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 combined UAE sales exceed AED 300m in the last financial year OR combined market share exceeds 40%. The two triggers are alternatives — either alone bites.
- File at least 90 days before completion. The review period is extendable by 45 days and is interrupted by requests for information.
- 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)·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 14 July 2026 the PD-05-2025 PDF 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 must still be reported fee-for-service with Activity.Net set to zero — only the IR-DRG code carries value.
- Carve-outs paid on top of the bundle: unit-priced drugs above AED 500, implantable or single-item HCPCS above AED 1,500, and outliers.
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
Issued 10 Jun 2026Government of Dubai
Law No. 17 of 2026 (Dubai Longevity Authority)
Creates a regulator licensing the longevity value chain end to end: R&D, clinical trials, manufacturing, delivery and patient-facing clinics.
- Decree No. 14 of 2026 names Sheikh Hamdan bin Mohammed as President.
- Decree No. 15 of 2026 names Helal Saeed Almarri as Chairman.
- Coordinates with the DHA, Dubai Health, Dubai Municipality and the Dubai Future Foundation.
CaveatNo detailed licensing framework has been published as at 14 July 2026. Early press misnamed the body — Gulf News ran it as the 'Dubai Health Sustainability Authority', The National as the 'Dubai Authority for Healthy Longevity'. The law names it the Dubai Longevity Authority.
Primary source: Dubai Government portal — Dubai Longevity Authority·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.
- Since late Dec 2025 the EDE holds 44 MOHAP services in full, 13 shared, with 5 narcotics-related services 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 drug or biopharmaceutical authorisation: 45 working days published, AED 7,000 (plus AED 3,500 analysis, AED 1,000 pharmacovigilance plan, AED 500 pricing certificate). Valid five years.
- Renewal 5 working days; minor variation 22 working days.
- Pricing certificate 90 working days — double the authorisation clock — and it needs Pharmaceutical Pricing Committee approval plus CIF from reference markets.
- 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 '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 rather than administrative hires.
- 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, 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.
CaveatNo 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
