Yes, you can generally chase a customer with an AI phone call in the UK, because a call about money they owe you is a service call, not a marketing call, so the Telephone Preference Service and the consent rule for automated marketing calls don't apply to it. The rules that do apply are data protection law, Ofcom's rules on silent and abandoned calls, and, if the customer is an individual, the law on harassing debtors and aggressive practices. Saying clearly that the caller is an AI, calling at reasonable times and keeping the call to the invoice keeps you well inside them.
In this article
The short version
- A call about money a customer owes is a service call, not marketing.
- TPS screening and the consent rule for automated marketing calls don't apply to it.
- Data protection law and Ofcom's rules on silent and abandoned calls still do.
- For individual customers, the law on harassing debtors and aggressive practices applies too.
- Say the caller is an AI, call at reasonable times and keep the call to the invoice.
Why a payment reminder call isn't a marketing call
Most of the UK's rules on unwanted calls come from the Privacy and Electronic Communications Regulations (PECR), and most of those rules only apply to marketing. Live marketing calls can't go to numbers registered with the Telephone Preference Service or its corporate version, and automated marketing calls need the person's specific consent.
A call reminding a customer about an unpaid invoice is different. The Information Commissioner's Office treats messages with an administrative or customer service purpose as service messages, not direct marketing, and gives the example of a gym calling a member whose monthly payment has failed. A chasing call about your own invoice is the same kind of call, so you don't need to screen the number against the TPS or collect consent for automated calls first.
The exemption is lost the moment the call promotes something. If your AI caller mentions a new service, an upgrade or an offer, the whole call can count as marketing. Keep it to what's owed and how to pay.
The rules that still apply
Data protection law applies whenever you use a customer's name, number and payment history, however the call is made. Chasing a debt for work you've done is likely to fall under contract or legitimate interests as your lawful basis. Your privacy notice should say that you may contact customers about unpaid invoices, including by automated or AI calls, and that calls may be recorded if they are. The ICO also expects you to be open about how personal data is used in an AI system. Give the AI caller only the data it needs: the customer's name, the invoice number, the amount and the due date, and nothing about other customers.
Ofcom can act against anyone who persistently misuses a phone network, whatever the call is for, and its policy names debt collection among the kinds of calls it has in mind. Silent calls, abandoned calls, calls showing a number that can't be called back, and repeated calls to the same number all count. An AI caller that hangs up without speaking or rings the same customer several times a day could fall into that.
If the customer is an individual, two more sets of rules come in. Under the Administration of Justice Act 1970, harassing someone with demands for payment that are calculated to cause alarm, distress or humiliation, or falsely implying criminal proceedings or official authority, is a criminal offence. And under consumer protection law, debt collection is a commercial practice, so aggressive tactics, contact at unreasonable hours and persistent unwanted calls can be unlawful. If you've provided regulated consumer credit, the FCA's rules on collecting arrears apply on top. Most trade invoices aren't regulated credit, but it's worth checking if you lend or offer finance.
What a fair AI chasing call looks like
You'll find most of this is ordinary good credit control, written down so a machine can follow it.
- Say at the start that the caller is an AI calling on behalf of your business, and never let it pass itself off as a person.
- Call during working hours on working days, and space calls out. One call at a set stage in your chasing is very different from daily calls.
- Show a number the customer can call back, and play a clear message instead of silence.
- Stick to the invoice: who you are, what's owed, when it was due and how to pay.
- Tell the customer if the call is recorded.
- Hand over to a person when the customer disputes the invoice, mentions illness, bereavement or money worries, or asks to talk to someone.
There are also things an AI caller should never do. It shouldn't take card or bank details by voice, change the amount, offer a discount or agree new terms. It shouldn't threaten court, bailiffs or a damaged credit rating, or use wording that sounds official when it isn't. And it shouldn't discuss the debt with anyone other than the customer or the person who pays.
How Adfin's AI phone call is set up
In Adfin, the AI phone call is one optional stage in escalations, which Adfin's collection agents run within rules you approve after your normal reminders haven't worked. The call says it's an AI, reminds the customer about the overdue invoice and can text them a secure payment link. It never changes amounts, offers discounts, agrees terms or takes card or bank details, and it never mentions legal action, debt collection or fees.
Calls are placed between 09:00 and 19:00 on UK working days. If there's no valid number, the call stage is skipped, and if nobody answers you get a task to follow up yourself. You can leave the call out of escalations entirely, or switch escalations off for a customer you'd rather speak to in person.
Related guides
- Can AI chase overdue invoices? What an AI phone call can and can't do for your credit control
- Should invoice reminders come from a person or an AI?
- Is it safe to let AI email your clients?
- Overdue invoice escalation timeline: when to send each notice (with a worked example)
- AI for credit control: a complete guide
Common questions
Do I need to check the Telephone Preference Service before an AI debt chasing call? No. TPS screening applies to unsolicited live marketing calls, and a call about an unpaid invoice is a service call as long as it doesn't promote anything.
Do I need a customer's consent to call them with an AI about an invoice? The consent rule for automated calls applies to marketing. For a debt call you still need a lawful basis under data protection law, which is likely to be contract or legitimate interests.
Does the AI caller have to say it's an AI? It's good practice, and it fits the ICO's expectation that you're open about how AI uses personal data. Letting a customer believe they're talking to a person can mislead them.
What times can I call a customer about a debt? For any customer, working hours on working days are the safe choice. Calls to individuals at unreasonable hours can be an aggressive practice under consumer law.
Are the rules different for consumers and businesses? Yes. The law on harassing debtors and aggressive practices protects individuals, and FCA rules apply to regulated consumer credit. Ofcom's rules on silent and abandoned calls apply to everyone.
Can an AI caller take a card payment over the phone? Adfin's AI call doesn't take card or bank details. It can text the customer a secure payment link instead.
Sources
- Information Commissioner's Office - Identify direct marketing (accurate as of November 2026) https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/direct-marketing-guidance/identify-direct-marketing/
- Information Commissioner's Office - Telephone marketing (accurate as of November 2026) https://ico.org.uk/for-organisations/direct-marketing-and-privacy-and-electronic-communications/guide-to-pecr/electronic-and-telephone-marketing/telephone-marketing/
- Ofcom - Persistent misuse policy statement (accurate as of November 2026) https://www.ofcom.org.uk/__data/assets/pdf_file/0024/96135/Persistent-Misuse-Policy-Statement.pdf
- legislation.gov.uk - Administration of Justice Act 1970, section 40 (accurate as of November 2026) https://www.legislation.gov.uk/ukpga/1970/31/section/40
- GOV.UK - Unfair commercial practices (CMA207) (accurate as of November 2026) https://www.gov.uk/government/publications/unfair-commercial-practices-cma207/unfair-commercial-practices
