of this writing. For the full economy-wide framework that still applies to everyone else, see our 2026 UAE telemarketing rules reference.

When must banks and insurers comply?

The regulation took effect on 19 February 2026, but licensed institutions were given a runway to implement it: full compliance is required by 29 June 2026. That deadline lines up with a 90-day implementation period counted from the regulation's Official Gazette publication on 31 March 2026, which is consistent with how the Central Bank has phased in comparable rules before.

What does Article 16 require for automated and AI dialing systems?

Article 16 is the provision most relevant to AI voice agents specifically. It requires that when a bank or insurer uses an automated or AI-driven dialing system, the call must connect the customer to a human telemarketer within two seconds of the customer answering. In practice, this rules out a fully autonomous AI-only sales conversation for outbound telemarketing calls placed by CBUAE-licensed institutions. An automated system can initiate the dial, but the handoff to a person has to happen almost immediately once the customer picks up.

This is a narrower rule than it might first sound. It governs outbound telemarketing dialers specifically, the kind of system that places large volumes of sales calls and connects answered ones to a live agent. It says nothing about inbound AI receptionists, which is a separate use case entirely, or about AI used for non-marketing purposes like fraud alerts or service notifications.

For any AI voice vendor building outbound systems for the UAE financial sector, Article 16 is a design constraint, not a footnote. A dialer built for a bank or insurer client needs a handoff mechanism that reliably completes within two seconds of answer detection, a materially tighter latency budget than most AI voice platforms are built to guarantee for a full speech-to-text, reasoning, and text-to-speech turn. In practice, this pushes CBUAE-compliant automated dialing toward a hybrid architecture: an automated system identifies and connects the call, and a human telemarketer takes the conversation from the first spoken word, rather than an AI agent conducting any part of the sales conversation itself on a CBUAE-regulated outbound telemarketing call.

The regulation raises the bar on what “consent” has to record. Rather than a blanket opt-in, the consent mechanism must capture specific preferences:

“The customer's preferred language, chosen communication channels, preferred method of contact (whether by a human agent, an AI based agent, or a robocall).”
CBUAE Telemarketing Regulation, as reported by CMS Law

That parenthetical is the detail worth sitting with: as far as this research can confirm, this is the first UAE regulatory text to name AI-based calling agents explicitly as a distinct, customer-selectable contact method, on equal footing with a human agent or a robocall. Whatever else changes about UAE telemarketing law in the coming years, this circular is the marker of when AI agents stopped being a hypothetical and started being a defined category in the rulebook.

What are the training and record-keeping requirements?

Two operational requirements round out the regulation. Marketers must complete a minimum of 15 hours of training before making telemarketing calls on behalf of a licensed institution. And institutions must retain telemarketing records, call logs, consent records, and related documentation for a minimum of 5 years. Neither figure is unusual by financial-sector standards; both are stricter than anything the general Cabinet Resolution 56/57 framework specifies for non-financial businesses.

Legal caveat

Legal note: This is an explainer of a newly effective regulation, not legal advice. The circular's own instrument number is contested across secondary sources (see above), and its full text was not directly accessible through the Central Bank's Rulebook portal at the time of writing. If your institution is CBUAE-licensed, confirm the regulation's exact requirements and your compliance deadline directly with the Central Bank or your legal counsel before relying on anything in this guide. MAJ Leads is not a licensed financial institution and does not advise on CBUAE regulatory compliance; it builds AI voice systems designed around the wider UAE telemarketing framework.

Why does this matter if your business isn't a bank or insurer?

Because it is a signal, not a footnote. This is the first time a UAE regulator has written AI-based calling agents into a binding rule by name, and it did so by imposing real constraints: a hard latency limit on automated handoffs, granular consent capture that treats contact method as a customer preference, and sector-specific training and retention duties. Financial services regulators tend to move first and set the pattern that other sectors eventually follow. A business outside CBUAE's remit today has a reasonable basis to expect the direction of travel, not the specific rule, to eventually reach the general economy.

This is also exactly the posture MAJ Leads builds around by default, regardless of which sector a client sits in. Our AI voice agent services are built with disclosure, consent handling, and human-handoff paths designed in from the start rather than retrofitted once a regulator asks for them. An AI receptionist answering inbound enquiries for a bank's retail branch, or an AI appointment-booking agent scheduling a mortgage or insurance consultation, already operates as a named, consented contact method rather than an ambiguous one. For the compliance architecture that applies across every UAE business regardless of sector, see our TDRA-compliant AI voice agent guide.

