No — and since February 2026 there is a Dubai circular that says so in terms. Here is the two-layer picture: what RERA and the DLD require of brokerages, what federal telemarketing law adds on top, and what you are still allowed to do.
No. DLD circular 02-2026, dated 26 February 2026 and addressed to real estate brokerage offices, absolutely prohibits obtaining owner or investor data by unlawful means and contacting them directly — by phone call, text message or any other channel — for marketing purposes. The stated consequences are a fifty-thousand-dirham fine, three months' suspension from practising, and permanent striking off the broker's registration for repeat violations, issued against both the office and the individual broker. There is a narrow exception for existing clients with documented prior dealings. Federal telemarketing law applies on top of all of this, not instead of it.
Written and maintained by the Lumaa team in Dubai · Last updated · Sources
Dubai brokers have asked this question for years and mostly got answers assembled from federal law plus folklore. In February 2026 the Dubai Land Department published an instrument aimed squarely at the practice.
It appears on DLD's own Rules & Regulations index, filed under License Circulars, as "Regulations Governing Communication with Property Owners and the Prohibition of Cold Callings". The index lists it under 27 February 2026; the document itself is dated 26 February 2026 and carries circular number 02-2026, reference DLD/OUT/2026/0001641. Where they disagree, we cite the document.
The circular is addressed to real estate brokerage offices. Its operative prohibition uses the emphatic Arabic construction yuḥẓaru ḥaẓran bāttan — absolutely prohibited — and covers two things together: obtaining owner or investor data from any source by unlawful means, and contacting those owners directly by telephone call, text message and other channels for marketing purposes.
It provides an exception for existing clients: where the office has prior documented dealings with the person, conditional on maintaining an approved record evidencing the contractual relationship and the prior transaction, to be produced on demand by the Agency. On a complaint or report from an owner or investor, a violation is issued against both the brokerage office and the individual broker.
On penalties, the document contains the figure 50,000 written out as fifty thousand dirhams, a provision for suspension from practising the activity for three months, and a repeat-violation provision for permanently striking off the broker's registration. It is signed by Ali Abdullah Al Ali, Senior Director of the Real Estate Control Department.
The reason a Dubai brokerage can be penalised twice for one call is that two regimes govern it, and the federal instrument says so explicitly. Article 9 of Cabinet Resolution No. 56 of 2024 distributes supervision: the Ministry undertakes general supervision, the Central Bank covers banks, financial institutions and insurance, the Securities and Commodities Authority covers securities, and then clause 4 provides that "the Competent Local Authorities shall be competent, in accordance with the distribution of competencies at the level of each Emirate, in everything related to Phone Calls for marketing products or services in the State" other than those carve-outs. In Dubai, for real estate, that local authority is the DLD and its regulatory arm RERA.
| Federal layer — TDRA / Ministry | Dubai layer — DLD / RERA | |
|---|---|---|
| Instrument | Cabinet Resolutions 56 & 57 of 2024 | DLD circular 02-2026; Bylaw 85 of 2006; RERA Practice Guide |
| Who it binds | Every UAE-licensed company, free zones included | Real estate brokerage offices and registered brokers |
| Cold calling owners | Marketing calls permitted subject to approval, hours, DNCR and recording | Absolutely prohibited, except documented existing clients |
| Calling hours | 9:00–18:00 for marketing calls | — |
| Number used | Must be registered to the company | Mandatory use of numbers in the brokers registry (DLD/OUT/2023/0002269) |
| Money penalty | AED 10,000–150,000 depending on violation and repeat | Fifty thousand dirhams |
| Non-money penalty | Warning; 7–90 day suspension of activity; licence cancellation; number disconnection | Three-month suspension from practising; permanent striking off for repeats |
| Who gets penalised | The company (Table 1) or the individual (Table 2) | Both the office and the individual broker |
Satisfying one layer does not satisfy the other. A brokerage can run a campaign that is impeccable under Resolution 56 — approved, inside the calling window, DNCR-screened, recorded with notice, from a registered company number — and still be in breach of circular 02-2026 because the people being called are property owners who never asked to hear from it.
