> ## 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 the United Kingdom > Is AI cold calling legal in the UK? PECR consent rules for automated B2B and B2C calls, TPS and CTPS screening, call recording, and AI disclosure duties. export const reviewed_0 = "October 2026" In the United Kingdom, an AI agent may only make marketing calls to people and businesses who agreed to automated calls from you beforehand. Regulation 19 of the [Privacy and Electronic Communications Regulations 2003 (PECR)](https://www.legislation.gov.uk/uksi/2003/2426/contents) sets this rule, and it covers companies as well as consumers. Marketing calls by a human stay opt-out. You screen them against the Telephone Preference Service (TPS) and the Corporate TPS (CTPS). Since February 2026, fines for breaking these rules can reach £17.5 million or 4% of worldwide turnover. 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 | AI agent: consent required. A request that names an AI agent call counts.
Human: allowed. The TPS rules don't apply to a call the person asked for. | AI agent: consent required. A request that names an AI agent call counts.
Human: allowed. The TPS and CTPS rules don't apply to a call the person asked for. | | Marketing call by an AI agent | Consent required, also from existing customers | Consent required, also from companies and existing customers | | Marketing call by a human | Allowed unless registered on the TPS. Existing customers keep this protection. | Allowed unless registered on the TPS or CTPS. Existing customers keep this protection. | ## Is AI cold calling legal in the United Kingdom? Only with consent. Regulation 19(1) bans direct marketing by "an automated calling or communication system" unless the person you call "previously notified the caller" that they consent (Regulation 19(2)). An automated calling system can start a sequence of calls on its own and plays sounds that aren't "live speech" (Regulation 19(4)). **Who's covered.** Regulation 19 protects every subscriber. That includes consumers, sole traders, partnerships, and companies. The B2B guidance of the [Information Commissioner's Office (ICO)](https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/business-to-business-marketing/) confirms that automated B2B calls need consent from the business. The consent must "specially cover automated calls from you." **Does an AI agent count?** No court or regulator has ruled on conversational AI agents. The ICO calls a live call one "where a live person is speaking" ([ICO](https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/guidance-on-direct-marketing-using-live-calls/what-are-live-direct-marketing-calls/)). In September 2025, it fined two energy firms for "avatar" calls, where agents played recorded clips that responded to the person's answers. The ICO treated these as automated calls ([ICO](https://ico.org.uk/about-the-ico/media-centre/news-and-blogs/2025/09/warning-over-robo-calls-as-energy-firms-fined-half-a-million-pounds-for-unlawful-marketing-calls)). An AI voice isn't live speech, so treat your AI agent as automated. **Human in the loop.** A human who presses **Dial** or listens in doesn't change this. Only a person who does the talking makes it a live call. ## Cold calls by a human Live marketing calls are opt-out under Regulation 21. You may call unless the number is on the TPS or CTPS, or the person or business told you not to call. Give your name, and an address or freephone number if asked (Regulation 24). Claims management and pension calls need consent even when a human calls (see [Sector rules](#sector-rules)). ## Existing customers and callback requests There's no soft opt-in for calls, since it only covers email and text messages. Existing customers keep their TPS protection for live calls, and AI calls need their consent. When the person asked you to call, the call counts as solicited, and the TPS rules don't apply to a human calling back ([ICO](https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/guidance-on-direct-marketing-using-live-calls/what-are-the-rules-on-live-direct-marketing-calls/)). Regulation 19 still requires consent for AI calls. A callback request counts if it says an AI agent will call you about that topic. ## Do-not-call register: Telephone Preference Service (TPS) and CTPS | | | | - | - | | Name | [Telephone Preference Service (TPS)](https://www.tpsonline.org.uk/) for individuals and sole traders, Corporate TPS (CTPS) for companies | | Run by | TPS Ltd, a subsidiary of the Data & Marketing Association (DMA), under contract from the regulator ([DMA](https://www.dma.org.uk/legal-and-public-affairs/preference-services-tps-and-mps)) | | Covers | Landlines and mobiles of individuals, sole