Three separate rulebooks apply, and the one most likely to reach a Dubai brokerage first is its own regulator, not the federal telecom authority. Here is what each one documents, and where the public record runs out.
A Dubai brokerage that cold calls property owners meets the Dubai Land Department before it meets anyone in Abu Dhabi. DLD circular 02-2026, dated 26 February 2026, prohibits brokerage offices from obtaining owner data by unlawful means and from contacting those owners for marketing. RERA has already fined a brokerage AED 50,000 and suspended nine brokers for cold calling to promote real estate services. Above that sits Cabinet Resolution No. 56 of 2024: marketing calls between 09:00 and 18:00 only, from a number registered to your own company, recorded with notice, screened against the Do Not Call Registry. The question every agent actually asks, whether a Bayut or Property Finder enquiry can be called back, has no settled answer. This page says so instead of inventing one.
Published · Sources
Most published guidance on UAE cold calling starts and ends with the federal telemarketing regulations. For a licensed brokerage in Dubai that is the third layer down, and the slowest of the three to arrive.
The first layer is the Dubai Land Department. DLD licenses brokerage offices and issues listing permits through Trakheesi, registers tenancy contracts through Ejari, and maintains the ownership register that a cold-calling list is usually assembled from in the first place. It regulates conduct directly, by circular, to every registered office.
The second is RERA, the regulatory arm inside DLD that issues broker cards. RERA can fine an office and suspend or strike off the individual agent. For a working broker that is the sharper instrument, because a broker card is the permission to trade at all.
The third is federal: Cabinet Resolution No. 56 of 2024, the TDRA Do Not Call Registry, and the Ministry of Economy's administrative penalty tables. A brokerage can be entirely compliant with the federal regime and still be struck off by RERA. The layers stack; none of them replaces another.
The document at the centre of this question is DLD circular 02-2026, dated 26 February 2026, carrying the reference DLD/OUT/2026/0001641. Its title translates as "Regulations Governing Communication with Property Owners and the Prohibition of Cold Callings".
What it does is narrow and specific. It prohibits brokerage offices from obtaining property owner data by unlawful means, and from contacting those owners for marketing purposes. It carries an exception for documented existing clients, and that exception is worded tightly enough that an office relying on it will need the documentation to hand rather than a recollection of a past deal.
The penalties described in the circular are a fine of AED 50,000, suspension of the office for three months, and permanent striking off for repeat offences. They apply to the brokerage office and to the individual broker. A junior agent working an owner list bought from a data broker is exposed personally, not only through their employer.
The copy of circular 02-2026 available to us is a scanned Arabic PDF. Optical text recovery did not reliably resolve the clause numbering, so this page publishes no numbered penalty schedule and cites no article numbers from it. The substance above is what the document says; the structure it says it in is not something we can vouch for. Anyone building a compliance policy on the circular should obtain the Arabic original through DLD and have it read by counsel.
We also could not find any English-language media reporting on this circular, and no Arabic reporting either. For a measure carrying a AED 50,000 fine and permanent striking off, that silence is worth stating plainly. It is the reason most brokerages in Business Bay and Dubai Marina have never heard of it, and the reason nearly every English-language page on Dubai cold calling published since February 2026 is describing the wrong rulebook.
This is not a dormant rule. RERA fined a brokerage AED 50,000 and suspended nine brokers specifically for cold calling to promote real estate services.
Two things about the shape of that penalty matter more than the amount. The fine landed on the office and the suspensions landed on named individuals, which is the pattern the circular describes. And the conduct penalised was cold calling to promote real estate services, not a data-protection breach adjacent to it. A brokerage that treats caller behaviour as an HR matter and data sourcing as an IT matter is looking at the wrong pair of risks.
Above the Dubai rules sits the federal telemarketing regime. Cabinet Resolution No. 56 of 2024 and its penalties companion Cabinet Resolution No. 57 of 2024 are published on the UAE Legislation portal. For a brokerage the operative requirements are:
The resolution is technology neutral. It does not carve out or separately restrict automated calls, so an AI voice agent calling a lead about an off-plan release in Business Bay is under the same obligations as the agent sitting next to it.
The UAE Ministry of Economy publishes the administrative penalty tables in English. For any brokerage running a power dialler, a predictive dialler or an AI voice agent, the single most relevant line is Table 1, Row 16: automatic or automated calling, AED 10,000 to AED 50,000.
That row sits alongside the conduct penalties rather than replacing them. A campaign that dials automatically, at 19:30, from an unregistered number, into a list of Palm Jumeirah owners obtained from a leaked spreadsheet is not looking at one penalty. It is looking at a federal automated-calling penalty, a federal hours penalty, a federal number-registration penalty, and a DLD circular that reaches the agent's broker card.
This is the question every Dubai agent has, and the honest answer is that it is unsettled. Every vendor page that asserts a clean answer asserts it without a citation. Here is the actual state of the record.
The point turns on two provisions of Cabinet Resolution 56 of 2024, pulling in opposite directions.
The regime regulates calls made to market a product or service to a consumer, and it treats a consumer's own request or consent differently from an unsolicited approach. A buyer who fills in the enquiry form under a Property Finder listing for a two-bedroom in Business Bay, or messages through Bayut about a Damac tower, has asked to be contacted about that property. On this reading the callback is a requested contact and the enquiry record is the evidence of the request. That is the reading the entire Dubai portal economy operates on, and Bayut, Property Finder and Dubizzle all hand the enquirer's number to the listing agent on exactly that assumption.