Sources

Frequently asked questions

What is the CBUAE Telemarketing Regulation and when did it take effect?
It is a sector-specific telemarketing regulation issued by the Central Bank of the UAE, applying only to CBUAE-licensed financial institutions such as banks, insurers, and reinsurers. It took effect on 19 February 2026, and licensed institutions were given a runway to implement its requirements, with full compliance required by 29 June 2026. Rather than replacing the economy-wide telemarketing framework, it supplements Cabinet Resolution 56 and 57 of 2024, which continue to govern telemarketing generally for every other business in the UAE. The Central Bank issued this regulation under authority Resolution 56 itself reserved to it in Article 9(2), which assigns telemarketing oversight for banks, financial institutions, and insurance companies specifically to the Central Bank rather than the Ministry of Economy.
Does the CBUAE regulation replace Cabinet Resolution 56 and 57 for banks?
No, it doesn't replace anything; it adds to the existing framework. Cabinet Resolution 56 of 2024 already reserved telemarketing oversight for banks, financial institutions, and insurance companies to the Central Bank under Article 9(2), stating that such calls are governed by this resolution and by the regulations the Central Bank issues in this regard. The 2026 CBUAE regulation is that reserved authority finally being exercised for the first time, layering sector-specific rules (the two-second automated-dialer handoff, granular consent capture, 15-hour marketer training, and 5-year record retention) on top of the base framework rather than instead of it. Banks and insurers still have to comply with the general DNCR screening, the 09:00 to 18:00 calling window, caller-ID registration, and every other obligation Resolution 56 and 57 already impose on any business conducting telemarketing in the UAE.
What does the CBUAE's two-second rule for AI dialers require?
Article 16 of the CBUAE Telemarketing Regulation requires that when a bank or insurer uses an automated or AI-driven dialing system to make telemarketing calls, the system must connect the customer to a human telemarketer within two seconds of the customer answering the call. In practice, this rules out a fully autonomous AI-only sales pitch on an outbound telemarketing call from a CBUAE-licensed institution; the automated system can place the dial, but the handoff to a person has to happen almost immediately once the customer picks up. The rule is scoped narrowly to outbound telemarketing dialers specifically. It does not restrict inbound AI receptionists answering customer-initiated calls, and it says nothing about AI used for non-marketing purposes such as fraud alerts, payment reminders, or service notifications, which fall outside this regulation's definition of telemarketing altogether.
Do banks and insurers still have to follow the DNCR and the 9-to-6 calling window?
Yes, without exception. The CBUAE regulation is additive, not a replacement. It does not remove any CBUAE-licensed institution's existing obligations under the general Cabinet Resolution 56 and 57 framework, including screening every dial list against the DNCR before calling, restricting outbound telemarketing calls to the 09:00 to 18:00 window, using a caller ID registered to the institution's commercial licence, and recording marketing calls with notice to the consumer at the start of the call. What the CBUAE regulation does is layer additional, sector-specific rules on top of those existing duties: the two-second automated and AI dialer handoff under Article 16, more granular consent capture describing preferred language, channel, and contact method, a minimum 15-hour marketer training requirement, and a minimum 5-year record-retention period. A bank or insurer has to satisfy both sets of rules simultaneously, not choose between them.
Is this the first UAE regulation to mention AI calling agents by name?
Based on the primary and secondary sources reviewed for this guide, yes. The CBUAE regulation's consent provisions require the consent mechanism to capture a customer's preferred language, chosen communication channels, and preferred method of contact, explicitly defined as being by a human agent, an AI-based agent, or a robocall. That explicit, named categorization of AI agents as a distinct, customer-selectable contact method does not appear anywhere in the earlier Cabinet Resolution 56 or 57 of 2024 text, which addresses automated communication systems in general terms but does not single out AI agents by name as their own category. Whatever the eventual fate of the wider UAE AI-regulation landscape, this circular is the first primary or well-sourced secondary text this research identified that writes AI calling agents into a binding rule as a defined, named concept rather than treating them as an unremarkable subset of automated dialing.

Anam Jalal

Founder & CEO, MAJ Leads

Anam Jalal is the founder of MAJ Leads, a Dubai-based AI voice agent company deploying TDRA-compliant AI receptionists and callers for UAE clinics, brokerages and SMEs — working hands-on across UAE telephony and CRM integrations, from SIP provisioning to TDRA compliance configuration.

Read more about Anam

Related articles

Explore our services