Bahrain

“It’s not where you take things from – its where you take them to.” – Jean-Luc Godard AI-generated artworks have been contentious in recent times, particularly as the internet witnessed a wave of Studio Ghibli-styled artwork and the likes, which now appear across sectors –from ephemeral uploads on personal social media platforms, to restaurant menus and for other large-scale advertising, marketing and/or commercial strategies– raising an underscoring question: “who holds the rights to AI-generated works?” This article explores the controversial question of ownership and inventorship in works generated by artificial intelligence (AI) and provides key insights on the contemporaneous approaches to AI innovation. Prior to further investigation, it is essential to recognise that this abstraction falls within the ambit of intellectual property (IP) law wherein IP is defined to refer to “[…] creations of the mind, such as inventions; literary and artistic works; designs; and symbols, names and images used in commerce”.[1] Derived from this sphere of law, people have protected their imagination and gained social or financial recognition through their IP rights, in line with Article 27 of the Universal Declaration of Human Rights.[2] As the international body for IP information and policy, the World Intellectual Property Organisation (WIPO) supports developing and implementing international law on IP, including through key treaties such as the Paris Convention, the Berne Convention, and the Patent Cooperation Treaty (PCT). International and national laws protect various types of IP –namely, patents, industrial design, trademarks, copyright and related rights. With the disruptive and transformative nature of technology and digital infrastructure, WIPO has had to confront challenging questions regarding the regulation of the innovation ecosystem. Particularly, innovations within AI algorithms have raised curiosities regarding AI’s role in the invention process and, thereby, the larger role of the IP legal ecosystem in addressing these uncertainties. Since its launch in November 2022, ChatGPT has become a landmark development in generative AI (GenAI), drawing unprecedented global attention to the field. From concerns on AI outputs and copyright-related infringements, to current debates regarding ownership of AI-generated works, existing IP frameworks struggle to provide clear answers or vary on technical grounds, and these issues are being litigated across the globe. In its factsheet, WIPO recognises “Generative AI tools can create new content, such as text, computer code, images, audio, sound and video, in response to a user’s prompt, such as a short, written description of the desired output. Current examples of generative AI tools include ChatGPT, Midjourney, Copilot and Firefly”.[3] The use case of AI in the invention process has been categorised into the following:[4] i. As a new model of invention ii. As a tool utilised by humans for or in invention iii. As an incorporative feature of the invention iv. As an autonomous generator of material without human input In its perspective, WIPO highlights that AI is a subject matter which triggers concern for mainly two types of IP –copyright and patents.[5] For the purpose of this article, the primary focus lies on the intersection of AI and IP law to delve into the idea of invention and evaluate legal developments. The question of ownership of AI-generated creations especially arises within patenting, wherein AI tools are commonly used for the generation or production of work. This may be in the form of assistance further to human intervention or autonomously generated without human intervention. 2019 witnessed a rapid incline of AI-related patenting, with over half of the inventions identified having been born in scientific publications as early as 2013.[6] Given that IP laws encompass both intangible aspects (corpus mysticum) and tangible objects of creation, innovation or distinction (corpus mechanicum), the use of AI in invention falls under current IP frameworks. However, coupled with the evolving understanding of AI’s role in the invention process, national IP frameworks grapple with the consideration of AI as an inventor. At the heart of IP is the principle of exclusivity – awarding authors, creators or inventors with the right to their creation. This principle ensures that the right-holder determines how their creation may be used and prevents others from commercially exploiting the same without permission. This trickles down into a time-bound right for patent owners, and the same for copyright-holders which later enters the public domain for free use. In its wake, GenAI has unsettled traditional IP laws and raised questions about potential legal challenges. The following sections discuss the legal challenges, followed by the implications of AI intervention as an autonomous inventor, referring to a relevant case study. An interrogation of the legal landscape As mentioned above, the definitional scope of IP incorporates different rights for traditional IP, supported by legal frameworks, and was previously created with the intention to address and protect the creations of individuals without consideration of