traders, and companies. Companies register for the CTPS in writing (Regulation 26(1A)). | | Access | Organisations license the data files from TPS Ltd for an annual fee ([prices](https://corporate.tpsonline.org.uk/prices)). | | Screening | A registration takes effect 28 days after listing (Regulation 21(3)). Screen at least every 28 days, and screen against your own do-not-call list. | For B2B calls, screen against both registers, because sole traders and some partnerships use the TPS. The registers only matter for calls by a human. AI calls need consent anyway, and an objection always wins. ## Consent for AI calls | Requirement | Detail | | - | - | | Standard | Voluntary, specific, informed, and unambiguous, as in the UK GDPR (Regulation 2). No pre-ticked boxes. | | Scope | Name automated or AI calls. Consent for marketing or for live calls isn't enough ([ICO](https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/guide-to-pecr/electronic-and-telephone-marketing/telephone-marketing/)). | | Proof | Record who consented, when, and how. You carry the burden of proof ([UK GDPR Art. 7(1)](https://www.legislation.gov.uk/eur/2016/679/article/7)). | | Withdrawal | People can withdraw "for the time being." Add them to your suppression list instead of deleting them. | | Purchased lists | Generic consent for any third party isn't enough. The consent must name you and be recent enough to cover your calls ([ICO](https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/guide-to-pecr/electronic-and-telephone-marketing/using-marketing-lists/)). | | Partner calls | The company that instigates the calls and the company that makes them are both responsible. Name the company you call for. | 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 The EU AI Act doesn't apply to calls within the UK, and the UK has no AI statute. The May 2026 King's Speech included no AI bill ([Lewis Silkin](https://www.lewissilkin.com/en/insights/2026/05/13/kings-speech-2026-commercial-technology-and-regulatory-developments-102msjh)). If you call people in the EU, the AI Act applies to you even from the UK, because the AI agent's output reaches people in the EU ([Art. 2(1)(c)](https://artificialintelligenceact.eu/article/2/)). [Article 50](https://artificialintelligenceact.eu/article/50/) then requires AI disclosure from August 2, 2026. No UK rule names AI disclosure, but these rules make it the safe choice: | Rule | What it requires | Applies to | | - | - | - | | PECR, Regulation 24 | Your name, plus an address or freephone number | Automated marketing calls | | [Consumer Contracts Regulations 2013, reg. 15](https://www.legislation.gov.uk/uksi/2013/3134/regulation/15) | Your identity, any company you call for, and the commercial purpose, at the start | Sales calls to consumers | | [Digital Markets, Competition and Consumers (DMCC) Act 2024, s. 226 and s. 227](https://www.legislation.gov.uk/ukpga/2024/13/section/226) | No deceptive presentation. Make the commercial intent clear. | Calls to consumers | | UK GDPR transparency ([ICO AI guidance](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/artificial-intelligence/guidance-on-ai-and-data-protection/how-do-we-ensure-transparency-in-ai/)) | Tell people how you process their data | All calls with personal data | An AI agent that pretends to be human risks a misleading action under the DMCC Act. In the avatar cases, the ICO stressed that the calls made people think they were talking to real UK agents. We found no Ofcom rule on AI disclosure. 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}. I'm calling about [purpose]. You can reach us at [freephone number or postal address]. 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.** Interception is an offence under section 3 of the [Investigatory Powers Act 2016](https://www.legislation.gov.uk/ukpga/2016/25/section/4). It means making call content available to someone other than the sender or intended recipient (section 4). So recording a call you take part in usually isn't interception. Businesses may also record on their own systems for listed purposes, such as establishing facts or checking standards. They must make "all reasonable efforts" to tell users that they record calls ([Interception by Businesses Regulations 2018, regs. 3 and 4](https://www.legislation.gov.uk/uksi/2018/356/regulation/4)). **Data protection.** You need a lawful basis (UK GDPR Art. 6) and a notice at the start (Art. 13), not necessarily consent. Legitimate interests can work if you give notice and a way to object. The star key stops the recording and discards it, but the transcript stays. **Voice as biometric data.