The 2026 circular did not come from nowhere. On 29 April 2022, RERA announced that it had suspended nine real estate brokers for three months and fined their brokerage office AED 50,000 for cold calling and direct telemarketing.
Two details are usually lost in retelling and both matter. The fine fell on the office; the suspension fell on the nine individual brokers — not, as it is often paraphrased, "a broker was fined AED 50,000". And the same release states the standing exposure in general terms: a fine of AED 50,000 and/or suspension of the broker's card for no less than three months. That is the sentence to quote at anyone who treats the rule as theoretical.
Two further Dubai instruments bear directly on outbound calling and are routinely missed.
The green list. The Real Estate Brokerage Practice Guide (second edition, November 2024) states that "brokers are not allowed to contact owners not registered as part of the green list, and if a broker should contact anyone not on the green list, a violation will be issued and their operations will be suspended in the event of a complaint or a report against them by an investor or a client." Note the trigger: a complaint or report by an investor or client.
Registered numbers. DLD's circular on the mandatory use of phone numbers registered in the brokers registry, reference DLD/OUT/2023/0002269 and indexed 11 April 2023, is the Dubai mirror of the federal registered-number requirement. In practice this is the rule that ends agents working leads from personal mobiles — and the personal-mobile exposure at federal level is the harsher of the two schedules, starting at AED 5,000 plus disconnection of every fixed and mobile number registered to that person until the fine is paid.
Beyond the cold-calling circular, Bylaw 85 of 2006 gives RERA an independent ladder against a broker: notice, warning, suspension of activities for up to six months, and blacklisting, with registration cancelled for a gross violation, a breach of the code of professional ethics, or the accumulation of three black points.
This is the question every Dubai brokerage actually wants settled. A buyer submits an enquiry on your Bayut, Property Finder or Dubizzle listing. Can you call them?
No UAE instrument answers it. We looked for one: there is no DLD, RERA or TDRA text addressing whether consent transfers from a listing portal to a brokerage. Any source that states a clean answer is inferring one.
What the federal text does give you is the two questions it turns on:
A genuine, unprompted enquiry on your own listing sits far closer to "at the request of the consumer" than a purchased list does, and the cold-calling circular is aimed at contacting owners whose data was obtained by unlawful means — a different fact pattern from returning a buyer's enquiry. That is a defensible reading, not a ruling. Get advice on your actual lead sources before you scale anything, and keep evidence of where each lead came from.
Advertising permits and calling are separate regimes and holding one does not help you with the other. The permit categories published on DLD's own real estate advertising permit e-service run to fourteen types covering channels such as SMS, property portals, print, outdoor, exhibitions, open days and project launch events. Telephone calls are not among them.
One related point often overstated: Bylaw 85 of 2006 requires that the broker's name and registration number appear "in all correspondence and reports issued by the Real Estate Broker". That is correspondence and reports — the frequently repeated claim that the ORN and BRN must appear on every advertisement does not come from that article.
The rules are technology-neutral, which cuts both ways. An AI voice agent cannot do anything a human broker is prohibited from doing: you cannot use AI to cold call owners, and Resolution 57 adds a specific row for using automatic calling in breach of the telemarketing rules, at AED 10,000 rising to AED 50,000 for a third offence.
What is left is substantial and entirely lawful: responding to enquiries the consumer initiated, at speed and at volume; contacting existing clients inside the documented-relationship exception; answering inbound calls, which are not telemarketing at all; and handling the reminder, confirmation and follow-up traffic that is service rather than marketing. Lumaa is built to run inside those constraints — calls from your own registered agency number, inside the calling window, scripts approved before anything goes live, every call recorded with notice.
For the federal picture in full, including the fines tables and what changed on 1 September 2026, see our UAE AI calling rules guide.
This page summarises published regulations and is not legal advice. Regulations change and enforcement practice varies; verify against the primary documents linked above and take advice on your own circumstances. Where a source was ambiguous or unavailable in English we have said so in the text rather than smoothing it over.