AI-generated work. Resultantly, it is an unexplored and grey area in the contemporary legal terrain. As with most IP rights, the protection availed is territorial in nature, which unveils the uncertainties that are bound to arise from the lack of harmonious interpretation on AI-generated works. This discrepancy especially harms transnational businesses and activities. Advertently, as evidenced by the DABUS claims discussed in detail below, seeking clarity by resorting to forum shopping. Implications on various IP rights arise as the training process for AI involves data mining/data scraping and other IP-protected data alongside potentially harmful and/or illegal content. AI models often rely on copyrighted material without clear accountability for authorship or protection against infringement. This reveals friction between holders of IP rights and AI investors compounded with the legal uncertainty, such as whether using copyright-protected material in training AI constitutes the infringement of copyright protection. Data insecurity caused by inappropriate and illegal outputs produced by GenAI–such as biased, discriminatory and harmful content. An invention of AI? The burning question–can AI be considered as an inventor?–is sought out in a pioneering series of patenting claims surrounding DABUS, where one Stephen Thaler created an AI machine, Device for Autonomous Bootstrapping of Unified Sentience (DABUS), and filed for national patent applications, naming DABUS as the inventor. Thaler claims that the machine is to be credited for two inventions, i.e., Fractal food and beverage container Fractal light-flashing device With the initiation of litigation in over fifteen jurisdictions and pending appeals, presented below is an overview of initial multi-jurisdictional responses: i. Australia The case of Thaler v. Commissioner of Patents,[7] wherein the Deputy Commissioner of Patents determined that the patent applicant did not comply with Regulation 3.2C(2)(aa) of the Patent Regulations. At the first appellate instance, the Court allowed an AI machine to be named as an inventor, keeping it consistent with current technological reality. The decision was overturned in 2022, with the Federal Court ruling in favour of the Commission of Patents, deeming the Deputy Commissioner’s conclusion as correct, i.e., that the application was inconsistent with the regulation by naming DABUS as an inventor.[8] In the same year, the appeal made to the High Court was rejected. ii. New Zealand Thaler applied for a patent in New Zealand in May 2021. Following the Assistant Commissioner of Patents’ refusal to accept the patent application based on permitting exclusively human inventorship. In appeal, the High Court of New Zealand takes account of similar overseas applications in parallel, namely Australia, United Kingdom, and the United States of America,[9] and in its judgment dated 17 March 2023,[10] held that it deemed it inappropriate for the Court to expand the definition of an inventor through statutory interpretation. Accordingly, the appeal was dismissed.  iii. United Kingdom In 2018, Thaler filed two patent applications for the inventions, stating that he was not the inventor. A year later, the Hearing Officer issued a decision on behalf of the Comptroller, holding that DABUS was not a person as envisaged in the statute, with no entitlement to grant a patent to Thaler on the grounds of owning DABUS, and called for withdrawal of the applications. Subsequently, in the appeal before the High Court, the application was deemed deficient. The consequent appeal was also dismissed.[11] Lastly, the appeal before the Supreme Court was dismissed,[12] noting that the Court did not err in its decision and affirmed the Comptroller’s decision.  iv. United States of America In Thaler v. Hirshfeld et. al., the plaintiff approached the Court with a one-count complaint against the defendants’ refusal to recognise an AI machine to be an inventor under the Patent Act.[13] In 2021, the District Court reviewed the legislative language of the statute and ruled in favour of the United States Patent and Trademark Office (USPTO), refusing the application. However, the Court recognised that “As technology evolves, there may come a time when artificial intelligence reaches a level of sophistication such that it might satisfy accepted meanings of inventorship. But that time has not yet arrived, and, if it does, it will be up to Congress to decide how, if at all, it wants to expand the scope of patent law”.[14] Despite upholding USPTO’s decision in the Federal Circuit Court, Thaler approached the Supreme Court with the core question of whether “the Patent Act categorically restrict(s) the statutory term ‘inventor’ to human beings alone”, resulting in the refusal of the petition. In lieu of these developments, USPTO also published new guidelines clarifying that for patentability, the inventor must be a natural person and filed guidance relating to the use of AI and outlining legal and ethical responsibilities of users.