Since 1 September 2026 the penalty for how a Dubai floor dials reaches the trade licence. This is telephony built so that call is never placed: numbers on your own licence, a phone system you own, and a gate that screens every dial. Every figure on these pages is linked to its source.
Alexander Kuznetsov · VLAN IT · September 2026
We move your agents off personal SIMs and onto Dubai numbers registered to your company's own trade licence, delivered over a carrier SIP trunk from du or e& into a phone system that belongs to you. Every agent keeps calling from their phone or laptop, from the office, from home or from abroad. The difference is that the system checks each number against the Do Not Call Registry before it dials, holds the 09:00 to 18:00 window, records every call with the required announcement, and keeps the call register a regulator can ask for. If a complaint does land, it lands on one agent's number. The rest of the floor keeps working.
What this is not: it is not a cloud subscription you rent forever, and it is not an anonymous number. Both of those are how companies end up with a barred number and nobody to appeal to.
Published by e& on its business Do Not Call Registry page, in English and Arabic, under the heading "Updated August 2026 (Effective 1 September 2026)". No regulator announced it, du and Virgin Mobile do not carry it, and the September round-ups in the press do not list it. Which is why it is worth reading in the original: e& Do Not Call Registry.
At 25 points the trade licence "will be restricted from purchasing telecom services for all active numbers", in e&'s words, and from activating new ones. e& publishes no fee to clear that. A sales floor with no dial tone does not have a compliance problem. It has a revenue problem.
What is not new: the registry itself, reporting a caller to 2211, and the phrase "black points", which UAE call-centre vendors were already using. What is new: the Do Not Originate Register, the 5 and 25 thresholds, the AED 5,000 per number, and the licence lock. Nobody publishes how many points a single validated report earns, so no one can predict when a floor crosses either line. The only available control is not earning them.
Cabinet Resolutions 56 and 57 of 2024 have governed every marketing call in the UAE for two years. The 1 September layer is e&'s enforcement on top of them. These are the six a phone system can either enforce or ignore.
Sources: Cabinet Resolution 56 of 2024 and Cabinet Resolution 57 of 2024 on the UAE legislation portal, and the Ministry of Economy and TDRA announcement of 29 August 2024. Telemarketing in Art 1 includes SMS and messages through social media applications, so the same rules reach WhatsApp. Free zones are inside the regime under Art 3(1).
One agent dials a number that is on the registry, from a SIM in their own name, at 19:00, for a company with no approval on file. Four separate first-offence fines under Cabinet Resolution 57. Not a prediction and not a worst case: the published schedule, read line by line.
| First offence | Article | AED |
|---|---|---|
| Marketing calls without prior approval | CR 57, Art 4(1) | 75,000 |
| Calling a number on the Do Not Call Registry | CR 57, Art 4(5) | 50,000 |
| Calling from a number not on the company licence | CR 57, Art 4(3), 4(13) | 25,000 |
| Calling outside 09:00 to 18:00 | CR 57, Art 5(3) | 10,000 |
| Up to, one call, first offence | 160,000 |
Separately, and from a different rulebook: e& charges what it calls "a regulatory fine of AED 5,000 per number" to take a number off the Do Not Originate Register. Five barred numbers is AED 25,000 to get back to where you were. Second and third offences under CR 57 rise to AED 150,000 on the most serious items, and where the same violation repeats within six months the authority may skip the fine ladder and suspend the activity for 7 to 90 days, or cancel the licence (CR 57, Art 3). An individual who markets from a number in their own name pays AED 5,000 and every number in that name is cut until it is paid. Enforcement is not theoretical: TDRA, as of June 2026, reports 3,301 violations, AED 19.19 million in fines and 9,433 numbers disconnected (Khaleej Times). Source for the schedule: Cabinet Resolution 57 of 2024.
A call made at the request of the consumer sits outside the definition of telemarketing in Cabinet Resolution 56, Article 1. So a floor that only calls back people who filled in a form has described a lawful model. The question a regulator asks is a different one: prove it. Which number was called, from which registered number, at what time, at whose request, with what recording. A floor dialling from personal SIMs with no register cannot answer that, and the burden does not move.
e&'s wording: telemarketers are prohibited from calling registry numbers even from a personal number. A registered company number is the only kind that can carry the answer.
e&'s one-word answer to a UAE business whose calling team sits outside the country. The rules follow the licence, not the desk.
Art 1 includes messages through social media applications. This system governs voice. Messaging is a separate control we scope with you rather than pretend to cover.
The gap on most floors is evidential, not legal. That is what the register and the recording are for. Source: e& Do Not Call Registry, FAQ section.
e&'s page carries one sentence that decides the design: "For fixed voice services and SMB bundles, black points are assigned against the pilot number." Put every agent behind one company landline and every complaint lands on the same counter. Five points on that number and the whole floor loses dial tone together.
Every extension presents the same number. One barred identity, and everyone waits while someone works out how to get it back. A floor we met in Business Bay in August 2026 had taken two violations on one agent's personal number: outgoing calls barred on every number under his Emirates ID, plus AED 5,000, with the 15-day window to contest already closed by the time anyone read the notice.
A complaint attaches to one agent's number and the rest are untouched. Before that, the registry check means a call that would earn the point is never placed. When a number is barred, the AED 5,000 release becomes a budget line rather than a surprise, and the floor does not stop while it is handled.
