Is calling customers with a robot legal in Uzbekistan

Calling customers with a robot in Uzbekistan is permissible when there is a lawful basis for the call and the data processing and, for advertising, the subscriber’s prior consent (Article 30 of the Law on Advertising). From 1 November 2026, Resolution PP-265 bans advertising calls over mobile networks between 18:00 and 09:00. Two layers of rules apply. The first is advertising: Article 30 of the Law on Advertising (Law No. ZRU-776) and clause 11 of PP-265. The second is data: under the Law on Personal Data (ZRU-547), a number, a name and a voice recording are personal data; consent may be given in any form that proves it was obtained, and the customer may withdraw it. Hence the practical rule: the basis for a call belongs in the customer record, not in a manager’s memory. Zukko.AI is an AI agent platform for business: the calling window is set in the campaign settings, 09:00–18:00 for advertising. An overview, not legal advice.

Is calling customers with a robot legal in Uzbekistan: what the law regulates

The rules reviewed below are not about the technology; they are about what the call says and about the customer’s data. Two layers apply. The first is advertising: Article 30 of the Law on Advertising (Law No. ZRU-776) allows advertising in the course of telecommunications services on condition of the subscriber’s prior consent (lex.uz), and clause 11 of Presidential Resolution No. PP-265 adds requirements for advertising calls and SMS from 1 November 2026. The second is data: a phone number, a full name, payment history and a voice recording are personal data, and their processing is governed by the Law on Personal Data (Law No. ZRU-547, lex.uz) as amended by Law No. ZRU-1125 of 26 March 2026 (lex.uz).

Under Law No. ZRU-547, consent is given in any form that makes it possible to confirm it was obtained (Article 21), the operator provides proof that consent was obtained in the cases set by legislation (Article 31), and a person may withdraw consent (Articles 21 and 30). The practical rule follows: the basis for a call has to sit in the customer card, not in a manager’s memory.

What changes for advertising calls from 1 November 2026

Presidential Resolution No. PP-265 of 15 July 2026 (clause 11) introduces a procedure that applies from 1 November 2026 (lex.uz):

• A ban between 18:00 and 09:00. During these hours, distributing advertising calls and notifications over mobile networks is prohibited.
• Advertising SMS only with consent. Goods and services may be advertised by SMS only after the person’s written or electronic consent.
• Registration of mailing services. Legal entities that provide advertising call and SMS distribution services operate only after registering their information systems in the State Register of Personal Data Databases.
• Blocking at the subscriber’s request. Mobile operators block advertising calls and notifications at the subscriber’s request.
• Two bodies of law. A breach of these requirements is a breach of both advertising and personal data legislation.

For outbound calling this is one hard change: an advertising campaign has to fit the 09:00–18:00 window. The familiar 9:00–21:00 window is a typical campaign setting for other calls, not a legal rule. Clause 11 speaks of advertising calls and notifications; whether the ban applies to service calls — an appointment reminder, a payment reminder, a call to a debtor — has not been established, and the legal assessment is for a lawyer.

Call type: what the rule says and what to do

The line between an advertising call and a service call is a matter of judgement: what decides it is the content of the conversation, not the name of the campaign. The table shows what the rules state directly and what remains a question for a lawyer.

What to observe when calling with a voice AI agent

• A basis for the call and for processing data. Customer consent or another lawful basis; for advertising, the subscriber’s prior consent.
• Proof of consent. The date, source and wording of the consent are kept in the customer card, so that they can be shown.
• Call time. From 1 November 2026, advertising calls only between 09:00 and 18:00. For other calls the business chooses the window; a typical setting is 9:00–21:00 Tashkent time.
• Respect for refusal. If the customer asks not to be called, the number is excluded from calling (do-not-call).
• AI disclosure. Fair practice is to say at the start of the call that an AI assistant is calling. Whether it is mandatory in your industry is for compliance to assess.
• Call recording. A voice recording is personal data: processing it needs a lawful basis.
• Data storage. After the ZRU-1125 amendments, storage in Uzbekistan is mandatory for biometric and genetic data and for the data of users of telecom operators’ services. More in the article on personal data localisation under ZRU-547.

How the voice AI agent handles it

Choosing a permitted time and collecting consent is the job of whoever launches the campaign: the platform helps you meet the requirements but does not replace a legal assessment. The consent rules for SMS and messengers are covered in the article on consent for mailings in Uzbekistan.

How the voice agent itself and the calling scenarios work is described on the voice AI page. Consent and opt-outs are easier to manage where the segments are built — in smart campaigns. Where the data sits, who can access it and how roles are separated is covered under security.

What the business gets

• Rules in the settings, not in an operator’s memory — the window, the retries and the stop-list are set in the campaign itself.
• Customer trust — honest AI disclosure instead of imitating a human.
• A clean base — refusals are applied automatically, no manual stop-lists.
• Transparency — you can see who was called, when, and how the call ended.

This is not a legal guarantee. Zukko.AI helps you meet the requirements, but the final legal assessment for your case must come from your lawyer or compliance function.

AI calls are the AI Voice module: they are available only on the Enterprise plan, from 15,000,000 UZS a month with 2,200 minutes included and 1,900 UZS per extra minute. Rollout takes up to 30 days. What automated calling looks like in practice is covered in the voice AI agent guide.