[15] Thaler also traversed into copyright law in Thaler v. Perlmutter wherein the plaintiff approached the Court following the refusal by the United States Copyright Office (USCO) to register an AI-generated artwork as a creation autonomously generated by an AI algorithm. The main issue was whether such autonomously generated work by an AI system, ‘Creativity Machine’, with a lack of human authorship, could be copyrighted. Rendering its judgment in 2023, the Court affirmed the denial by USCO and emphasised on the fundamental prerequisite of human creativity for copyright protection.[16] Regarding patent filing, it should be noted that South Africa was the first jurisdiction to recognise DABUS as an inventor through its patent office’s acceptance of the patent application, though this was through an examination on formality rather than a substantive review. Since then, Saudi Arabia’s patent office has also accepted Thaler’s application listing DABUS as the inventor, though the implications of this decision within the broader GCC patent framework remain to be fully determined. At a regional level, while the European Patent Office (EPO) has addressed AI inventorship cases, it maintains that under the European Patent Convention (EPC), inventors must be natural persons, though it has also recognised that owners of AI systems may have certain rights in the patent application process.[17] The DABUS litigation exemplifies the fundamental challenges in reconciling traditional IP frameworks with emerging AI technologies. While some jurisdictions like South Africa and Saudi Arabia have recognised AI inventorship, most major jurisdictions have resisted, citing the need for human involvement in inventorship and authorship. This reflects a broader challenge within IP law to reconcile traditional legal frameworks with the growing capabilities of AI. The situation highlights the necessity for legislative updates and international cooperation to address the evolving landscape of AI in intellectual property. The U.S. Court’s recognition of potential future scenarios where AI could meet inventorship criteria suggests a possible shift in the legislative and judicial approach in the future, depending on technological advancements and societal acceptance. Important to note is Thaler’s petition before the U.S. Supreme Court, in which he calls attention to a looming issue: “AI-generated inventions are increasingly important in many sectors of the economy. But without a reliable ability to patent their breakthroughs, companies large and small will have little protection for the significant investments they must make in research and innovation […]”.[18] To summarise, an assessment of these country profiles reflects the confines within which national courts have approached the case, mindful of the gravity and relevance of the matter from a jurisprudential point of view, while tackling the specific issues raised before the relevant court. The point of “who or what is the inventor?” is a matter influencing innovation and economic growth.[19] This legal discourse has inspired and run parallel to examining its ethical implications. Below are salient questions and points stemming from existing legal action and research: Are AI-generated works considered as derivative or original? How would an artist be credited and how would one’s contribution be quantified for just attribution? On a related note, is it ethical to use works that have undefined origins? AI-generated works may negate the incentivisation of producing artwork or creations that an individual would profit from, and potentially their heirs by extension. Further, how would this impact the market value of artists whose works or contributions chip into AI training sets? From a creative standpoint, what would be the cultural and social impact of creations produced by GenAI? Could this gradually result in a homogeneous style of art? How might the role of AI-generated inventions or creations devalue human creativity and innovation? Given that AI models are trained on existing information and material, including personal information, IP-protected materials, or sources that are not credited, this allows for the preservation and proliferation of societal bias and illegal content. To illustrate, Prisma Labs was charged with a class action lawsuit for the breach of personal information through unlawful data collection and illicit storage of such data. Lensa AI, under the company, was marketed as an app for editing and retouching, requiring individuals to upload selfie images to be processed as an artistic image. In addition to biometric extraction, the app often generated highly sexualised images of women.