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Regulatory Brief · Healthcare & Life Sciences · 6 October 2026

From 1 November 2026, every Basic, Enhanced and Flexi policy in Abu Dhabi covers organ and tissue transplantation for donor and recipient, complications included whenever they appear. Policies already sold carry the benefit without the premium.

DoH Circular 197/2026, dated 6 October 2026, adds diagnosis and treatment for organ and tissue transplantation, for donors and recipients, to Abu Dhabi's Basic and Flexi health insurance policies, and applies the federal transplant obligation to all Basic, Enhanced and Flexible policies in force or issued or renewed from 1 November 2026. Basic members pay AED 20 or AED 10 per new outpatient visit. Flexi members pay 20%, capped at AED 500 per inpatient service and AED 1,000 a year, after which the insurer pays in full. Complications are covered whenever they arise. The premiums on policies already sold were set before the benefit existed, and anyone valuing an Abu Dhabi insurance or TPA book should price that gap.

The 30-second read

What a board member needs before the next meeting on this.

  1. Abu Dhabi has set its date. Circular 197/2026 applies transplant cover to all Basic, Enhanced and Flexible policies from 1 November 2026. That is the date DoH applies the benefit in Abu Dhabi; the circular does not say it is the federal commencement date of Cabinet Resolution 61/2026.
  2. Policies already in force are included. The rule reaches policies currently valid as well as those issued or renewed. The circular provides no premium adjustment, so an annual policy sold before 1 November carries the benefit until renewal at a price that did not include it.
  3. The member's share is capped. The insurer's is not. Basic members pay AED 20 per new outpatient visit, or AED 10 for a referred specialist visit. Flexi members pay 20%, capped at AED 500 per inpatient service and AED 1,000 a year, after which the insurer pays 100%.
  4. Complications carry no time limit. The circular restates the federal duty to cover donor and recipient before, during and after the procedure, including complications whenever they arise or are detected. A liability with no discovery period has to be reserved as one.
Applies to Insurers, third-party administrators and brokers licensed by DoH in Abu Dhabi health insurance, buyers and reinsurers pricing their books, and hospitals planning a transplant service line

The Department of Health in Abu Dhabi issued Circular No. 197/2026, dated 6 October 2026 and listed on its index on 8 October, to every insurer, third-party administrator, broker and provider it licenses in health insurance (DoH circulars).

It adds diagnosis and treatment for organ and tissue transplantation, for donors and recipients, to the Basic and Flexi policies, and applies the federal transplant obligation under Cabinet Resolution 61/2026 to all Basic, Enhanced and Flexible policies "currently valid or to be issued /renewed", from 1 November 2026. That is 26 days after the circular's date, on our count. Our brief on Resolution 61/2026 left the operative date open. In Abu Dhabi, it is now fixed.

How the transplant benefit reached Abu Dhabi policies20 Apr 2026Cabinet Resolution61/2026 issued6 Oct 2026DoH Circular197/2026 dated1 Nov 2026Cover applies topolicies in forceRenewalFirst chance toprice the benefit
01

The benefit arrives in policies already sold

This change does not wait for renewal, when a carrier could reprice. A Basic, Enhanced or Flexi policy written in March 2026 was priced without transplant cover, and from 1 November it carries that cover until it renews (DoH circulars). The circular sets no premium adjustment and no transition period.

The cost of every transplant episode between 1 November and each policy's renewal date falls on a premium set before the benefit existed. For an insurer with a book renewing evenly through the year, part of that book carries the benefit for most of a year without having paid for it.

02

The member's share is capped. the insurer's is not

For Basic policies, the circular adds inpatient transplant care at authorised hospitals to Clause Third of Schedule 1, and outpatient care at authorised hospitals and health centres to Clause Fourth. The member pays AED 20 per new visit, or AED 10 per new visit to a specialist or consultant on a GP referral, and follow-ups within seven days of the first examination are free (DoH circulars).

For Flexi, the member pays 20% of each inpatient service, capped at AED 500 per new service, with an annual copayment limit of AED 1,000, beyond which the insurer covers 100%; outpatient visits carry 20%. On our arithmetic, the AED 500 cap binds on any inpatient service costing more than AED 2,500, and two such services exhaust the annual limit.

Everything above that sits with the insurer for the rest of the year. For Enhanced policies, the circular sets the date and the federal duty but no cost-sharing table of its own.

Get the instruments that touch your licence, assessed, as they are issued. See Regulatory Watch

03

The tail has no end date

The circular restates the federal duty in full. Insurers must cover every service connected to removal and transplantation for donor and recipient, before, during and after the procedure, including complications whenever they arise or are detected, under all schemes in the State (DoH circulars).

Non-compliance is a violation of Law No. 23 of 2005 on health insurance in the emirate. A transplant recipient covered on 1 November who develops a related complication years later is inside a duty with no stated discovery period. That is a long-tail liability attached to a product sold one year at a time.

04

What a buyer of the book should price

For anyone valuing an Abu Dhabi insurer, a TPA or a medical portfolio, the circular changes three numbers. The first is the unpriced period: the months between 1 November 2026 and each in-force policy's renewal, multiplied by the expected transplant cost for that membership. The second is the reserve for complications with no discovery limit, which belongs in the balance sheet, not in next year's loss ratio.

The third is the reinsurance response: whether the treaty covers a tail defined this way. On our reading, a seller who has not modelled all three is presenting a loss ratio the buyer cannot rely on. For hospitals, the circular does the opposite. It gives a transplant service line a defined payer route and defined member cost-sharing, although the circular does not list which hospitals are authorised.

Before your next meeting

Four questions for an Abu Dhabi insurer's board, or its buyer

  1. How many Basic, Enhanced and Flexi policies will be in force on 1 November 2026, and in which month does each renew?
  2. What reserve has the actuary set for transplant complications that may be detected years after the policy has lapsed or moved?
  3. Does the current reinsurance treaty respond to a transplant liability with no discovery period, and has the reinsurer said so in writing?
  4. Has the TPA updated its adjudication rules for the Basic visit fees, the Flexi caps and the seven-day follow-up exemption before claims arrive?

The Monday work for an insurer or its buyer is specific. Pull the in-force Basic, Enhanced and Flexi policy count by renewal month. Ask the actuary what reserve basis applies to complications with no discovery period, and ask the reinsurer in writing whether the treaty responds. Confirm the TPA has loaded the Basic visit fees, the Flexi caps and the seven-day exemption before the first claim. Pricing a book that carries a benefit it was never paid for is the work of our business valuation practice.

This brief covers one instrument. The UAE healthcare regulatory tracker carries the full set — DoH, DHA, EDE and the other emirates — with what each one changes and when it takes effect.

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