Issued 20 Apr 2026; in force three months after gazette publication, which law firms date to 30 Jul 2026Ministry of Economy & Tourism
Cabinet Decision No. 59 of 2026 (executive regulations to Federal Decree-Law No. 36 of 2023)
Mandatory, suspensory merger control. A qualifying deal must be notified and cannot complete until cleared.
- Notify if the parties' combined annual sales in the relevant market inside the UAE exceed AED 300m in the last fiscal year, OR their combined share exceeds 40% of that market. CD 3/2025 says 'any of': either alone bites. The sales test is relevant-market sales, not the group's total UAE turnover.
- File at least 90 days before completion (Art. 12(1) of the Decree-Law). Separately, the Minister has 90 days from a complete application to decide, extendable by 45 (Art. 13(2)). A review can therefore run 135 days and outlast the filing lead time you planned around.
- Cabinet Decision No. 105 of 2026 prices the filing: 0.02% of the participating undertakings' total annual sales, capped at AED 150,000. An objection costs AED 1,500. A grievance costs AED 500, refunded if it succeeds.
- Third parties have 15 working days from publication of the deal's basic information to object.
- Silence is rejection. A failure to decide within the period is deemed a refusal, not a deemed approval.
CaveatCommentary circulating in the market reads the two thresholds as cumulative and describes the 40% test as applying to the merged entity. Both are wrong. The text says 'any of' and measures the parties' combined pre-merger share.
Primary source: Ministry of Economy — competition legislation (CD 59/2026; thresholds in CD 3/2025; fees in CD 105/2026)·Our brief: What it does to a healthcare deal
Issued 27 Oct 2025; effective 16 Nov 2025Dubai Health Insurance Corporation, under the DHA
Policy Directive PD-05-2025 (Dubai health insurance claims management)
Governs claims for every insurer, TPA and licensed provider in Dubai. The Dubai Government Insurance Program is expressly exempt.
- 141-day claims submission-and-settlement cycle.
- Remittance advice and payment within 45 calendar days of claim submission; 30 days on resubmission.
- 0.03% of the net claimed amount per day as a delay fee — payable by the provider on late submission, and by the insurer on late payment.
- Pre-authorisation: 6 hours for elective outpatient, 24 hours for elective inpatient, immediate for emergencies with written confirmation inside 24 hours.
- Penalties: AED 50,000 per claim for failing to follow the DHA's claims procedures; AED 20,000 per incident; AED 10,000 for general non-compliance. Any violation can carry suspension or revocation of the operating permit.
CaveatAs at 2 September 2026 the PD-05-2025 PDF still returns a 404 on the ISAHD portal and its link is commented out of the page source, while PD-01 to PD-04 still resolve. No circular repealing or replacing it has been published. We verified against the archived official PDF. Confirm the directive's current status with DHIC before relying on it.
Primary source: DHIC / ISAHD — PD-05-2025·Our brief: Why billing became a licensing matter
1 Nov 2025Department of Health, Abu Dhabi
IR-DRG for day cases, under the DoH Mandatory Tariff and Claims & Adjudication Rules V2025.1
Ambulatory surgical and medical procedures are paid per episode on an IR-DRG grouping, not per line item. Coding now sets the price.
- Mandated for all inpatient and daycase encounters except dental, across all products.
- Activities are still reported fee-for-service with Activity.Net set to zero, except the IR-DRG code, service code 99 for the outlier payment and service code 98 for the HCPCS high-cost add-on. Three codes carry value, not one.
- The carve-outs are narrower than they read. For a single-item or implantable HCPCS above AED 1,500, only the amount in excess of AED 1,500 is reimbursed separately. For a daycase drug in the Unified Procurement Program above AED 500, only the markup is. Outliers are paid on service code 99.
- Below that line drugs are absorbed: outside long-term care, a single drug not exceeding AED 500 accumulative across the stay sits inside the bundle.
CaveatThe relative weights sit in the Mandatory Tariff, which DoH updates. V2025.1 sets no periodic reweighting cadence of its own.
Primary source: DoH — Claims and Adjudication Rules V2025.1·Our brief: How it moves day-case margin
Signed 6 Jun 2026; published in Official Gazette issue 780 on 13 Jun 2026 and in force from the date of publication (Art. 27)Government of Dubai
Law No. 17 of 2026 (Dubai Longevity Authority / سلطة دبي للديمومة الصحية)
Creates a regulator that permits the longevity value chain: advanced and applied therapies, R&D and laboratory and clinical trials, therapeutic and preventive services, and the promotion, marketing, sale or distribution of longevity products.
- Article 7(a): no natural or legal person may carry on the Activity anywhere in the Emirate without a permit from the Authority — expressly including the special development zones and the free zones, the DIFC among them. The law contains no transitional or grandfathering article.
- Article 8: the Authority permits facilities; the DHA permits individual professionals under Executive Council Resolution No. 49 of 2024, and the Authority's approval is required before those permits issue.
- Article 19: the Chairman of the Executive Council sets the violations and the fines. Alongside a fine the Authority may suspend a permit for up to six months, or cancel it and coordinate with the commercial licensing authority to cancel the trade licence.
- Article 22: 30 days to file a grievance, decided within 15 days, and the committee's decision is final.
- The Concerned Entities are the DHA, Dubai Academic Health Corporation, the Department of Economy and Tourism, and Dubai Municipality (Art. 2).
