From 1 January 2027, a new Abu Dhabi hospital that meets two of three tests must have underground protected capacity designed in from day one. DoH has not yet said what that space must contain, or what it will cost.

The requirement applies where a proposed hospital meets at least two of three criteria: it is planned to provide critical acute or tertiary services, including Level I or II trauma, neurosurgery, cardiovascular and comparable high-acuity surgery; it has a planned licensed inpatient capacity of 150 beds or more; or it gives essential acute cover to a regional or rural area with no comparable acute hospital within approximately 100 kilometres (DoH Circular 202/2026).

On our reading, a 150-bed general hospital in Abu Dhabi city with a cardiac service is in scope, and a 140-bed cardiac centre on the same street is outside it unless DoH treats its location as remote.

The service list is written as "including, but not limited to", and the remote test defers to DoH criteria for rural areas that the circular does not reproduce, so two of the three thresholds carry DoH discretion.

Where the requirement applies, the protected capacity must be built into the hospital's planning and design from the initial development stage, and applicants are told to account for it from the earliest stages of site selection, architectural design, engineering planning and capital development (DoH Circular 202/2026).

The circular adds that applicants "should not rely on subsequent modification of an approved hospital design", and that DoH may ask for evidence of compliance at stages of the licensing and approval process. An underground level is a structural decision that changes excavation, foundations and programme. On our reading, a scheme whose design is frozen without it carries a licensing risk that cannot be fixed later at a price anyone would choose.

DoH will issue detailed technical and engineering requirements for design, construction, equipping, commissioning, activation, operation and maintenance by 1 January 2027, which may cover structural protection, emergency power, ventilation, medical gases, water, fire safety, communications, infection control, surge configuration and activation times (DoH Circular 202/2026). That specification is pending; once issued, it becomes part of DoH's hospital licensing requirements.

The deadline for the standard is the date the obligation begins, so a hospital designed this quarter for filing in January is being designed to a document that has not been published. Size is open too. The circular makes capacity proportionate to licensed services, bed count, emergency role and risk profile, and leaves DoH to decide whether the space supports continuity of existing care, emergency admission, or both.

Subject to DoH approval and building, civil defence and safety rules, the protected area may serve non-clinical uses such as parking during normal operations, provided it can be converted to its emergency clinical function within the required activation timeframe (DoH Circular 202/2026). Normal use must not compromise structural protection, emergency utilities, medical gas and ventilation where applicable, infection control or readiness for activation.

That is the main lever on cost. On our reading, a basement car park already in the scheme carries part of the excavation, and the increment is the protection, the services and the conversion capability. The activation timeframe is one of the items the pending standard will set.

Projects already under development or within the licensing process on the effective date are assessed by DoH case by case, taking account of their stage of design, approval and construction (DoH Circular 202/2026). There is no safe harbour for early filers. For a buyer or lender, every large Abu Dhabi hospital in the pipeline carries an open question until DoH answers it in writing.

Until the standard is issued, a capex model should carry the line as a range with stated assumptions: a base case in which a planned basement car park is upgraded to dual use; an upside in which DoH assigns only the continuity function, for existing patients and surge, with no emergency admission function; and a downside in which DoH requires an emergency admission function on a dedicated level. We put no figure on any of them. The instrument gives none, and an invented benchmark would mislead the one reader who knows the build cost.