[20] It is integral to connect these curiosities with concrete solutions and as a starting point for exploration, engagement, and the development of this subject matter. Given the scholarship on these contemporaneous concerns from the WIPO and other key interlocutors, the upcoming segment is forward-looking. From a Bahraini law perspective In Bahrain, as in many jurisdictions, the question of who owns AI-generated creations is nuanced and involves interpretations of existing intellectual property laws. Bahrain’s IP framework is governed by Law No. 1 of 2004 on Patents and Utility Models, Law No. 6 of 2006 on Industrial Designs, and Law No. 22 of 2006 on Copyright and Related Rights, and is further influenced by international treaties and agreements, including the TRIPS Agreement, the Paris Convention, and the GCC Patent System, demonstrating its integration with both global and regional IP protection mechanisms. However, specific provisions addressing AI-generated works are not yet clearly defined in Bahrain's legal system. Copyright Law: Under Law No. 22 of 2006, Bahrain’s copyright law traditionally requires a human author for protection. Works must result from human creativity and originality, as defined in Article 1 of the law. Therefore, AI-generated works without human intervention may not qualify for copyright protection under current laws. If an AI tool is used as an instrument by a human creator, the human’s contribution could be recognised, allowing for copyright protection of the resultant work. Patent Law: Under Law No. 1 of 2004, Bahrain’s patent law, like many other jurisdictions, defines an inventor as a natural person, and requires that inventions meet the criteria of novelty, inventive step, and industrial applicability. Therefore, AI cannot be named as the inventor under the current patent framework. Innovations created using AI tools would need to have a human inventor who contributed to the inventive process, even if AI played a significant role in the creation. Policy and Legal Development: As AI technology evolves, Bahrain, in line with its Economic Vision 2030 and commitment to digital transformation, may need to consider legislative updates to address the unique challenges AI-generated creations pose, particularly within the framework of existing IP laws. This could involve redefining authorship and inventorship criteria to accommodate AI’s role in creative and inventive processes. In summary, under current Bahraini law and in accordance with Law No. 22 of 2006 and Law No. 1 of 2004, AI-generated works face significant challenges in obtaining IP protection unless there is substantial human contribution to the creative or inventive process. As the technology and its applications continue to develop, Bahrain may look to international practices and consider reforms to address these emerging issues effectively. Considerations and Conclusion In the pursuit of creating a comprehensive and competent legal landscape that is conducive for innovation, the following strategic considerations are a step towards carefully interlacing the worlds of AI and IP: Uphold the fundamental principles of IP law to protect human creativity and innovation, while maintaining appropriate incentives for continued technological advancement. Reassess and redefine the criteria for IP protection under Bahraini law to ensure effective and equitable measures regarding authorship, creation, and inventorship in the contemporary AI landscape with AI. Foster international cooperation, particularly within the GCC framework, to maximise benefits and minimise risks while developing trustworthy AI systems that comply with regional and international IP standards.[21] Anticipatory governance steered by diverse and forward-looking AI governance practices. While still in early stages of development, several jurisdictions have established leading practices and valuable precedents on AI governance.[22] Policy development, broadly based on an interrelated tripartite classification: Advocate for multi-stakeholder engagement, including government entities, private sector, and academic institutions, in developing and updating IP policies and laws to establish robust governance mechanisms aligned with Bahrain’s legal framework. Simultaneously, promote investment in AI research and development in accordance with the Economic Vision 2030. Monitor and evaluate global approaches and policies, shaping legal jurisprudence and affecting well-rounded international standards and practices. Develop comprehensive legal policies under Bahraini IP law regarding ownership and licensing of AI-generated works, while establishing clear protective frameworks that define and safeguard individual contributions to AI-assisted creative processes. Prioritise ethical considerations when targeting the intersection of AI and IP to establish sustainable and responsible AI systems. To achieve this, governments are and should implement national strategies and ethics frameworks.[23] For instance, the implementation of human-centred values and fairness,[24] and initiatives to reduce AI bias.[25] To conclude, this niche area demands extensive consideration to harness the ethical and responsible use of GenAI. As of 2020, more than 340,000 AI-related patent applications had been filed globally since the emergence of AI technology, accompanied by over 1.6 million scientific publications in the field.