- Decree No. 14 of 2026 names Sheikh Hamdan bin Mohammed as President; Decree No. 15 of 2026 names Helal Saeed Almarri as Chairman.
CaveatThe permit conditions are left to a board resolution under Article 7, so the perimeter is live while the mechanics are not. On the name: Article 1 titles the law in Arabic as سلطة دبي للديمومة الصحية, which renders literally as Dubai Health Sustainability Authority, against the English Dubai Longevity Authority. Both are official and the pair is not a literal translation, so the Gulf News rendering followed the gazetted Arabic rather than misnaming the body. Use whichever form matches the language of the document you are drafting.
Primary source: Official Gazette of the Government of Dubai, year 60, issue 780, 13 June 2026 — Law No. 17 of 2026 (Arabic)·Our brief: Whether your clinic now sits inside the perimeter
Announced 24 Feb 2026. The underlying duty took effect 2 Jan 2025 with a one-year grace period that expired 2 Jan 2026.Emirates Drug Establishment
Multi-agent rule for medical products, under Federal Decree-Law No. 38 of 2024
Ends the single exclusive agent. A marketing authorisation holder must appoint more than one authorised agent per medical product — a term that reaches devices and biologicals, not only pharmaceuticals.
- Article 22 requires at least two importers and one or more distributors.
- MOHAP's transfer page lists which services moved to the EDE and which are held jointly, but publishes no count of either. The service tallies circulating in the market are not the ministry's numbers.
- Permits for the possession and handling of controlled materials and products are listed as joint jurisdiction, not as retained by the ministry.
- Community and compounding pharmacies remain with MOHAP.
CaveatExecutive regulations implementing Article 22 have not been issued. The obligation is live; only the mechanics are pending. Do not read the missing guidance as a missing deadline.
Primary source: MOHAP — transfer of services to the EDE·Our brief: What it does to distributor value
EDE took the register at end-Dec 2025Emirates Drug Establishment
Marketing authorisation for medical products, under Federal Decree-Law No. 38 of 2024
One standard eCTD authorisation route, scaled by product class. There is no abridged or verification pathway for products already approved by the FDA, EMA, MHRA or PMDA.
- New authorisation: 45 working days published. AED 100 application and AED 7,000 for the authorisation, plus AED 3,500 analysis, AED 1,000 pharmacovigilance plan and AED 500 pricing certificate after committee approval. The certificate runs five years, or for whatever validity the EDE grants.
- Renewal is 15 working days at AED 100 plus AED 2,500. A minor variation is 22 working days at AED 1,000.
- Re-pricing a single product is its own service: 90 working days at AED 1,000, twice the authorisation clock, needing Pharmaceutical Pricing Committee approval against reference prices from GCC and European markets. The pricing certificate issued alongside an authorisation publishes no duration of its own.
- All five eCTD modules for a new chemical entity, biological or biosimilar; a reduced set for generics. Product class drives the dossier, not prior approval abroad.
- GCC centralised registration is the one real recognition route: UAE expiry is set five years from the first GCC certificate.
CaveatThe GCC centralised-registration line above is drawn from GCC rules rather than from an EDE service page; confirm it with the EDE before building a timeline on it. The 'abridged/verification pathway' widely sold for the UAE is Saudi Arabia's — the SFDA publishes a pathway of that name citing those same regulators. No UAE instrument or EDE document contains one. EDE approved AstraZeneca's baxdrostat first in the world in May 2026, which is not the behaviour of a regulator relying on others. The statute's fast-track route was deferred to executive regulations that have not been issued.
Primary source: EDE — marketing authorisation service (fees, durations, eCTD structure)·Our brief: Why the verification route is a myth
Announced 16 Jun 2026; compliance assessed from the start of 2027MoHRE, with MoHAP
Emiratisation amendment for specialised healthcare roles
Half of a private healthcare facility's annual 2% Emiratisation target must go to specialised healthcare roles; the other half covers the sector's remaining skilled positions.
- Applies to facilities with 50 or more employees.
- Half the target in the first half of the year, the balance in the second.
- More than 8,800 Emiratis worked in private healthcare at end-2025, 82% of them women.
CaveatMoHRE has published no penalty amount specific to this rule, and no gazetted instrument number. The AED 10,000 per month per unfilled skilled position that runs from 1 July 2026 belongs to the general Emiratisation regime — treat it as the order of magnitude, not as this rule's tariff. The qualifying professions are MoHAP's approved health professions, which MoHRE's text does not enumerate.
Primary source: MoHRE — 16 June 2026 announcement·Our brief: The 18-month hiring window
Amendment approved 19 May 2026Sharjah Executive Council / Sharjah Health Authority
Executive Council Resolution No. 29 of 2025 on the regulation of practising healthcare activities and professions, as amended (Sharjah)
Adds administrative penalties across government-affiliated, private and free-zone facilities in Sharjah, and the professionals inside them.
- The SHA licenses facilities and professionals in its own right, including the Assessment Certificate issued through its Request for Healthcare Professional Assessment service.
- The SHA was established by Emiri Decree No. 12 of 2010, amended by Emiri Decree No. 33 of 2016.
CaveatThe two points above come from the SHA's own material, not from the Executive Council report cited here. No schedule of penalty amounts has been published. There is also no published programme migrating facilities from MOHAP to the SHA on a stated timetable, despite consultancies describing one — verify which regulator holds each licence site by site.
Primary source: Sharjah24 — Executive Council amends the resolution·Our brief: Map your Sharjah sites
