> ## Documentation Index > Fetch the complete documentation index at: https://docs.botbrains.io/llms.txt > Use this file to discover all available pages before exploring further. # AI Cold Calling Laws in Ireland > Is AI cold calling legal in Ireland? Consent rules for automated and mobile calls under S.I. 336/2011, the NDD opt-out register, recording, and AI disclosure. export const reviewed_0 = "October 2026" In Ireland, an AI agent may only make marketing calls to individuals, sole traders, and any mobile number when the person agreed beforehand. You may make automated calls to company landlines unless the company objected or its number is on the National Directory Database (NDD) opt-out register. The rules sit in Regulation 13 of [S.I. No. 336 of 2011](https://www.irishstatutebook.ie/eli/2011/si/336/made/en/print), the Privacy and Electronic Communications Regulations. The Data Protection Commission (DPC) enforces them through criminal prosecutions. This page summarizes the law as of {reviewed_0} to help you plan AI phone calls. It isn't legal advice. Laws and how regulators apply them change, so check your use case with a lawyer before you start a campaign. ## At a glance | Call | To consumers (B2C) | To businesses (B2B) | | - | - | - | | Inbound service call | Allowed. Disclose the AI and the recording. | Allowed. Disclose the AI and the recording. | | Outbound service call | Allowed | Allowed | | Marketing callback the person asked for | Allowed | Allowed | | Marketing call by an AI agent to existing customers | Consent required | Company landlines: allowed unless they objected.
Mobiles and sole traders: consent required. | | Cold marketing call by an AI agent | Consent required | Company landlines: allowed unless registered or the company objected.
Mobiles and sole traders: consent required. | | Marketing call by a human to existing customers | Landlines: allowed unless they objected.
Mobiles: consent required. | Landlines: allowed unless they objected.
Mobiles: consent required. | | Cold marketing call by a human | Landlines: allowed unless registered.
Mobiles: consent required. | Landlines: allowed unless registered.
Mobiles: consent required. | ## Is AI cold calling legal in Ireland? Regulation 13(1) bans direct marketing by "an automated calling machine" to "a subscriber or user who is a natural person" without their consent. Regulation 2 defines an automated calling machine as a system that "operates to make calls without human intervention." **Who's covered.** Individuals and sole traders need to consent. Employees might too, because a "user" is any natural person using the line "for private or business purposes." For companies, Regulation 13(3) is opt-out: you may call unless the company objected or its number is on the NDD. Regulation 13(6) overrides both for mobiles. Any marketing call to a mobile, by a human or a machine, needs consent, even in B2B. **Does an AI agent count?** No Irish court or regulator has ruled on conversational AI agents. An AI agent that holds the conversation fits "without human intervention," so treat it as automated. A human who only presses **Dial** or listens in doesn't change that. Only a human who conducts the conversation makes it a live call. **Calling from abroad.** It's unclear whether the rules bind callers outside Ireland, and [McCann FitzGerald](https://mccannfitzgerald.com/uploads/Direct_marketing_QAndA_Ireland.pdf) advises assuming they do. ## Cold calls by a human Live marketing calls to landlines are opt-out under Regulation 13(5). You may call unless the person or business objected or the number is on the NDD. Mobiles need consent under Regulation 13(6). Give the caller's name and any company you call for (Regulation 13(10)(a)). ## Existing customers and callback requests The Regulations define an unsolicited call as one "not requested by the called party." A callback the person asked for isn't unsolicited, so the consent and opt-out rules don't apply. Keep to what they asked about, and still give your name and company (Regulation 13(10)). There's no soft opt-in for calls, since Regulation 13(11) covers email and text messages only. The