[26] There is no question about the immense potential presented by AI technology. In light of the rollout of legal battles into other areas of IP, it is imperative to expedite the development of comprehensive legal frameworks that address the evolving IP ecosystem. Integrating artificial intelligence into the realm of intellectual property presents a complex array of challenges and opportunities. As AI continues to advance and generate creations that blur the lines between human and machine input, existing IP frameworks are tested and often found wanting. Recent landmark cases such as DABUS (Device for Autonomous Bootstrapping of Unified Sentience) in multiple jurisdictions, including the 2021 South African patent grant and subsequent global rejections, illustrate the ongoing challenge of defining inventorship and authorship in the age of AI. Courts and legislators face the daunting task of balancing the protection of human creativity with the recognition of AI’s contributions. Under Bahraini Law No. 1 of 2004 on Patents and Utility Models, as well as Law No. 22 of 2006 on Copyright and Related Rights, and similar to other jurisdictions such as the United States, current IP frameworks explicitly require human inventorship or authorship for IP protection, underscoring the need for legislative evolution to accommodate technological advancements. Moving forward, a harmonised approach between regional bodies (particularly the GCC Patent Office under the GCC Patent Regulation, the EU, and ASEAN) and international organisations (such as WIPO), coupled with ethical considerations, Bahrain’s Economic Vision 2030 objectives, and innovative policy development, is essential to create a cohesive legal landscape that fosters innovation while safeguarding the rights of creators across jurisdictions. Only through such measures can we adequately address the transformative impact of AI on intellectual property and ensure a sustainable future for both human and AI-generated innovations. Authors: Saad Al Doseri Srivani P. Nair [1] World Intellectual Property Organization (WIPO), What is intellectual property? (WIPO publication no. 450(E), 2020), p.1. [2] Universal Declaration of Human Rights (adopted 10 December 1948 UNGA Res 217 A(III) (UDHR) art 27. [3] WIPO, Generative AI: Navigating Intellectual Property (WIPO, 2024), p.2. [4] WIPO, Getting the Innovation Ecosystem Ready for AI: An IP policy toolkit (Geneva, 2024), p.12. [5] WIPO, ‘Conversation on Intellectual Property and Artificial Intelligence’ (Second Session, May 2020). [6] WIPO, WIPO Technology Trends 2019: Artificial Intelligence (Geneva, 2019), p.14. [7] Thaler v. Commissioner of Patents [2021] FCA 879. [8] Commissioner of Patents v. Thaler [2022] FCAFC 62. [9] Thaler v. Commissioner of Patents [2023] NZHC 554, para. 15-21. [10] Ibid., para 33. [11] Thaler v. Comptroller-General of Patents, Designs and Trade Marks, [2021] EWCA Civ 1374. [12] Thaler v. Comptroller-General of Patents, Designs and Trade Marks, [2023] UKSC 49. [13] Thaler v. Hirshfeld et. al., No. 1:20-cv-903, 2021 WL 3934803. [14] Ibid., para 130. [15] See Department of Commerce, Guidance on Use of Artificial Intelligence-Based Tools in Practice Before the United States Patent and Trademark Office (Federal Register Vol. 89, No. 71, April 2024). [16] Thaler v. Perlmutter, No. 1:22-cv-01564 (D.D.C. Aug. 18, 2023) (2023). [17] See Thaler v. Vidal; Petition for Writ of Certiorari, p.31, available at: . [18] Ibid., p.28. [19] Supra note 16, p.2. [20] Flora et. al. v. Prisma Labs Inc., 3:23-cv-00680, (N.D. Cal.). [21] OECD AI Principles (May 2019). [22] OECD, ‘Steering AI’s Future: Strategies for Anticipatory Governance’ (OECD Artificial Intelligence Papers No. 32, OECD Publishing, February 2025). [23] OECD, ‘The State of Implementation of the OECD AI Principles Four Years On’ (OECD Artificial Intelligence Papers No. 3, OECD Publishing, October 2023). [24] Ibid., p.15. [25] Ibid., p.34. [26] WIPO, WIPO Technology Trends 2019: Artificial Intelligence (Geneva, 2019), p.13.

His Majesty King Hamad bin Isa Al Khalifa, King of Bahrain, has ratified and promulgated Law No. (23) of 2025, implementing significant amendments to Bahrain’s Commercial Law, originally issued by Decree-Law No. (7) of 1987. These amendments, approved by both the Shura Council and the House of Representatives, aim to modernise and strengthen the legal framework governing commercial transactions, particularly focusing on cheque regulations. Key Amendments: Joint Account Holder Regulations: The revised Article (283) Clause (4) mandates that upon the death or legal incapacitation of a joint account holder, the remaining holders must inform the bank of their intention—whether to continue or close the account within ten (10) days. The bank is required to freeze the deceased or incapacitated person’s share as of the date of death or incapacity until a legal successor is appointed by the competent Sharia or civil court, ensuring clarity and security in joint account management. Cheque Certification and Payment: Changes to Article (451) detail enhanced procedures for cheque certification. The drawee may certify cheques wholly or partially and must do so upon request if sufficient funds are available. Certified cheques have their cover frozen, ensuring funds remain available for the holder until the cheque presentation deadlines expire. Partial Payment of Cheques: A new dimension is added with Article (465 bis), allowing drawees to make partial payments if the account balance is less than the cheque value, unless the holder refuses. This provision aims to minimize cheque dishonours and improve payment flow, with the Central Bank of Bahrain empowered to regulate the procedures. Legal Enforcement of Cheques: Article (465 bis 1) establishes that cheques