This week the news was all about kids going back to school. A very important event got overlooked, and it touches every business owner and CEO in this country.

What e& published

Reporting a marketing call is nothing new. The registry has existed since September 2022, and anyone can text the caller’s number to 2211 (TDRA) or call 101 for personal numbers and 800 5800 for business numbers (e&). Putting your own number on the registry is a different step: text DNCR to 1012. What changed on 1 September is what happens next.

1. Validated reports become black points on the number that placed the call. On fixed-line and business bundles they land on the pilot number, the main number of the bundle that the other numbers and channels hang off, so every agent’s calls feed one counter. Complaints are checked before anything happens: of 92,748 numbers reported by the public, 9,433 were cut.
2. Five black points: the number goes on the Do Not Originate Register. Outgoing calls barred. AED 5,000 per number to take it off the register.
3. Twenty-five black points on the trade licence: no telecom services for any active number, no new numbers anywhere in the UAE. e& publishes no way to pay that off.

Points per violation are not published, on either language version, so no one can say when a company crosses five or twenty-five. The phrase “black points” has been in UAE call-centre vendor adverts since February 2026; the register, the thresholds, the AED 5,000 and the licence lock are the new part.

du’s registry page still carries its 2023 wording: violators “will have their telecommunications services interrupted”. The TDRA newsroom has no announcement. Khaleej Times’ round-up of what changes in September, published 29 August, lists nine items; this is not one of them. No law firm has issued an alert. Everything on this page about black points is e&’s statement of e&’s policy.

The fines are from 2024

Cabinet Resolution 56 of 2024 sets the conduct rules; Cabinet Resolution 57 of 2024 sets the fines. Both in force since 27 August 2024, unamended. They cover every company licensed in the UAE, free zones included (Art 3(1)), financial and non-financial.

AED, Cabinet Resolution 57 of 2024. An individual who markets from a number in their own name pays AED 5,000 and every fixed and mobile number in their name is cut off until it is paid. The calling window has no weekend, holiday or Ramadan exception.

Approval comes from the authority that licenses the business (Art 1, Art 9(4)). For Dubai mainland that is DET, not TDRA. DET’s consumer protection arm fined 159 companies AED 50,000 each in February 2025. TDRA’s own count as of June 2026: 3,301 violations against individuals, AED 19.19 million in fines, 9,433 numbers disconnected.

One agent, one call

A SIM in the agent’s own name, a number on the registry, 19:00, a company with no approval on file.

Two different AED 5,000 sit outside that table: the first-offence fine on an individual under Resolution 57, and the per-number fee to leave the Do Not Originate Register, which e& calls a regulatory fine and which the operator charges, not the authority. A company can owe both in the same week.

What compliant calling costs

Ten seats on a ten-channel du trunk, one on-premise PBX with its hardware, monthly support, 5% VAT. du list prices. The same basis as the open cost model below.

AED. The internet line (AED 950 a month at du list) and call minutes are not in the table: you pay them on every route, so they cancel in a comparison. Add about AED 12,000 a year for the line if the office has none.

That table is one configuration: ten seats. If your floor is a different size, the open cost model runs the same arithmetic for any number of agents, sizes the trunk from du's published tiers, and puts the alternatives and the fine exposure beside it.

Not in the table: the DET approval fee (not published), legal counsel (no published rates), and for real estate the RERA advertising permit, AED 1,000, or 5,000 for a launch event, plus AED 20. The real cost of compliance is higher than the table.

A fine is a number you can pay. A trade licence that cannot buy telecom services is a sales floor with no dial tone.

What works and what does not

Works

• Numbers from e& or du, registered under your commercial licence, not under an employee’s name (Art 4(3), 4(13)).
• Origination through e& or du, on your own trunk, under your own licence.
• Prior approval from your licensing authority before the first marketing call. DET for Dubai mainland.
• A registry scrub at dial time that an agent cannot override.
• The calling window, the redial caps (once a day, twice a week on no answer) and the opening disclosure enforced by the dialer, not by training.
• Separate pilot numbers per team, so one agent’s black points do not bar the whole company.

Does not

• Personal SIMs. Banned for marketing calls (Art 3(2)), and the individual penalty cuts every number in the agent’s name.
• A foreign SIP carrier or a foreign caller ID from a UAE office. International bypass. Under TDRA’s VoIP policy the operator may block an unlicensed service at its own discretion, with no regulator in the loop.
• A CPaaS account. Twilio prohibits outbound voice from UAE numbers; Vonage, Telnyx, Plivo and Bandwidth sell UAE toll-free only. Compliant local outbound is not a self-serve product.
• WhatsApp instead of calls. Marketing messages through social media applications are telemarketing by definition (Art 1). Same rules, same fines.