DPC's [NDD FAQ](https://www.dataprotection.ie/en/organisations/rules-electronic-and-direct-marketing/ndd-faqs) lets you rely on "consent arising from an existing relationship" despite an NDD opt-out. Its [consent FAQ](https://www.dataprotection.ie/sites/default/files/uploads/2026-05/FAQ_Consent_Electronic_Direct_Marketing_April2020.pdf) demands GDPR-standard consent, so get explicit consent for AI calls and mobiles. ## Do-not-call register: National Directory Database (NDD) | | | | - | - | | Name | NDD opt-out register, the [do-not-call register](https://www.comreg.ie/advice-information/directory-enquiry-services/). | | Run by | [PXS B.V.](https://www.pxs.com/ndd) for ComReg (Decision D19/24), for three years from July 1, 2024. | | Covers | Residential and business numbers. Ex-directory numbers count as opted out. | | Access | License the data from PXS for a cost-based fee that ComReg approves (Regulation 14(6) and (7)). | | Screening | A new opt-out binds you 28 days after the NDD records it (Regulation 13(9)). Screen at least every 28 days. | The register matters for live calls to landlines and AI calls to company landlines. Per ComReg, people who agreed to your calls stay reachable even on the register. An objection always wins. ## Consent for AI calls | Requirement | Detail | | - | - | | Standard | Voluntary, specific, informed, and unambiguous, by a statement or clear affirmative action ([GDPR Art. 4(11)](https://gdpr-info.eu/art-4-gdpr/), [Art. 7](https://gdpr-info.eu/art-7-gdpr/)). Pre-ticked boxes don't count. | | Scope | Name AI or automated calls, the purpose, and every company that will call. | | Proof | You must prove the person "unambiguously consented" (Regulation 13(14)). Keep it while you call. | | Withdrawal | As easy as giving it. Stop calling at once. | | Purchased lists | Consent must be "current, valid and legitimately sourced," and you stay accountable for vendors ([DPC](https://www.dataprotection.ie/en/news-media/latest-news/data-protection-commission-welcomes-outcome-prosecution-marketing-offences-1)). | | Partner calls | Name the company you call for (Regulation 13(10)). The consent must cover it. | Before you start, read [Before you start outbound campaigns](/concepts/phone/countries#before-you-start-outbound-campaigns). ## Tell callers they're talking to an AI Since August 2, 2026, [Article 50 of the EU AI Act](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401689#art_50) requires that people know they're talking to an AI system, at the latest when the conversation starts. This applies to inbound and outbound calls, to consumers and to business contacts, and you can't count on the exception for obvious cases when your AI agent sounds human. The [default introduction](/concepts/phone#introductions) already says that your AI agent is an AI, so keep that statement first when you edit it. When you call a consumer to sell something, the [Consumer Rights Directive](https://eur-lex.europa.eu/eli/dir/2011/83/oj/eng) also requires you to name your company, anyone you call for, and the commercial purpose at the start. We found no Irish AI disclosure rule beyond the AI Act. These rules require you to identify yourself: | Rule | What to say | Applies to | | - | - | - | | Regulation 13(10) | Your name and any company you call for. Automated calls add the address and phone number of both. | All marketing calls | | [Consumer Rights Act 2022, s. 106(7)](https://www.irishstatutebook.ie/2022/en/act/pub/0037/sec0106.html) | Your identity, any company you call for, and the commercial purpose | Sales calls to consumers | | [Consumer Protection Code 2025, Reg. 113](https://www.centralbank.ie/regulation/consumer-protection/consumer-protection-code/section-48-regulations/part-2-general-consumer-protection-requirements) | Name, firm, purpose, recording, then ask whether to continue | Regulated financial firms | Recommended introduction for outbound marketing calls. Replace the bracketed parts: ```text theme={null} Hello, this is {agent_name}, an AI agent calling for {project_name}, [business address], phone [callback number]. I'm calling about [purpose]. This call is recorded. Press the star key at any time to object to the recording. If you don't want more calls from us, just tell me and we won't call you again. ``` For inbound calls: ```text theme={null} Hello, this is {agent_name} from {project_name}. I'm an AI agent. This call is recorded. Press the star key at any time to object. How can I help you? ``` Edit the text under [Introductions](/concepts/phone#introductions). Use [guidance](/concepts/guidance) to handle requests to stop calling, and a [Unitool](/concepts/unitools) to write them to your CRM. ## Call recording **Criminal law.