marked for insufficient funds or partial payment are enforceable documents under the Execution Law in Civil and Commercial Matters. This strengthens the legal standing of such cheques, enhancing creditor protection. Prohibition and Penalties: Article (491 bis) introduces strict penalties for the misuse of blank cheques, including fines ranging from two hundred to ten thousand dinars, depending on the infraction. This aims to deter the use of cheques as credit or guarantee instruments, aligning with consumer protection efforts. Partial Payment and Enforceability of Cheques Bahrain has implemented a partial payment mechanism for cheques. Pursuant to Article 465 bis, where the drawer’s account holds insufficient funds to cover the full value of a cheque, the drawee bank must make partial payment of the available amount to the bearer, unless the bearer refuses such partial payment. In such cases, the bank is required to mark the cheque to reflect the partial payment, return the original cheque to the bearer, and issue a certificate confirming the amount paid. The remaining funds — whether constituting full or partial payment — must be frozen by the drawee bank and held under its responsibility for the benefit of the cheque bearer until the expiry of the cheque’s presentation period, which is six (6) months from the date of issuance, as prescribed under Article 451(4). Once this period lapses, the bank is no longer permitted to process the cheque or make any payments against it, even if sufficient funds become available at a later stage, as per Article 451. In such cases, the bearer must resort to the Execution Court, as the amended law now recognises the cheque as an enforceable instrument under the Civil and Commercial Execution Law (Decree-Law No. 22 of 2021). This allows the bearer to apply directly for enforcement without the need to first obtain a judgment through ordinary civil proceedings. These amendments aim to protect the rights of cheque bearers while reducing reliance on criminal proceedings against drawers. Previously, where a cheque was issued without sufficient funds, the standard procedure was to file a criminal complaint under Article 393 of the Penal Code (Decree-Law No. 15 of 1976), which often led to lengthy proceedings and, in some cases, custodial sentences or fines. Such outcomes could delay or prevent repayment, especially where imprisonment impacted the drawer’s financial position, thereby diminishing the bearer’s chances of recovery. By allowing partial payments, the reform enhances confidence in cheques as a means of payment, promotes commercial efficiency, and helps relieve pressure on the criminal justice system by shifting such disputes towards civil enforcement procedures. Criminalisation of Blank Cheques The recent amendments introduce an explicit prohibition on issuing blank cheques intended to serve as instruments of credit or security. Any person who issues a blank cheque as a credit or guarantee instrument in contravention of Article 491 shall be subject to a fine of not less than two hundred Bahraini Dinars (BD 200) and not exceeding two thousand Bahraini Dinars (BD 2,000). Moreover, where a bearer completes the details of a blank cheque and presents it for encashment, the bearer is liable to a fine of no less than 10% and no more than twice the amount entered on the cheque. In all cases, the fine must not be less than BD 500 and may not exceed BD 10,000. The Ministry of Industry, Commerce and Tourism, being the competent ministry responsible for consumer protection under Law No. (35) of 2012, has been assigned responsibility for receiving and acting upon complaints against non-financial institutions that breach the relevant provisions, in accordance with Law No. (35) of 2012 concerning Consumer Protection. This measure forms part of broader efforts to promote good governance and uphold consumer rights. By contrast, financial institutions engaged in lending or financing activities remain under the direct regulatory supervision of the Central Bank of Bahrain. This legislative reform represents a significant step toward resolving recurring issues in commercial practice and enhancing consumer protection. In particular, it aims to curb the longstanding practice of compelling clients to issue blank cheques as collateral, which has historically given rise to forgery risks and disputes. Joint Accounts Operation Post-Death or Incapacity The amended law permits surviving or legally capable joint account holders to continue operating a joint account in the event of the death or legal incapacity of one of the account holders, provided that the bank is notified within ten (10) days from the date of death or incapacity, as required by Article 283(4). In such cases, only the share of the deceased or incapacitated party is to be frozen as of the date of death or incapacity, pending the appointment of a legal successor. This reform marks a significant departure from the previous approach, under which the entire account would be frozen until a successor was legally appointed. The new mechanism facilitates business continuity, minimises operational disruptions, and helps mitigate potential financial losses or legal complications. Conclusion