** A voice only becomes special category data when you use it to uniquely identify someone ([ICO](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/lawful-basis/biometric-data-guidance-biometric-recognition/key-data-protection-concepts/)). Recording for quality doesn't. botBrains stores recordings, transcripts, and call data in the EU. ## Caller ID and calling hours **Caller ID.** Every marketing call must show your number or a number where people can reach you (Regulations 19(2)(b) and 21(A1)). Since January 29, 2025, UK providers block calls from abroad that show UK landline numbers. Exceptions include UK customers whose calls run through cloud services abroad ([Comms Council UK](https://commscouncil.uk/press/ofcom-updated-cli-guidance-tackling-scam-calls/)). A [July 2026 Ofcom statement](https://www.ofcom.org.uk/phones-and-broadband/scam-calls-and-messages/consultation-tackling-scam-calls-from-abroad) extends this to UK mobile numbers. Calls from abroad that show one appear as withheld unless the provider can verify them. The caller sees your botBrains number, so ask botBrains for a UK number and test delivery first. **Calling hours.** We found no statutory calling hours. Firms regulated by the Financial Conduct Authority (FCA) must call only "at an appropriate time of the day." They must also state their name, firm, and purpose at the outset, and end the call when asked ([COBS 4.8.3R](https://www.handbook.fca.org.uk/handbook/COBS/4/8.html)). Ofcom can fine persistent misuse, such as silent or repeated calls ([Communications Act 2003, s. 128](https://www.legislation.gov.uk/ukpga/2003/21/section/128)). 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 | | - | - | | Claims management | Consent required for any marketing call, live or automated (Regulation 21A) | | Pensions | Banned unless an FCA-authorised firm or scheme trustee calls with consent or an existing client relationship (Regulation 21B) | | Financial services | Prohibited, except in narrow cases. FCA firms may cold call retail clients only in cases such as existing clients who expect calls ([COBS 4.8.2R](https://www.handbook.fca.org.uk/handbook/COBS/4/8.html)). A wider ban on cold calls for consumer financial products, consulted on in 2023, wasn't in force when we checked. | | Energy | Ofgem's Standard Licence Condition 25 requires accurate, fair, and professional telesales to domestic customers ([Ofgem](https://www.ofgem.gov.uk/publications/investigation-npower-and-its-compliance-standard-conditions-25-and-27-electricity-and-gas-supply-licences)). The ICO's 2025 avatar fines targeted energy and insulation leads. | | Phone contracts with consumers | Confirm the contract on a durable medium ([Consumer Contracts Regulations 2013, reg. 16](https://www.legislation.gov.uk/uksi/2013/3134/regulation/16)). | | Debt collection and service calls | The DMCC Act bans "persistent and unwanted solicitations," except where needed to enforce a contract ([DMCC Act 2024, Sch. 20 para. 28](https://www.legislation.gov.uk/ukpga/2024/13/schedule/20)). | ## Fines and enforcement On September 30, 2026, the Information Commission replaced the Information Commissioner's Office (ICO) and took over its PECR powers ([S.I. 2026/1015](https://www.legislation.gov.uk/uksi/2026/1015/made)). | Law | Regulator | Maximum | | - | - | - | | PECR, Regulations 19 to 24 | Information Commission | £17.5 million or 4% of worldwide turnover for breaches since February 5, 2026. The regulator can also fine directors. Earlier breaches: £500,000. | | UK GDPR | Information Commission | £17.5 million or 4% of worldwide turnover ([Data Protection Act 2018, s. 157](https://www.legislation.gov.uk/ukpga/2018/12/section/157)) | | DMCC Act 2024 | Competition and Markets Authority (CMA), Trading Standards | £300,000 or 10% of turnover ([s. 182](https://www.legislation.gov.uk/ukpga/2024/13/section/182)) | | Communications Act 2003 | Ofcom | £2 million for persistent misuse ([s. 130](https://www.legislation.gov.uk/ukpga/2003/21/section/130)) | | EU AI Act, Art. 50 (calls to the EU) | EU national authorities | €15 million or 3% of worldwide turnover ([Art. 99](https://artificialintelligenceact.eu/article/99/)) | The Data (Use and Access) Act 2025 raised the PECR fines (Schedule 13, in force since February 5, 2026, [S.I. 2026/82](https://www.legislation.gov.uk/uksi/2026/82/made)). It also counts unanswered call attempts as calls (Regulation 2). The ICO is reviewing its PECR guidance after these changes, so expect updates ([ICO](https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/guide-to-pecr/electronic-and-telephone-marketing/telephone-marketing/)). Recent cases: In September 2025, the ICO fined Home Improvement Marketing £300,000 and Green Spark Energy £250,000 for millions of avatar calls without consent ([penalty