** You may record. Ireland needs the consent of only one party to the call, and your business is that party, because your AI agent calls or answers on your behalf. Section 98 of the Postal and Telecommunications Services Act 1983 excludes recording with the consent of the sender or the intended recipient ([section 13 of the 1993 Act](https://www.irishstatutebook.ie/eli/1993/act/10/enacted/en/print)). Criminal law doesn't require the caller's consent. **Data protection.** You need a lawful basis ([GDPR Art. 6](https://gdpr-info.eu/art-6-gdpr/)) and a notice ([Art. 13](https://gdpr-info.eu/art-13-gdpr/)), not necessarily consent. Legitimate interest can work if you give notice and a way to object ([Art. 21](https://gdpr-info.eu/art-21-gdpr/)). The star key stops the recording and discards it, but the transcript stays. Financial firms must announce recording at the outset (Consumer Protection Code 2025, Reg. 63). **Voice as biometric data.** A voice only counts as biometric data when you process it to identify someone ([Art. 4(14)](https://gdpr-info.eu/art-4-gdpr/), [Art. 9](https://gdpr-info.eu/art-9-gdpr/)). Recording for quality doesn't. botBrains stores recordings, transcripts, and call data in the EU. ## Caller ID and calling hours **Caller ID.** Automated marketing calls must state your phone number (Regulation 13(10)(b)), and people can reject calls with a hidden number (Regulation 8(1)(c)). Since October 2024, operators block calls from abroad showing Irish numbers ([ComReg 25/87](https://www.comreg.ie/publication-download/nuisance-communications-scam-call-interventions-update-december-2025), [ComReg 22/114](https://comreg.ie/publication-download/nuisance-communications-fixed-cli-blocking-intervention-arrangements-for-international-operations)). The caller sees your botBrains number, so ask botBrains for an Irish number and test delivery first. **Calling hours.** We found no general statutory hours. Financial firms may call only from 9 AM to 9 PM, Monday to Saturday, excluding public holidays (Consumer Protection Code 2025, Reg. 112). Energy suppliers may call 9 AM to 9 PM on weekdays and 9 AM to 7 PM on Saturdays, but not on Sundays, public holidays, or Christmas Eve ([CRU](https://www.cru.ie/en-ie/consumer-information/your-rights/energy/)). botBrains doesn't enforce calling hours or screen numbers, so you schedule calls yourself. On voicemail, the agent hangs up without a message. ## Sector rules | Sector | Rule | | - | - | | Financial services | Depends. You may make unsolicited calls only to existing customers in listed cases, or to prospects with written consent from the last 12 months, a directory listing, or a referral. The [Consumer Protection Code 2025](https://www.centralbank.ie/regulation/consumer-protection/consumer-protection-code/section-48-regulations/part-2-general-consumer-protection-requirements), Regulations 108 to 114, sets these rules and applies since March 24, 2026. "Consumer" includes companies with turnover up to €5 million. | | Energy | Give your name, contact details, and company. Log opt-outs and remove the person from your marketing database ([CRU](https://www.cru.ie/en-ie/consumer-information/your-rights/energy/)). | | Phone contracts with consumers | Confirm the contract on a durable medium ([Consumer Rights Act 2022, s. 109](https://www.irishstatutebook.ie/eli/2022/act/37/enacted/en/print)). | | Debt collection and service calls | Stop calling consumers who ask you to, unless the law permits the contact to enforce a contract ([Consumer Protection Act 2007, s. 55(3)(c)](https://revisedacts.lawreform.ie/eli/2007/act/19/revised/en/html)). | ## Fines