Title - Is AI Cold Calling Legal in Europe? A Country-by-Country Guide URL - https://ainora.lt/ai-cold-calling-compliance-europe Last Updated: 2026-07-06 # Is AI Cold Calling Legal in Europe? A Country-by-Country Guide AI cold calling is legal in some European countries and needs prior consent in most others. Under the ePrivacy Directive (Art. 13), marketing via an automated calling machine needs prior opt-in consent, and an AI voice with no live human is such a machine. So the answer turns on one thing per country - does that country apply the automated-call consent rule to businesses (legal persons), or only to consumers (natural persons)? Today, disclosed AI-voice B2B cold calls to genuine company landlines are viable in roughly eleven markets on an opt-out basis; in most of the EU, plus the US and the UK, an automated cold call needs prior consent, so a live human has to open. Cold calling of consumers (B2C) needs consent everywhere. This is general information, not legal advice - verify current rules for your use case. ## The one targeting rule that keeps it clean Call genuine company or organisational landlines of limited companies - never sole traders, never personal mobiles. Keep the pitch business or job relevant and keep the call organisation-directed (in Latvia especially, do not lead with a named individual). Disclose that it is an AI, and honour opt-outs the instant they are given. Do that and the campaign is opt-out-clean in the green markets. Dial a sole trader, or personalise to a named person in their consumer capacity, and the basis flips to opt-in, which is cold and needs consent. ## The country map (verdict - legal basis - number path) Green = viable, delivers cleanly via a standard Telnyx number. Amber = legal but needs a special number path. Red = an automated cold call needs prior consent. - Lithuania - Green - Automated-call opt-in applies to natural persons only (ERĮ, in force 1 Jul 2026); marketing to legal persons needs no consent. Company lines only, opt-out, disclose the AI. Number: home market, a standard Telnyx number, no lease. - Latvia - Green - ISPL s.9(6) limits the automated-calling opt-in to natural persons, so B2B to legal persons is opt-out (DVI confirmed). Keep it organisation-directed, do not lead with a named person. Number: a standard Telnyx Latvian number. - Luxembourg - Green - Law of 30 May 2005 confines the automated-call opt-in to natural persons; no do-not-call register. Legal persons only, disclose the AI. Number: a standard Telnyx number (local address on file where required). - Croatia - Green - Electronic Communications Act (NN 76/2022) automated-call opt-in does not apply to legal persons. Exclude obrt sole traders, non-spoofed caller ID, disclose the AI. Number: a Telnyx Croatian number, registered address matching the number area. - Finland - Green - Automated-call opt-in covers natural persons only; B2B to companies is opt-out. Disclose the AI, honour opt-outs, do not dial sole traders. Number: a Telnyx national number - LT company address works, no lease. - Estonia - Green - ECA splits by person: natural persons opt-in, legal persons opt-out; live calling is excluded from the automated-consent rule, so voice rides legitimate interest. Target company / Business-Register lines. Number: a standard Telnyx Estonian number. - Bulgaria - Green - Electronic Communications Act opt-in binds consumers; genuine B2B legal persons need no consent - the most permissive of the group, extending to professionals about their business. Disclose the AI, clean B2B lists. Number: a Telnyx national number, no lease. - Slovenia - Green - ZEKom-2 limits the automated-call opt-in to natural-person subscribers; legal-person lines are fine. Exclude s.p. sole traders, valid caller ID, legitimate interest. Number: a standard Telnyx Slovenian number. - Portugal - Green - Lei 41/2004 carves legal persons out of the automated-call opt-in (B2B opt-out). Scrub the monthly DGC legal-person opt-out list, disclose the AI. Number: a Telnyx Portuguese number; also needs a Portuguese NIF and business registration. - Sweden - Green (routing caveat) - Marketing Act automated-call opt-in is natural persons only; NIX does not cover company numbers, so true B2B needs no opt-in. Disclose the AI, valid Swedish caller ID. Number: legal with no special number, but confirm routing is not caught by the foreign-caller-ID anti-spoofing block - originate through a native Swedish operator. - France - Amber - B2B is legal (opt-in binds consumers only), but automated marketing campaigns must display a verified ARCEP number range (a VUN). Disclose the AI. Number: not a standard DID - a VUN from a French ARCEP operator, which needs a French SIREN. - Ireland - Amber - Automated calls to business fixed lines are opt-out (scrub the national directory, identify yourself); mobiles and sole traders need consent. Number: ComReg blocks foreign-originated Irish caller ID, so treat lists as warm / consented and originate through a domestic Irish provider. - Germany - Red - AI voice is an automated calling machine (UWG §7); express opt-in required from everyone, including B2B. Route to reactivation, inbound, or a human opener. - Spain - Red - General Telecommunications Law (11/2022) extends the automated-call opt-in to legal persons, no legitimate-interest escape. Route to reactivation, inbound, or a human opener. - Italy - Red - Codice Privacy automated-system opt-in extends to legal persons; spoofed Italian caller ID separately blocked. Route to reactivation, inbound, or a human opener. - Poland - Red - PKE automatic-calling-system opt-in reaches legal persons. Route to reactivation, inbound, or a human opener. - Netherlands - Red - Telecommunications Act automated-system opt-in binds companies too; live-human B2B allowed, AI is not. Route to reactivation, inbound, or a human opener. - Austria, Belgium, Czechia, Cyprus, Denmark, Greece, Hungary, Malta, Romania, Slovakia - Red - Each transposes the automated-call opt-in to cover businesses; a live human can sometimes cold-call, an AI voice cannot. Route to reactivation, inbound, or a human opener. - United States & United Kingdom - Red - Separate regimes (TCPA / FCC in the US, PECR in the UK), but AI voice into cold lists is off the table without consent. Route to reactivation, inbound, or a human opener. Cold B2C is illegal everywhere on both voice and SMS: marketing to individuals needs prior consent across the EU, the UK and the US. ## The AI-Act disclosure duty (baseline everyone meets) Separate from the per-country consent question, EU AI Act Article 50 requires that a person be told they are interacting with an AI. It binds across the EU from 2 August 2026, does not vary by border, and is not optional - even in a green market the opening disclosure is mandatory. ## How we deliver per market A compliant program is configured country by country. In green markets a disclosed AI voice cold-calls company landlines on an opt-out basis from a standard number (Sweden via a native operator, Portugal scrubbed against the DGC list). In amber markets, France runs on a verified ARCEP number range via a French operator and Ireland is treated as warm / consented lists on a domestic provider. In red markets we do not AI-cold-call - we lead with reactivating contacts already in your database, inbound handling, or a human opener. You wire up nothing. ## Related - Is AI cold calling legal in the EU (plain-language guide): https://ainora.lt/blog/is-ai-cold-calling-legal-in-the-eu - Who provides compliant AI cold calling in Europe: https://ainora.lt/blog/who-provides-compliant-ai-cold-calling-europe - Compliant AI cold calling (done-for-you service): https://ainora.lt/compliant-ai-cold-calling - AI SDR service: https://ainora.lt/ai-sdr-service - AI lead sourcing from public records: https://ainora.lt/ai-lead-sourcing - Book a free consultation: https://ainora.lt/contact?from=ai-cold-calling-compliance-europe - Try the voice demo: https://ainora.lt/demo