Skip to main content
In Slovenia, an AI agent may only make marketing calls to consumers and sole traders who agreed beforehand. The rule is Article 226 of the Electronic Communications Act (Zakon o elektronskih komunikacijah, ZEKom-2). It only protects phone subscribers who are natural persons, so AI calls to companies need no prior consent under ZEKom-2. AKOS, the communications regulator, enforces it and also supervises AI disclosure under the EU AI Act.
This page summarizes the law as of October 2026 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

Only with prior consent, unless you call a company. ZEKom-2 Art. 226(1) reads:
“Uporaba samodejnih klicnih in komunikacijskih sistemov za opravljanje klicev na naročnikovo telefonsko številko brez človekovega posredovanja (npr. klicni avtomati, SMS, MMS), telefaksov ali elektronske pošte za namene neposrednega trženja je dovoljena samo na podlagi naročnikovega ali uporabnikovega predhodnega soglasja.”
In English: you may only use automatic calling systems that call a subscriber’s number without human intervention, fax, or email for direct marketing with the subscriber’s or user’s prior consent. Article 226(4) limits this rule to subscribers who are natural persons. It protects consumers and sole traders (s.p.), but not companies. What counts is who holds the phone contract, so an employee’s mobile on a company contract falls outside it. Does an AI agent count as automated? Probably yes. Neither AKOS nor the Information Commissioner (IP) has ruled on conversational AI. An AI agent places the call and runs the conversation “brez človekovega posredovanja” (without human intervention), so treat it as automated. A colleague who can take over doesn’t change this. Calls to companies still need care. The GDPR covers the contact person’s name and number. Legitimate interest (GDPR Art. 6(1)(f)) usually works, but an objection ends all marketing calls (Art. 21(3)). Companies can set a TIS ban too, so respect it.

​
Cold calls by a human

ZEKom-2 Art. 226(3) covers all other marketing calls, including calls by a human. They’re “dovoljena le s soglasjem naročnika ali uporabnika” (only allowed with the subscriber’s or user’s consent). Refusing must be free, and you must respect directory bans (Art. 217(3) to (5)). The IP takes a softer line. In a 2022 opinion on the previous law, which had almost the same wording, it said you may call a number in the public directory unless it carries a ban. Unlisted numbers need real consent. AKOS, which enforces Art. 226 (Art. 229), hasn’t published a view. The Consumer Protection Act (ZVPot-1) requires your company name and the commercial purpose at the start of a sales call (Art. 146(1)). Persistent calls to win new customers without consent are an aggressive practice (Art. 54(3)).

​
Existing customers and callback requests

Slovenia has no soft opt-in for calls. The existing-customer exception in Art. 226(2) covers email only. Collect consent for AI calls in your contract or customer account, as a separate checkbox. A callback request is consent for that call. Make your form say that an AI agent calls back.

​
Do-not-call register: Telefonski imenik Slovenije (TIS)

Slovenia has no separate do-not-call list. Subscribers instead mark a ban on commercial calls, research calls, or both in the public phone directory (ZEKom-2 Art. 217(3)). Check TIS even when you have consent. ZEKom-2 doesn’t say which wins when a person consented and later set a ban, so treat a newer ban as a withdrawal. ZEKom-2 uses the GDPR meaning of consent (Art. 3(75)), and the Data Protection Act (ZVOP-2) adds no rules for marketing calls. Consent must be voluntary, specific, informed, and unambiguous, and the person can withdraw it at any time (GDPR Art. 4(11) and Art. 7). You carry the burden of proof. For what botBrains asks before outbound campaigns, see before you start outbound campaigns.

​
Tell callers they’re talking to an AI

Since August 2, 2026, Article 50 of the EU AI Act 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 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 also requires you to name your company, anyone you call for, and the commercial purpose at the start. AKOS supervises Article 50 in Slovenia (ZIUDHPUI Art. 10(5)). Its August 2026 guidance counts AI agents as interactive AI systems. It asks for a clear spoken notice, a truthful answer when someone asks, and a repeated notice in long calls. Vague lines such as “Sem digitalni pomočnik” (“I’m a digital helper”) aren’t enough. Slovenia has no AI-specific calling rule. ZVPot-1 requires your company name and the commercial purpose at the start of a sales call (Art. 146(1)), plus your registered address for financial services (Art. 150(1)). You must deal with consumers in Slovenian, and in Italian or Hungarian where those national communities live (Art. 7(1)). Recommended introduction for outbound marketing calls in Slovenian:
For inbound calls:
Replace [rok hrambe] with your retention period, for example “šest mesecev” (six months). Edit the introduction per project, see introductions. To honor a request to stop calls, add guidance for objections and a Unitool that writes the objection to your CRM.

​
Call recording

ZEKom-2 Art. 214(7) allows recording in lawful business practice as evidence of a commercial transaction or other business communication. You must tell the other side in advance about the recording, its purpose, and how long you keep it, on the call itself (Art. 214(8)). Delete the recording once the period for legally challenging the transaction ends. The IP reads this narrowly. Its March 2024 opinion limits it to calls that conclude, change, or end a business relationship. Recording only for quality or training needs the caller’s prior consent (Art. 214(6)). A1 Slovenia, for example, records sales calls with a notice and asks service callers to press 1 to consent. The Criminal Code (KZ-1) Art. 137 punishes recording a conversation not meant for you, or a confidential statement to misuse it, with a fine or up to one year in prison. An announced business recording doesn’t fall under it. Under the GDPR, you need a lawful basis and must tell the caller about the recording (Art. 6 and Art. 13). A recording isn’t biometric data unless you process the voice to identify someone (Art. 4(14) and Art. 9). In botBrains, pressing the star key stops the recording and discards it. The transcript stays, and Art. 214 covers stored call content too, so mention it in your notice. The star key is an objection, not consent, so check with your lawyer before you record calls that don’t concern a contract. botBrains stores recordings, transcripts, and call data in the EU.

​
Caller ID and calling hours

ZEKom-2 sets no duty to show a number on marketing calls and no special prefix. Subscribers can reject calls with a hidden number (Art. 222(4)), so show yours. Callers see your botBrains number, and botBrains provisions Slovenian numbers on request. We found no legal calling hours for phone marketing. We recommend calling on working days during business hours and never again after a refusal. botBrains starts calls one at a time with Dial or through the API. It doesn’t schedule campaigns, enforce calling hours, or screen TIS, so you do that yourself.

​
Sector rules

​
Fines and enforcement

In 2025, AKOS ran 97 supervisory and 35 misdemeanor procedures in electronic communications. Its main topics included call confidentiality (Art. 214) and unsolicited communications (Art. 226), according to its 2025 annual report. We found no published case on AI or robocall marketing. ZEKom-2 was last amended in 2025, without changes to Art. 226. A draft amendment to ZVPot-1 entered government coordination in June 2026 (IUS-INFO). It covers repairs, green claims, and distance financial services, not marketing calls.

​
Sources

​
Next steps

Phone integration

Set up your phone line, introductions, and outbound calls.

Calling laws by country

Compare consent rules for AI calls across the EU, the UK, and the US.