Cold calling rules and tools for UAE real estate: how to run outbound calling without breaching the rules

What Dubai brokers may and may not do when contacting owners and investors

Two layers apply, and people mix them up. The first is aimed at real estate brokers specifically: circulars from the Dubai Land Department and its regulator RERA. The second is the UAE's general telemarketing law, which applies to every licensed company. This guide starts with the first, because it is the one that can cost a broker their registration.

I am not a lawyer and this is not legal advice. Confirm anything that matters with the relevant authority or a lawyer.

DLD Circular 02-2026 in plain words

The circular is titled "Regulations Governing Communication with Property Owners and the Prohibition of Cold Callings". It is dated 26 February 2026 and addressed to brokerage offices. In plain terms it says three things.

1. Unlawful data. An office must not get owner or investor information from any source by unlawful means. Where a number came from now matters as much as whether you call it.
2. Direct contact. An office must not contact owners or investors directly, by phone or other communication channels, to offer, market or buy property. The English text says phone or other channels. I have not verified whether it names WhatsApp, so do not assume either way.
3. The exception. Clients with duly documented prior transactions with your office can be contacted, provided the office keeps an approved record evidencing the contractual relationship or previous transaction and submits it to the authority on request.

On complaint, a violation is issued against the office and the broker. The penalties stated are a AED 50,000 fine and a three-month suspension, and repeated violations lead to permanent revocation of the broker's registration. In practice the owner of the brokerage carries the office-level fine and licence risk, and the individual agent can lose their registration on repeat.

It is worth knowing this has been enforced before. In April 2022, RERA fined a brokerage office AED 50,000 and suspended nine brokers for three months over cold calling and direct telemarketing. That release mentions calls only.

Registered numbers only: a setting, not a habit

DLD/RERA Circular 01-2023 (11 April 2023) requires brokers to use the phone numbers registered in the Real Estate Brokers Registry, and not numbers that are not registered with RERA. Violations are penalised as prescribed. For you that means your dialer's caller ID and your agents' calling lines are a compliance setting. Agents using personal SIM cards or unregistered numbers is a rule problem, not only a habit problem. Check each agent's registered number against the one they dial from.

What happens when someone complains

Owners and the public can report unwanted broker calls through Dubai REST, the real estate services app and portal run by the Dubai Land Department, using its Report Malicious Calls service. Gulf News reports that DLD follows up within a week, which I could not confirm on an official page. A complaint can start an investigation, and at that point the first thing you will be asked for is evidence: where the number came from and what the relationship is. If you cannot produce it quickly, you are in trouble even if the call was fine. That is why the record-keeping below matters.

The general telemarketing rules

Separately from the real estate circulars, Cabinet Resolution 56 of 2024 (the federal telemarketing regulation) sets UAE telemarketing rules and applies to every licensed company, free zones included. Marketing calls are limited to 9am to 6pm, and you must not call numbers on the national Do Not Connect Register. The definition of telemarketing includes marketing text messages and marketing messages sent through social media apps, not only calls. Two more points from the text matter to a sales floor: the resolution bars individuals from making marketing calls from personal numbers (Article 3(2)), so agents should not dial prospects from their own mobiles, and a caller must ask the consumer whether they want to continue the call before marketing to them (Article 5(7)). I cannot say how a regulator would apply this to every case, so check the resolution or ask a lawyer.

Penalties are set by Cabinet Resolution 57 of 2024: company fines range from AED 10,000 to AED 150,000 depending on the violation and how many times it is repeated, and the authority can also suspend the business for 7 to 90 days or cancel its licence. Press reports of exact amounts for specific violations conflict, so use the range and read the resolution annex for your case.

One more point I deliberately do not state: whether and when recording a call needs the other person's consent in the UAE. I could not find a primary source, and vendor telephony pages differ. If you record calls, get a lawyer to confirm your disclosure wording. Bitrix24's own help centre, for example, tells users to check that recording complies with local law.