Be precise about what this buys. One number per agent contains a barring to one agent. It does not contain the licence total: e& counts the 25 against the trade licence. The only control on that line is not earning points, which is why the screening sits in front of the dial and not in a report afterwards.
In the UAE, voice that touches the public phone network is a licensed activity reserved to e& and du under TDRA's VoIP Regulatory Policy v2.0. A foreign cloud PBX, or a calling app over a VPN, is an unlicensed service, and paragraph 3.2 of that policy lets a licensee block it at its own discretion: no notice, no regulator in the loop, nobody to appeal to. That is why "the line just dropped" is a Dubai experience rather than a network fault.
Every call travels to a server in Europe and back before it reaches the other party: about 120 ms round trip from Dubai to Frankfurt before codecs and jitter buffers add their share. Blockable at the operator's discretion, and the number is not on your licence.
The call starts on a du or e& trunk in your name, so there is nothing to block. Voice stays in the country; the round trip abroad never happens. Agents connect by softphone from the office, from home or from abroad over their own internet connection, and the recipient sees your licence name on the screen, which is what gets a call answered.
Sources: TDRA on VoIP services and the VoIP Regulatory Policy; ITU-T G.114, which treats 150 ms one-way delay as the limit most conversations tolerate; Dubai to Frankfurt round-trip measurements. Call quality from an agent abroad depends on that agent's internet connection; the UAE leg is fixed.
The system is a standard open-source PBX, fully documented, so any competent engineer can take it over. Nothing about it depends on us being available.
| Violation | Article | First offence | Handled by |
|---|---|---|---|
| Calling a Do Not Call Registry number | 4(5) | 50,000 | Blocked at dial |
| Calling from an unregistered number | 4(3), 4(13) | 25,000 | The migration itself |
| Calling outside 09:00 to 18:00 | 5(3) | 10,000 | Enforced window |
| Calling back after a refusal | 5(4) | 10,000 | Frequency governor |
| More than 1 a day or 2 a week unanswered | 5(5) | 10,000 | Frequency governor |
| No call register | 4(6) | 10,000 | Generated automatically |
| No recording, or no announcement | 4(7) | 10,000 | Automatic |
| Pressure, deception, untrained staff | 5(1), 5(2), 4(2) | 10,000+ | Script and training |
| No prior approval to telemarket | 4(1) | 75,000 | Your filing with your licensing authority |
We will not tell you a phone system makes fines impossible. It removes every violation that comes from the dialling itself. What is left is what your agents say, which is what the recordings and the script are for. The one item the system cannot touch is the largest: the approval has to be filed by you, with DET for a Dubai mainland company. We prepare the pack. If you already hold it, that row does not apply to you.
One basis, stated: du published list rates, VAT included, no internet line, since you have one, and no call minutes, which we price from your bills rather than estimate. Two floor sizes from the open model, which you can set to your own seat count.
Build, activation, hardware and twelve months of running. Then running only: the trunk and the support line.
Channels sized one per seat, because on an outbound floor everyone dials after the morning briefing. Seats scale by adding numbers to the trunk.
We never sit between you and the carrier, and we do not resell telecom. Every figure above comes from the open cost model, where you can move the seat slider and see each carrier price linked to its source.
| Route, 20 seats | Year 1 | Year 2+ | 3 years | Pre-dial screening |
|---|---|---|---|---|
| This build | 70,770 | 28,476 | 127,722 | Built in, unmetered |
| Cloud platform, seats only | 56,385 | 51,660 | 159,705 | Not included |
| Cloud platform, outbound configuration | 128,079 | 123,354 | 374,787 | Metered by call volume |
| Carrier hosted voice, 20 user lines | 29,295 | 29,295 | 87,885 | None |
| 20 business SIMs at carrier list price | 27,720 | 27,720 | 83,160 | None |
| Carry on as today | 0 | 0 | up to 160,000 per call | None |
One fine > one year.
A single first offence for calling without approval is AED 75,000. The complete system at 20 seats, hardware included, is AED 70,770 in year one.
All figures VAT included, AED, 20 seats, three years, with the trunk in every row because no platform can originate your calls without one. The cloud rows are shown twice on purpose. The first is the platform's published seat price with its trunk line and setup (CallGear: AED 185 a user, AED 4,500 setup, AED 400 trunk). The second adds what an outbound floor needs: a separate outbound module at AED 3,690 a month and registry screening billed by call volume from AED 500 to AED 3,000 a month, assuming up to 25,000 calls a month. Carrier hosted voice at e& Office Presence and du Hosted Voice list. SIMs at e&'s list price of AED 110 a line, not the five-month promotional rate, which would overstate that route by a fifth. Call minutes are in no row on purpose: they are bought from the same carrier at the same rate whichever route you take. The line that matters: on a cloud platform the screening that keeps you compliant is a subscription, and the meter runs with your call volume. Here it is built once and owned, and calling more costs nothing more. The two cheapest rows buy no screening, no register and no recording at all.
Stages 2 and 3 are deliberately not priced here. Connecting your CRM through its API, and putting dedicated numbers on each marketing channel, are both worth doing, and neither can be costed until we have seen the API and the channel list. Call tracking in particular has to be built on numbers registered to your licence, not on a vendor's pool. Stage 1 stands on its own.
Or write, with the list of numbers your floor uses if you want the free check: mr.kuznetsov.av@gmail.com
Alexander Kuznetsov · VLAN IT · The background to the 1 September change, with every source: vlanit.com/articles/dncr/