The registry provision is drafted as a prohibition on calling registered numbers, and operator guidance describes registration as overriding prior consent. On this reading, a person whose number is on the registry cannot be called back for marketing at all, whatever they typed into a portal form. The enquiry gives you a reason to call; it does not give you a route past the registry. If that is right, then a meaningful slice of portal enquiries in Dubai are unreachable by phone and reachable only by WhatsApp or email.
Both readings are defensible on the published text. We could not find a regulator statement resolving the point, and no published enforcement decision on this specific fact pattern. So the practical answer is that a brokerage should screen portal enquiries against the registry like any other list, keep the enquiry record, and understand that it is carrying an unresolved risk rather than an approved practice.
One thing the record does settle: the DLD circular is a different fact pattern. The circular targets owner data obtained unlawfully. A prospective buyer who submitted an enquiry on a Nakheel or Emaar listing is not an owner contacted from a leaked register. That does not resolve the federal question, but it does mean the two exposures are separate and a brokerage should stop treating them as one problem.
The Do Not Call Registry is run by the Telecommunications and Digital Government Regulatory Authority. Two shortcodes are in circulation and both are real: 2211 is TDRA's current national route, and 1012 remains live and is the number that both e& and du document on their own pages. Cite both. A broker who has only ever seen one of them will assume the other is a typo and skip the check.
A third shortcode, 5222, circulates online and is sometimes attributed to du. We could not find it on any operator or regulator page. The only place we traced it to was inside an AI-generated summary, which is a reasonable description of how it entered circulation. Do not use it.
Screening itself runs through your telecom operator. e& provides business customers registry access through its business portal. This remains the brokerage's obligation as the licensee and no calling vendor can discharge it for you.
The rule that Do Not Call Registry registration overrides prior consent, together with the duty to verify a number before calling it, was documented by du in August 2023. It is widely reported as a 2026 change. It is not one.
The date matters commercially. A brokerage told that this is new in 2026 will conclude that its 2024 and 2025 campaigns were fine under the old rules. They were not under different rules. If you ran unscreened consent-based calling into Dubai owner lists in 2024, the exposure is real and already accrued.
Separately, a change dated 1 September 2026 is described on e&'s own Do Not Call Registry page. We looked for the underlying instrument on tdra.gov.ae, on u.ae and on uaelegislation.gov.ae and could not find it. There is no findable document called a "TDRA Voice Spam Policy", despite that name appearing in several vendor blogs. Until a regulation text surfaces, the correct way to describe the September 2026 position is as what the carrier says applies to its own network, not as a named regulation.
Two figures circulate in UAE telemarketing coverage: roughly Dh19 million in fines, and 9,433 line disconnections. They appear in enough places to look confirmed. Three caveats travel with them and are usually dropped.
Treat the figures as indicative of enforcement appetite and nothing more precise than that.
The reason DLD wrote a circular about data acquisition rather than about calling manners is that Dubai owner-contact data leaks constantly. Freehold ownership records, service-charge rosters, Ejari tenancy data, handover lists from off-plan projects, and building-management contact sheets for towers in Business Bay, Dubai Marina and Palm Jumeirah move between brokerages on WhatsApp and USB sticks. Lists of Emaar, Damac and Nakheel handover buyers are traded openly enough that most agents have been offered one. DLD already sees an office through Trakheesi, so its listing activity and its carded agents are mapped on the regulator's side before any complaint is filed.
The circular's hinge is the phrase about obtaining owner data by unlawful means. In practice the compliance question for a Dubai brokerage is whether it can produce, for any given number, a lawful account of how that number was obtained. Call manners are a secondary matter. If the honest answer is that it arrived in a spreadsheet from a former colleague, the office is exposed regardless of what was said on the call, and so is the agent who dialled.
Lumaa is an AI calling platform built in Dubai. Maya, its voice agent, places calls from your own company-registered UAE line, records every call with the disclosure delivered at the start from a script you approve, keeps a transcript and a call log for each one, and runs campaigns inside the 09:00 to 18:00 window. Those are the mechanical parts of Resolution 56, and a platform can carry them consistently in a way a sales floor of twenty agents on personal phones cannot.
What it does not do: Lumaa has no native integration with Bayut, Property Finder or Dubizzle, and no native CRM connector. Lead lists come in as CSV or XLSX. Anyone telling a Dubai brokerage that their portal leads flow automatically into an AI dialler should be asked to demonstrate it.
Registry screening, and the lawful sourcing of any owner list under the DLD circular, remain the brokerage's own obligations as the licensee. No vendor can take those on. If you want to see the mechanics rather than read about them, book a demo, or read the wider federal picture in our UAE AI calling compliance guide.
Not traced to a primary source, and therefore not relied on above: the Dh19 million fines and 9,433 disconnection figures (Gulf Today reported a conflicting 97,248), and the RERA penalty announcement, which we describe from its published terms without a stable official URL. This guide is general information for brokerage owners and sales managers, not legal advice. Verify current requirements with counsel, with DLD, and with your licensing authority before changing a calling policy. Position as of 3 September 2026.
Your own registered line, every call recorded and disclosed, inside the window, with the log to prove it.