AI calls UK regulations are not one rulebook. When an AI agent makes or takes calls for a UK business, several sets of rules can apply at the same time: UK GDPR for recordings and transcripts, the Privacy and Electronic Communications Regulations (PECR) for marketing calls, and Ofcom's rules on silent and abandoned calls.
For marketing calls, PECR requires specific consent before an automated call that plays a recorded message, and TPS and CTPS screening for live calls unless the person has consented. Every call must say who is calling, and your number must be displayed. Recordings and transcripts usually contain personal data under UK GDPR, so tell callers and keep only what you need.
Two kinds of call, two sets of rules
The first question is whether the call is marketing at all. PECR defines direct marketing as the communication, by whatever means, of advertising or marketing material directed at particular individuals. The test is what the call is for, not which technology made it.
A booking reminder is not marketing. A call that confirms an appointment and asks whether the caller wants an upgrade is. If an agent makes a service call and then promotes something, treat the whole call as marketing and apply the marketing rules to it. That one habit avoids a common mistake in outbound planning.
Automated calls need specific consent
The ICO's telephone marketing guidance defines an automated call as a call made by an automated dialling system that plays a recorded message. For those calls, PECR regulation 19 applies, and the consent must specifically cover automated calls. General marketing consent is not enough, and neither is consent given for live calls.
An AI agent that speaks in a live conversation is not the same as a recorded message, but the line is not always clear, and regulators look at what actually happens on the call. Ask counsel how your agent is classified before you launch an outbound campaign. Until you have a written answer, collect specific consent for any automated call.
Live calls: TPS and CTPS screening
The Telephone Preference Service (TPS) is a central register of individuals who have opted out of live marketing calls. The Corporate Telephone Preference Service (CTPS) works in the same way, for companies and other corporate bodies. For live marketing calls, you must not call a number on either register unless the person has specifically consented to your calls. The rules sit in PECR regulations 21, 21A and 21B.
Screening is a check you run before the campaign, not during the call. Build it into the list of numbers the agent is allowed to dial, and keep a record of when each list was screened. A call to a registered number is not excused by the agent's good manners.
Who is calling, and which number is shown
For live calls, the caller must always say who is calling, and must allow their number, or an alternative contact number, to be displayed. For automated calls, the same display rule applies, and the message must also include the caller's name and a contact address or a freephone number.
Make the agent state the company name at the start of every call. Keep a freephone number or contact address that works, and test it. A recipient who cannot reach you to opt out has a reason to complain.
Recording calls and transcripts under UK GDPR
Recordings and transcripts usually contain personal data. The name of a caller, a phone number, a booking and a complaint are all personal data, and the agent's summary of the call is personal data too.
Tell callers at the start that the call is recorded and why. Keep the recording only as long as you need it, limit who can open it, and note the purpose for which you recorded it. If the purpose is quality checks, do not let the same recording quietly become a marketing list. Confirm the detail for your business with counsel.
Ofcom and silent or abandoned calls
Ofcom, the communications regulator, has a policy on the persistent misuse of networks and services. Its work on silent and abandoned calls focuses on calls that leave a person unsure who is calling. Predictive dialling systems can create abandoned calls when a person answers and no agent is free.
For AI outbound campaigns, check that every answered call is connected to the agent or to a clear message, and never leave a person on an open line with nobody there. Check Ofcom's current guidance before you set a dialler's rules, because the detail changes and this article does not list specific thresholds.
Setting up an outbound campaign in the UK
Outbound campaigns carry most of the risk, so plan them in a fixed order. Start with the list: where each number came from, and whether the person gave consent for the kind of call you plan to make. Then screen live-call numbers against the TPS and CTPS, and set the calling hours and frequency your own policy requires.
Next, test the message with a colleague who will play a sceptical customer. Check that the caller is identified, that the number shown is correct, and that the opt-out works from the first call. Finally, watch the complaints and opt-outs in the first week, and stop the campaign if they rise. A campaign that is paused early is far easier to explain than one that runs for a month before anyone looks.
A checklist for UK campaigns
Use this table as a starting point for the conversation with counsel.
| Check | Why it matters |
|---|---|
| Specific consent for automated marketing calls | PECR regulation 19 requires consent that specifically covers automated calls |
| TPS and CTPS screening for live marketing calls | PECR regulations 21, 21A and 21B, unless the person has consented |
| Name and a contact address or freephone number in automated messages | ICO guidance on automated calls |
| Your number displayed, or an alternative contact number | ICO guidance for live and automated calls |
| Clear identity at the start of every live call | ICO guidance for live calls |
| Recording notice at the start of each call | Good practice, to be confirmed with counsel |
| A retention limit for recordings and transcripts | Good practice, to be confirmed with counsel |
| No answered calls left open on outbound campaigns | Ofcom's approach to silent and abandoned calls |
If your business is regulated by the FCA, the same calls also raise questions about fair outcomes for customers. FCA Consumer Duty and AI phone agents covers that side of the picture.
How VoiFlow handles this
VoiFlow's journeys and campaigns run outbound sequences with calling windows, consent and do-not-call rules, and every call is recorded, transcribed and scored for review. Those features help a UK team put the checks above into practice, but they do not replace the checks. Read the trust page for how data is handled, and confirm the rules for each campaign with counsel.
For the US position on the same kind of calls, see AI voice calls and the TCPA.
What to do next
Write down which of your calls are marketing and which are service calls, then check each campaign against the table above. Take the list to counsel. When you are ready to plan the set-up, read about outbound calling campaigns and then contact us to talk through your first campaign.
Frequently asked questions
Do I need consent to make AI marketing calls in the UK?
For automated marketing calls, yes. PECR regulation 19 requires consent that specifically covers automated calls. For live marketing calls, check the TPS and CTPS registers and the consent rules, and take advice on your campaign.
Is a booking reminder a marketing call?
Not if it only confirms a booking. PECR defines direct marketing as advertising or marketing material directed at particular people. If the call also promotes a product or an offer, treat it as marketing.
Must the agent say that it is an AI?
If a caller asks, the agent must say it is an AI assistant, and it should never deny it. Saying so at the start of the call is also good practice, because the caller then knows what they are speaking to.
What if someone asks not to be called again?
Record the request straight away, stop marketing calls to that number, and make sure every list you call from is updated. The ICO's guidance says you must make it easy for people to withdraw consent, and tell them how to do it. Test the opt-out on live calls before every campaign, so that a request made during a call is honoured the same way as one made by email.
Should I record AI calls?
Many businesses record calls for quality and evidence. If you do, tell callers at the start, keep the recordings only as long as you need them, and limit who can open them. Check the purpose and the retention period with counsel.
This is general information, not legal advice.