notice](https://ico.org.uk/media2/m5xnbu1m/home-improvement-marketing-ltd-monetary-penalty-notice.pdf)). In August 2026, it fined Elderly Aids £190,000 for 758,053 live calls to TPS numbers ([ICO](https://ico.org.uk/about-the-ico/media-centre/news-and-blogs/2026/08/ico-hits-company-selling-call-blockers-with-190k-fine-for-nuisance-calls/)). ## Sources * [Privacy and Electronic Communications (EC Directive) Regulations 2003](https://www.legislation.gov.uk/uksi/2003/2426/contents), Regulations [2](https://www.legislation.gov.uk/uksi/2003/2426/regulation/2), [19](https://www.legislation.gov.uk/uksi/2003/2426/regulation/19), [21](https://www.legislation.gov.uk/uksi/2003/2426/regulation/21), [21A](https://www.legislation.gov.uk/uksi/2003/2426/regulation/21A), [21B](https://www.legislation.gov.uk/uksi/2003/2426/regulation/21B), [24](https://www.legislation.gov.uk/uksi/2003/2426/regulation/24), [26](https://www.legislation.gov.uk/uksi/2003/2426/regulation/26), and [Schedule 1](https://www.legislation.gov.uk/uksi/2003/2426/schedule/1) * [Data (Use and Access) Act 2025](https://www.legislation.gov.uk/ukpga/2025/18/contents), sections 110, 115, and 118 to 119; commencement by [S.I. 2026/82](https://www.legislation.gov.uk/uksi/2026/82/made) and [S.I. 2026/1015](https://www.legislation.gov.uk/uksi/2026/1015/made) * [Data Protection Act 2018, s. 157](https://www.legislation.gov.uk/ukpga/2018/12/section/157); [UK GDPR Art. 7](https://www.legislation.gov.uk/eur/2016/679/article/7) * [Investigatory Powers Act 2016](https://www.legislation.gov.uk/ukpga/2016/25/section/4), sections 3 and 4; [Investigatory Powers (Interception by Businesses etc. for Monitoring and Record-keeping Purposes) Regulations 2018](https://www.legislation.gov.uk/uksi/2018/356/regulation/3), regulations 3 and 4 * [Consumer Contracts Regulations 2013](https://www.legislation.gov.uk/uksi/2013/3134/regulation/15), regulations 15 and 16 * [Digital Markets, Competition and Consumers Act 2024](https://www.legislation.gov.uk/ukpga/2024/13/section/226), sections 226, 227, 182, and Schedule 20 * [Communications Act 2003](https://www.legislation.gov.uk/ukpga/2003/21/section/128), sections 128 and 130 * ICO: [Telephone marketing](https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/guide-to-pecr/electronic-and-telephone-marketing/telephone-marketing/), [Guidance on direct marketing using live calls](https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/guidance-on-direct-marketing-using-live-calls/), [Business-to-business marketing](https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/business-to-business-marketing/), [Using marketing lists](https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/guide-to-pecr/electronic-and-telephone-marketing/using-marketing-lists/), [AI transparency](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/artificial-intelligence/guidance-on-ai-and-data-protection/how-do-we-ensure-transparency-in-ai/), [Biometric data](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/lawful-basis/biometric-data-guidance-biometric-recognition/key-data-protection-concepts/) * ICO enforcement: [avatar calls fines, September 2025](https://ico.org.uk/about-the-ico/media-centre/news-and-blogs/2025/09/warning-over-robo-calls-as-energy-firms-fined-half-a-million-pounds-for-unlawful-marketing-calls), [Home Improvement Marketing penalty notice](https://ico.org.uk/media2/m5xnbu1m/home-improvement-marketing-ltd-monetary-penalty-notice.pdf), [Elderly Aids, August 2026](https://ico.org.uk/about-the-ico/media-centre/news-and-blogs/2026/08/ico-hits-company-selling-call-blockers-with-190k-fine-for-nuisance-calls/) * [FCA Handbook, COBS 4.8](https://www.handbook.fca.org.uk/handbook/COBS/4/8.html) * [Ofcom: Tackling scam calls from abroad](https://www.ofcom.org.uk/phones-and-broadband/scam-calls-and-messages/consultation-tackling-scam-calls-from-abroad); [Comms Council UK on the 2024 CLI guidance](https://commscouncil.uk/press/ofcom-updated-cli-guidance-tackling-scam-calls/) * [Ofgem: npower investigation under Standard Licence Condition 25](https://www.ofgem.gov.uk/publications/investigation-npower-and-its-compliance-standard-conditions-25-and-27-electricity-and-gas-supply-licences) * [TPS](https://www.tpsonline.org.uk/), [TPS licence prices](https://corporate.tpsonline.org.uk/prices), [DMA: Preference services](https://www.dma.org.uk/legal-and-public-affairs/preference-services-tps-and-mps) * [Lewis Silkin: King's Speech 2026](https://www.lewissilkin.com/en/insights/2026/05/13/kings-speech-2026-commercial-technology-and-regulatory-developments-102msjh) * EU AI Act [Art. 2](https://artificialintelligenceact.eu/article/2/), [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.