and enforcement | Law | Regulator | Maximum | | - | - | - | | S.I. 336/2011, Reg. 13 | DPC | Class A fine (up to €5,000) on summary conviction. On indictment, €250,000 for a company or €50,000 for an individual. Each call is a separate offence (Reg. 13(13) and (15)). | | Consumer Rights Act 2022 | CCPC, ComReg, Central Bank | €60,000 or 18 months in prison on indictment (s. 142) | | GDPR | DPC | €20 million or 4% of worldwide turnover ([Art. 83](https://gdpr-info.eu/art-83-gdpr/)) | | EU AI Act, Art. 50 | National AI Act authorities | €15 million or 3% of worldwide turnover ([Art. 99](https://artificialintelligenceact.eu/article/99/)) | The DPC warned each company below before it prosecuted. In October 2024, Google Ireland pleaded guilty to two charges of marketing calls after an opt-out. It paid €1,500 to charity plus costs instead of a conviction ([DPC](https://dataprotection.ie/en/news-media/latest-news/data-protection-commission-welcomes-outcome-latest-round-prosecutions-marketing-offences)). In September 2026, Brown Thomas pleaded guilty to marketing emails without valid consent or a working opt-out ([DPC](https://www.dataprotection.ie/en/news-media/latest-news/data-protection-commission-welcomes-outcome-prosecution-marketing-offences-1)). We found no Irish case on AI or robocalls. A draft Regulation of Artificial Intelligence Bill 2026, published as a general scheme in February 2026, spreads AI Act enforcement across Irish regulators ([Matheson](https://www.matheson.com/insights/irish-government-publishes-general-scheme-of-ai-bill/)). ## Sources * [Privacy and Electronic Communications Regulations 2011, S.I. No. 336 of 2011](https://www.irishstatutebook.ie/eli/2011/si/336/made/en/print), Regulations 2, 8, 13, and 14 * [Consumer Rights Act 2022](https://www.irishstatutebook.ie/eli/2022/act/37/enacted/en/print), sections 106, 109, and 142 * [Interception of Postal Packets and Telecommunications Messages (Regulation) Act 1993](https://www.irishstatutebook.ie/eli/1993/act/10/enacted/en/print), section 13 * [Consumer Protection Act 2007 (revised)](https://revisedacts.lawreform.ie/eli/2007/act/19/revised/en/html), section 55 * [Central Bank Consumer Protection Code 2025, Part 2](https://www.centralbank.ie/regulation/consumer-protection/consumer-protection-code/section-48-regulations/part-2-general-consumer-protection-requirements), Regulations 63 and 108 to 114 * [DPC: NDD FAQ](https://www.dataprotection.ie/en/organisations/rules-electronic-and-direct-marketing/ndd-faqs) and [FAQ on consent for electronic direct marketing](https://www.dataprotection.ie/sites/default/files/uploads/2026-05/FAQ_Consent_Electronic_Direct_Marketing_April2020.pdf) * [ComReg: directory enquiry services and the NDD](https://www.comreg.ie/advice-information/directory-enquiry-services/), [ComReg 22/114](https://comreg.ie/publication-download/nuisance-communications-fixed-cli-blocking-intervention-arrangements-for-international-operations), [ComReg 25/87](https://www.comreg.ie/publication-download/nuisance-communications-scam-call-interventions-update-december-2025) * [PXS: National Directory Database](https://www.pxs.com/ndd) * [Commission for Regulation of Utilities: your rights as an energy customer](https://www.cru.ie/en-ie/consumer-information/your-rights/energy/) * [McCann FitzGerald: Direct marketing Q\&A Ireland](https://mccannfitzgerald.com/uploads/Direct_marketing_QAndA_Ireland.pdf), law stated as at December 31, 2019 * GDPR [Art. 4](https://gdpr-info.eu/art-4-gdpr/), [6](https://gdpr-info.eu/art-6-gdpr/), [7](https://gdpr-info.eu/art-7-gdpr/), [9](https://gdpr-info.eu/art-9-gdpr/), [13](https://gdpr-info.eu/art-13-gdpr/), [21](https://gdpr-info.eu/art-21-gdpr/), [83](https://gdpr-info.eu/art-83-gdpr/); EU AI Act [Art. 50](https://artificialintelligenceact.eu/article/50/) and [Art. 99](https://artificialintelligenceact.eu/article/99/) ## Next steps Set up your phone line, introductions, and outbound calls. Compare consent rules for AI calls across the EU, the UK, and the US. This documentation is built and hosted on [Mintlify](https://mintlify.com), a developer documentation platform.