The Dubai free-zone healthcare licence is now a DHA licence, and it does not move on its own.
Executive Council Resolution 49/2024 puts Dubai free zones and the DIFC inside DHA's perimeter, makes the licence non-transferable in a sale, and lets DHA close a facility for three months.
What a board member needs before the next meeting on this.
- Free zones and the DIFC are inside DHA's perimeter now. Resolution 49/2024 covers every Dubai healthcare establishment except federal entities; a zone licence alone no longer means DHA does not apply to you.
- The DHA licence is non-transferable without approval. A change of control needs the regulator's prior consent on the Director General's conditions. Unconfirmed, it is a discount a buyer takes out of your price.
- The real penalty is time, not money. DHA can close a facility, wholly or partly, for up to three months pending investigation. Model the lost revenue and the covenant test, not an expected fine.
- The 2025 manual is the operational document. Administrative Resolution 25/2025 holds the licensing categories and standards. The framework tells you that you are regulated; the manual tells you what compliant means.
For years a healthcare operator in a Dubai free zone could tell itself a comforting story: the Dubai Health Authority regulated the mainland, and the zone regulated the zone. Executive Council Resolution No. (49) of 2024 ended that story. It draws one regulatory perimeter around the practice of health professions and health activities across the whole Emirate, and it names the free zones, the special development zones and the Dubai International Financial Centre inside it.
This matters most to the people who bought or built in a zone precisely because they believed they sat outside DHA's reach. They were not wrong about the old arrangement. They are wrong about the new one, and the gap between the two is where a licence turns out to be worth less than the balance sheet assumed.
The perimeter now includes the zones everyone treated as outside it
Resolution 49 applies to every establishment providing healthcare services in Dubai, including those in free zones, special development zones and the DIFC. The only carve-out is federal government entities and their affiliated facilities. No facility and no professional may practise without a permit from the DHA, and a facility may not employ an unlicensed professional or a visiting doctor without prior approval. For a clinic that has run for years under a free-zone health authority alone, this is not a tightening of a rule it already followed. It is a second regulator it had assumed was absent, with its own permit and its own inspectors.
A licence you cannot move is a licence you do not fully own
The resolution makes DHA licences valid for one renewable year and, more consequential for anyone contemplating a sale, non-transferable without the DHA's prior approval on conditions set by the Director General. In a share sale the operating entity does not change, but a change of control still reaches the approval the resolution reserves to the regulator. A buyer's counsel finds this in the first week of diligence. The seller who has not confirmed in advance that the operating permit and the physician licences survive a change of ownership is selling an asset with a conditional core, and the discount for that condition comes out of the price rather than the buyer's return. This is the same portability trap that decides healthcare deals across DHA and DoH jurisdictions; Resolution 49 writes it into statute for every zone in Dubai.
The closure power is the part boards underprice
Resolution 49 gives the Director-General and the Medical Practice Committee the power to close a facility, wholly or partly, for a period that can extend to three months while a suspected violation is investigated, and to suspend a professional for the same period. A three-month partial closure is not a fine that lands as a line item. It is a hole in a quarter of revenue, a covenant test put at risk, and a data-room document a buyer reads as recurring exposure. Boards that model regulatory risk as the expected value of a penalty are pricing the wrong instrument. The instrument here is time, and time is the one input a leveraged healthcare business cannot refinance.
Administrative Resolution 25 of 2025 turned the framework into a checklist
The 2024 resolution set the perimeter; Administrative Resolution No. (25) of 2025 approved the manuals and protocols for actually practising under it. That is the document an operator opens on Monday, because it holds the licensing categories and the standards that apply to each. Reading the framework tells you that you are regulated. Reading the manual tells you what compliant looks like for your specific activity, and where your current setup diverges from it.
Four questions before your next Dubai healthcare deal or inspection
- Does our free-zone or DIFC facility hold, or now need, a DHA permit under Resolution 49?
- Have we confirmed our operating and physician licences survive a change of control?
- What would a three-month partial closure do to our revenue and our covenants?
- Where does our current setup diverge from Administrative Resolution 25 of 2025?
The practical test is short. If your facility sits in a Dubai free zone or the DIFC and your licensing file still assumes DHA is someone else's regulator, that file is out of date, and every month it stays out of date is a month of accrued exposure that a buyer or an inspector can price. Confirming where your permits and their transferability stand under Resolution 49 and its 2025 manual is the first move, and it is exactly where our market access and regulatory practice begins.