MoHAP has hard-coded organ-donor recruitment into policy. It changes what a UAE transplant programme is worth on a deal.

Since 2017 through June 2026, the Hayat programme has facilitated 1,780 organ transplants from deceased donors: 924 kidneys, 502 livers, 181 lungs, 151 hearts and 22 pancreases, sourced from a cumulative 549 deceased donors (MoHAP, 13 August 2026). The UAE ranks first in the GCC at 13.95 deceased donors per million population, and 2025 donor numbers rose 35.5% against 2024 with transplant activity up 31% over the same period. Demand is not the constraint: MoHAP records more than 4,000 people in the UAE living with chronic kidney failure and waiting on a transplant. Every one of those figures is stated by the Ministry itself, not extrapolated from third-party estimates.

MD 91/2026 puts recognition, therapeutic, insurance and in-kind benefits behind the donor equation (MoHAP, 13 August 2026). Eligible beneficiaries are living donors and their relatives up to the fourth degree, individuals who have documented a wish to donate or made a bequest and their relatives, and the relatives of deceased donors. They are granted priority where an organ or tissue transplant is required, subject to health condition and assessment by the National Centre for Regulation of Human Organ and Tissue Donation and Transplantation. Insurance benefits run to full medical and insurance coverage for living donors for every examination and procedure related to the donation. Therapeutic benefits cover admission, accommodation and continuous post-donation follow-up. In-kind provisions include accommodation near the treating hospital, travel and transport support, work-absence assistance, home-care services, and — for the families of deceased donors — psychosocial support programmes. It is the state doing the recruitment work that a private programme cannot do at scale, and it changes the elasticity of the deceased-donor pool.

MoHAP names the nine accredited transplant centres in the same release (MoHAP, 13 August 2026). In Abu Dhabi, Cleveland Clinic Abu Dhabi performs heart, lung, liver, kidney and pancreas transplants; Sheikh Khalifa Medical City runs liver and kidney transplantation for adults and children; Burjeel Medical City performs kidney and liver transplants. In Dubai, Dubai Hospital covers adult kidney transplantation, Al Jalila Children's Hospital covers paediatric kidney transplantation, Mediclinic handles adult kidney transplants, and King's College Hospital London – Dubai provides adult and paediatric liver transplantation plus adult living-donor kidney transplantation. In Sharjah, Al Qassimi Hospital handles adult kidney transplantation and Medcare Hospital performs adult living-donor kidney transplants. Nine names, not one directory. A target that markets transplant revenue without sitting inside that perimeter is marketing intent, not licensed activity, and the diligence line is which lines the target holds accreditation on, not which lines the marketing deck lists.

For an operator inside the perimeter, MD 91/2026 lifts the ceiling on donor supply without asking the operator to fund the recruitment. State-backed donor recruitment plus the +35.5% deceased-donor growth in 2025 read as a capacity-side tailwind on top-line, priced against nine accredited centres for a population that is already the GCC's most active donor market and shows structural demand growth. For a target outside the perimeter, the same numbers make the accreditation pathway a mandatory diligence step: without it, a stated transplant strategy is a licensing plan, not a revenue plan. For a payer, the state's assumption of insurance coverage for the donation event reshapes the medical-loss ratio on transplant lines and the pricing of donor-side benefits; a private policy that assumed those costs is now overlapping with a public one. For a specialist investor, this is the sequencing signal that composite-tissue and paired-donation licences are the next perimeter — announced by MoHAP as the direction of travel, not dated, and not yet in-force revenue. Booking that optionality on a deal today is a modelling error; missing it entirely is the read that the specialist buyer's diligence exists to prevent.

MD 91/2026 does not sit alone. It runs in an integrated federal architecture with Federal Decree-Law No. 25 of 2023 on Human Organ and Tissue Donation and Transplantation and the executive regulations Cabinet Resolution No. 61 of 2026, together with the standing statutory infrastructure that Hayat has operated under since 2017. The composite-tissue expansion — face, hand, arm, intestine, uterus — that MoHAP has publicly flagged will need its own licensing standard before centres can advertise those services as accredited. Sponsors modelling a UAE transplant thesis should sequence the composite-tissue line behind a dated standard, not ahead of it.