A remote sales circuit is verified in the same way a customer service operation is: by asking, at each step, what evidence demonstrates that the step happened as required.
Checkpoints and evidence
| Checkpoint | Requirement | Evidence |
|---|---|---|
| Opening of the call | Identity of the trader and commercial purpose stated explicitly | Script under version control, plus recording or transcript |
| Pre-contractual information | Full set provided before the consumer is bound | Script section, and durable-medium record where sent in writing |
| Consent to be bound | Signature of the offer or written consent, where the trader initiated the call | Signed document, recorded written consent, or evidence that the consumer initiated the call |
| Confirmation | Durable medium, within the national deadline | Dated dispatch record and content sent |
| Right of withdrawal | Information on the period and on how to exercise it | Text provided and record of withdrawals received and processed |
Where the lawful basis question returns
A remote sale that follows an outbound call carries all of the marketing compliance questions with it. The sales circuit may be impeccable and the contact that generated it unlawful, and the second defect is not cured by the first.
Any review of a telephone sales process therefore has to start one step earlier, at the lawful basis for the call itself.
Where any part of the sales interaction is conducted by an AI system interacting directly with a natural person, the transparency duty of article 50 of Regulation (EU) 2024/1689 applies, and has done since 2 August 2026. This is independent of, and additional to, the distance contracting requirements.
Apply this to your operation
A general framework is no substitute for a concrete assessment. The diagnostic determines what applies to your operation.