Guides · checked 4 October 2026

AI calling compliance: UK and Portugal

Everything a small business should check before an AI agent rings anyone in the UK or Portugal, with the official source for each line.

This is not legal advice

This guide quotes the law and the regulators’ own pages and says where they are silent. It cannot tell you whether your campaign is lawful: that depends on who you call, where your list came from and what you say. For a decision that matters, ask a solicitor (UK) or an advogado (Portugal). Every source below was read on 4 October 2026; laws and guidance change, so check the date before you rely on it.

The checklist, country by country

United KingdomPortugal (EU)
Calling businessesAllowed for live calls unless the number is on the TPS/CTPS or objected; screen both registersCompanies: allowed unless they objected to you or are on the DGC list (check monthly). Sole traders: consent first
Calling individualsLive calls: TPS screening and objections. Automated calls: prior consentPrior express consent
AI voice agentsNo ICO guidance yet on whether they count as automated callsConsent rule applies to individuals whatever makes the call
Say it is an AINo specific law; never misleadYes, at the first interaction (AI Act art. 50, since 2 Aug 2026)
RecordingInform people (2018 Regulations, UK GDPR)Inform and get consent (Lei 41/2004 art. 4.º(3))
Calling hoursPECR sets no calling hours; Ofcom’s rules on silent and abandoned calls apply09:00-22:00 for consumers (DL 134/2009)
Maximum fine£17.5m or 4% of turnover (PECR, since 5 Feb 2026)€5m for companies (Lei 41/2004); AI Act up to €15m or 3% (for SMEs, whichever is lower)

The guides

PECR and AI calls in the UK

Live versus automated calls, and the 2026 fine.

Read

TPS and CTPS screening

Two registers, the 28-day rule, licences.

Read

Silent and abandoned calls (Ofcom)

How an AI dialler must behave on the network.

Read (guide awaiting verification)

Recording calls

UK notice, Portuguese consent, sample wording.

Read

Saying it is an AI

EU AI Act Article 50 and the UK position.

Read

GDPR for AI calling

Lawful basis, the right to object, the first sentence.

Read

Calling Portugal

Consent, the DGC list, calling hours, fines.

Read

Is cold calling legal in the UK?

Our earlier guide to PECR, TPS and CTPS.

Read