Yes, in all three countries, but not for every kind of call. Reminders, confirmations and follow-ups on something the customer already has are not marketing, and an AI agent can make those calls anywhere in Scandinavia as long as it says it is an AI. Sales calls are different. Norway, Sweden and Denmark all require prior consent for marketing through automated calling systems, and nobody has yet ruled that an AI agent falls outside that rule. Denmark goes further: unsolicited sales calls to consumers are banned, whoever or whatever makes them.
Sources were checked on October 29, 2026. This is an overview of the rules, not legal advice.
One shared rule, three different systems
All three countries implement Article 13 of the EU ePrivacy Directive, Norway through the EEA Agreement. It requires prior consent for direct marketing by "automated calling and communication systems without human intervention". For calls made by a person, each country chooses its own system. That is why the consent rule for machines reads almost the same in all three marketing acts, while the rules for human sales calls differ.
The open question is the same everywhere: is an AI agent that dials, talks and answers questions an "automated calling system"? The rules were written for machines that play a recorded message. An AI agent holds a real conversation, but it also dials and speaks with no person on the line. We have found no court ruling or regulator guidance in any of the three countries that settles it. Until one does, the careful reading is that the consent rule applies to sales calls made by an AI agent.
Norway
Markedsføringsloven § 15 bans marketing to natural persons through an "automatisert oppringningssystem (talemaskin)" without their prior consent. The second subsection exempts marketing where the person is "contacted orally by telephone", which is why a human telemarketer needs no consent. The Norwegian Consumer Authority's guidance on email and SMS marketing describes an automated calling system as automatic dialing that plays a recorded marketing message when the phone is answered, though it says its list of methods is not exhaustive. That points toward a narrower reading, but it does not settle the question for an agent that holds a conversation. The existing-customer exemption in § 15 covers email only, and a sales message left on voicemail counts as email under the act.
Consumer sales calls must also follow these rules, whoever makes them:
- No calls to consumers registered in Reservasjonsregisteret or to anyone who has opted out with you directly (§ 12), and the list must be checked before the first call and in the month you call (§ 13 a). Existing customers may be called about similar products, but that is an exception to the register, not to the consent rule.
- Weekdays 09:00–21:00 only, never on weekends or public holidays, and never from a hidden or unlisted number (§ 14).
- Introduce yourself, say the call is marketing and say where you got the person's details (§ 16).
- After an unsolicited phone offer, the consumer is bound only once they accept the offer in writing after receiving a written confirmation (angrerettloven § 10). Newspaper subscriptions and charities are exempt.
The register and the calling hours cover consumers only, but § 15 protects all natural persons, so an AI agent calling a named employee with a sales offer may need consent too. The Norwegian version of this guide goes into more detail.
Sweden
Marknadsföringslagen 19 § requires prior consent before marketing to a natural person through "uppringningsautomater eller andra liknande automatiska system" that are not operated by an individual. Under 21 §, ordinary calls made by a person are allowed unless the person has clearly objected, which in practice means checking the industry-run NIX-Telefon register. Screening your list against NIX covers the rule for human calls. It does nothing for the consent rule. The existing-customer exception in 19 § again covers email only.
If the call is meant to lead to a contract with a consumer, distansavtalslagen 2 kap. 3 a § has applied since September 1, 2018. At the start of the call the consumer must hear the company's identity, the purpose of the call and the name of the person calling. The contract is valid only if the consumer accepts your offer in writing after the call. How an AI agent meets the "name of the person" requirement has not been tested.
Both 19 § and 21 § protect natural persons, so a limited company's switchboard is outside them, but a sole trader is not. The rules may tighten: on July 9, 2026, the government appointed an inquiry into opt-in or a ban on telemarketing to consumers, due by January 15, 2027. More in the Swedish version.
