AI voice agents for UK e-commerce and retail answer order, delivery and return calls, and the store answers for what its agent says, as the CMA treats it like an employee. The greeting says it is an AI assistant, prices include mandatory delivery fees from the store's system, and cart or cross-sell calls count as marketing under PECR.
Key Takeaways
- The store answers for its AI agent just as it does for staff.
- Quoted prices include mandatory delivery fees, read from the store's system.
- Cart-recovery and cross-sell calls are marketing under PECR, so consent comes first.
A voice agent that quotes a price without the delivery fee puts the store in the wrong. We cover prices and returns from your systems, the person in the loop, PECR on order and cart calls and where UK call data sits with Dograh. Our guide to retail voice agents covers the wider picture.
The store answers for its agent
Online shopping is a large share of UK retail, so order and delivery calls are too. The ONS retail sales release put online sales at 28.8% of all retail sales in September 2026, with online sales values 6.8% higher than a year earlier.
For those calls, the UK has guidance that names AI agents directly. The Competition and Markets Authority's guidance on AI agents and consumer law says a business is responsible for what its AI agent does in the same way it is responsible for an employee, even when another company built it. The agent must not mislead through what it says or leaves out, and the CMA can fine up to 10% of worldwide turnover.
The same guidance says people should know they are dealing with AI where that might affect their decisions. So the opening line names the store and says the caller is speaking with an AI assistant. In Dograh, that line is the Greeting Text on the Start Call node, spoken word for word. Callers can cut into a greeting after two words by default, so switch off Allow Greeting Interruption on the node to make sure the label plays in full.
Prices and returns from your systems
On a store call, every figure the agent says comes from your systems, never from the model's memory. The CMA's letter to online retailers says mandatory delivery fees must be included in the total price and shown up front. So when a shopper asks what an order costs, your order system returns the total with the delivery fee in it, and the agent reads that number.
Returns follow the same rule. The Consumer Contracts Regulations 2013 give online shoppers a 14-day cancellation period for most goods, and many stores offer longer. The agent reads both the statutory cancellation period and your own policy from your returns system, so it never shortens one or stretches the other. AI voice agents for returns and RMA covers the return flow step by step.
An HTTP API tool does the lookup during the call. When the tool starts, a message (a typed line or a recorded clip) can play, such as "Let me pull up that order", and the request runs while it plays. A later update, such as "I'm still checking", covers a slow lookup.
Open Source Alternative to Vapi / Retell
Self-hosted voice agent platform — no per-minute fees
dograh-hq/dograh
Star on GitHub
A person in the loop
The CMA expects a human in the loop, and on a voice line that means two things: people review calls, and a person takes the ones the agent cannot settle. Before any order detail, the agent checks the caller, for example with the order number plus the delivery postcode. It never takes card numbers by voice, and your own system sends a payment link by text or email when one is needed.
For review, QA samples calls at the rate you set. Replace its prompt with instructions that flag any call where the agent quoted a price, fee or return window that was not in the tool result, and have a person read those calls each week.
Stores on Twilio, Telnyx, Plivo, Cloudonix or Asterisk ARI hand calls over with the Transfer Call tool. Your team's phone rings first, and the shopper is put through only after someone answers it. No summary goes with the call by default, so the agent writes the order number and the problem to your system first, such as a faulty item or a refund dispute.
Order calls and cart calls under PECR
UK rules split store calls in two. The ICO's guidance on live marketing calls says purely administrative service messages are not direct marketing, but promotional content inside a service call makes the call marketing.
A delivery delay, a return update or a refund confirmation is a service call. An abandoned-cart reminder, a cross-sell or a "we miss you" call is marketing under the Privacy and Electronic Communications Regulations (PECR). Live marketing calls are screened against the Telephone Preference Service (TPS), and automated marketing calls need specific consent. An AI agent's marketing call is generally safer treated as automated, as AI voice agents for real estate in the UK explains, so cart calls go only to shoppers who gave that consent.
A shopper can opt out by voice at any point. The agent confirms it, records the request in your CRM, and the number drops off the next upload. AI voice agents for abandoned cart recovery covers the cart call itself. Treat this post's reading of the CMA guidance and PECR as general information, and confirm your store's position with counsel.
Join the Dograh Community
Dograh is an OSS alternative to Vapi. Join our Slack community for queries, releases, best practices & community interactions.
Where UK call data sits
Store calls carry names, addresses and order histories, which are personal data under UK GDPR. To keep them in the UK, self-host Dograh in a UK data centre and run the models there too.
Behind each store call are two layers: Dograh orchestrates the call flow, the order-system tools and the telephony, and the retailer chooses the speech and language models as a separate layer. On a self-hosted install, recordings and transcripts sit on your own servers, with recording controlled by one server-wide switch.
Self-hosted installs send anonymous usage telemetry by default, which you stop with ENABLE_TELEMETRY=false and by removing POSTHOG_API_KEY. Running Dograh on the store's own servers means no per-minute platform fee, yet the servers, model keys and phone minutes still have a price. On Dograh Cloud, the store pays a 1¢-a-minute platform fee.
Which store call to start with
Start with inbound order-status and delivery questions, because the agent only reads and records. Add returns next, once the return window lookups are tested. Cart and cross-sell calls come last, on their own campaign, built from shoppers whose consent is on record.
Run your launch tests over a real phone line. A browser test sends 16 kHz audio, but most phone calls arrive at 8 kHz, which is where product names and postcodes get misheard.
Glossary
- Total price
- The price including every mandatory fee, such as a delivery charge the shopper cannot avoid. The CMA says online retailers must show it up front, so a voice agent reads the total from the store's system.
- Statutory cancellation period
- The 14 days the Consumer Contracts Regulations 2013 give online shoppers to cancel most orders. A store may offer longer, and the agent reads both from the store's policy.
- Human in the loop
- The CMA's expectation that people oversee an AI agent. On a voice line, it means staff review flagged calls and a person takes calls the agent cannot settle.
- Service message (PECR)
- A purely administrative call, such as a delivery update, which is not direct marketing. Add an offer or a cart reminder and the call becomes marketing under PECR.