A three-list CRM model

The simplest way to turn the rules into something agents can follow is a status field on every contact that sorts people into three lists:

1. Callable: enquiry or opted-in. People who contacted you or asked to be contacted: portal and ad enquiries, form submissions, referrals who asked for a call. Call them about what they asked.
2. Callable with a record: documented prior transaction. Past clients with a contract or transaction on file. The CRM contact must link to the contract or transaction reference, because the circular expects you to produce that record.
3. Do not contact: cold or unknown. Owner or investor data with no relationship and no documented source. No dialing, no WhatsApp, no email campaign.

The dialer should only be able to load lists one and two. This works because it replaces memory with a field.

Where every number came from: the source field and the evidence file

Make "source" a mandatory CRM field, with values such as portal enquiry, website form, Meta lead ad, referral from [name], past client, event sign-up. A contact with an empty source cannot be called. For prior-transaction contacts, add a field with the contract number or transaction reference and upload the document. Then run a quarterly audit: pick 20 random contacts that agents called and trace each one back to its source. Shared spreadsheets of owner numbers bought from a third party are the classic failure; if one exists in your office, delete it and find out who made it.

How software and AI help with outbound calling, and where a person decides who may be called

A power dialer is software that dials the next number on a list as soon as the agent finishes the previous call, so agents spend time talking and not tapping. Tools that offer this, such as telephony apps on the marketplace of Bitrix24 (a CRM and team workspace), describe their features themselves, so treat the feature lists as vendor claims. What matters for compliance is a short feature list:

• Click-to-call from the CRM, so every call is logged against a contact automatically.
• Call logging with timestamps and notes, giving you proof of when and why each call happened.
• Time windows, so the dialer physically blocks calls outside 9am to 6pm.
• Do-not-contact flag and suppression list import, so numbers on your internal list and any list you maintain are skipped.
• Registered caller ID, locked to the number registered for that broker.
• List scrubbing before every campaign: compare the call list against your consent records, the do-not-contact flag, and the national register as the authority makes it available. Check what access you have to that register and how, because I did not verify an access method.

AI can help in the background. It can summarise call notes into the CRM, flag contacts with an empty source, spot the same number appearing on both the callable and do-not-contact lists, and draft follow-up messages for people who asked to be contacted. It cannot decide who may be called. A named person, not the software, owns that list. Do not use AI to find owner numbers online. That is the exact data-sourcing problem the circular is about.

To try the audit part with Claude, export your call log for the week with columns for contact, source and list status, paste it in and ask: "List every row where the source is empty, or the list status is do-not-contact, or two statuses exist for the same phone number. Do not guess missing values." Then have a person fix each one. For the wider call-note task, see AI call notes and CRM entry. If you want the CRM setup and dialer rules built to your own policy, that is work I do for brokerages, but a well-configured CRM covers most of it.

Warm outreach that replaces cold calls

The better answer to a tighter rule is to need cold calling less. Warm sources a broker can use:

• Answer portal and ad enquiries fast. This is the best-converting call you will make. See speed to lead and Meta lead ads into your CRM.
• Past clients with a documented transaction, using the record rule above.
• Referrals, where the referrer introduces you and the owner has asked to be called.
• Opted-in lists on WhatsApp and email. See the WhatsApp broadcast guide.
• Owners who ask to be called. There was a Green List on Dubai REST for this, reported by Gulf News in 2022. I could not confirm its current status, so check Dubai REST before relying on it.

A weekly compliance review for the owner

Name one person and give them 20 minutes a week. They check: the number of calls made, the number to contacts with an empty source (should be zero), any contact called outside 9am to 6pm (should be zero), calls from any number that is not a registered broker line (should be zero), new imports into the CRM and where they came from, and any complaint received. Keep a one-line note of each review. If a complaint arrives, the notes show you run a process.

Policy checklist for agents

1. I only call people who contacted me, opted in, or have a documented transaction with this office.
2. I record where every number came from.
3. I call between 9am and 6pm, from my registered number.
4. I never buy, scrape or copy owner lists.
5. If someone asks me to stop, I mark them do-not-contact the same day.
6. If I am unsure, I ask the compliance owner before I call.

How I'd approach this

I would start with the status and source fields, because they cost nothing and give you most of the protection. Next I would lock dialing to registered numbers and sensible hours. Only then would I buy a power dialer, and only to speed up calls to people you are allowed to call. Have a lawyer read the policy once.