In conclusion, the recent amendments to Bahrain’s Law of Commerce mark a significant advancement in the regulation of cheque transactions, reflecting a modern approach to commercial practices. By introducing partial payment mechanisms and enhancing the enforceability of cheques, these reforms aim to bolster confidence in cheques as reliable payment instruments while reducing the burden on the criminal justice system. The prohibition on issuing blank cheques as credit or guarantee instruments and stringent penalties for misuse further underscore Bahrain’s commitment to consumer protection and financial integrity. Additionally, the updated regulations for joint account operations ensure continuity and security in economic transactions following the death or incapacitation of an account holder. Overall, these legislative changes are poised to enhance commercial efficiency, protect consumer rights, and foster a more robust and reliable financial environment in Bahrain. Authors: Saad Al Doseri, Founding Partner, Al Doseri Law Shooq Mohamed Nimah, Senior Associate, Al Doseri Law The provisions of the amended Law of Commerce pursuant to Law No. (23) of 2025, amending the Law of Commerce No. (7) of 1987: Article One The texts of Articles (283) clause (4), (410) paragraph (1), (451) paragraphs (2), (3), and (4), (474) paragraph (2), (480) paragraph (1), (482), and (491) of the Commercial Law issued by Decree-Law No. (7) of 1987, shall be replaced with the following text: Article (283) Clause (4):Upon the death or legal incapacitation of one of the joint account holders, the remaining holders must notify the bank of their intention to continue the account within ten days from the date of death or incapacitation. The bank must freeze withdrawals from the joint account equivalent to the share of the deceased or legally incapacitated partner until a legal successor is appointed. Article (410) Paragraph (1):The holder of a bill of exchange, upon non-payment at maturity, may have recourse against endorsers, the drawer, and others obligated. Article (451) Paragraphs (2), (3), and (4): 2. The drawee may mark the cheque as certified either wholly or partially, indicating the availability of the full or partial funds at the drawee on the date of certification, and the drawee’s signature on the front of the cheque constitutes its certification. 3. The drawee cannot refuse to certify the cheque if requested by the drawer or holder and if there are sufficient funds to cover the full or partial amount of the cheque. 4. The full or partial cover of a certified cheque remains frozen with the drawee for the benefit of the holder until the cheque presentation deadlines expire. Article (474) Paragraph (2): If the drawee receives an opposition, it must refrain from paying the cheque’s value wholly or partially to its holder and reserve the full or available amount in the account until a decision is made. Article (480) Paragraph (1): The holder of a cheque has recourse against the drawer, endorsers, and others obligated if presented within the legal period and not fully paid, and if refusal of full or partial payment is proven by protest. In lieu of protest, refusal of payment or partial payment can be proven by: a) A statement issued by the drawee mentioning the day of cheque presentation. b) A statement from the clearinghouse indicating the cheque was presented within the legal period and not fully paid, dated and written on the cheque itself, and signed by the issuer. Article (482): Non-payment or partial payment must be proven as described in paragraph (1) of Article (480) before the presentation period expires. If the presentation occurs on the last day of this period, refusal of payment or partial payment may be proven on the next business day. Article (491): It is prohibited to issue blank cheques for use as credit or guarantee instruments. The Ministry concerned with consumer protection, under Law No. (35) of 2012 concerning consumer protection, shall take necessary actions to enforce the provision mentioned in paragraph (1) of this article. The Central Bank of Bahrain shall ensure compliance by licensees under the Central Bank of Bahrain and Financial Institutions Law issued by Law No. (64) of 2006 to enforce the mentioned provision. Article Two New articles numbered (465 bis), (465 bis 1), and (491 bis) are added to the Commercial Law issued by Decree-Law No. (7) of 1987, as follows: Article (465 bis): If the account balance is less than the cheque value, the drawee must partially pay the available amount unless the holder refuses partial payment. The cheque holder may re-present a cheque partially paid. The drawee must mark the cheque indicating partial payment upon each partial payment and return the original cheque to the holder with a certificate of partial payment. The Central Bank of Bahrain may issue a decision to specify an alternative mechanism for proving partial payment other than marking the cheque. The Central Bank of Bahrain shall issue a decision regulating the conditions, controls, and procedures related to the application of the partial payment provisions of the cheque, whether payment is in cash or by written settlement methods such as account entry, bank transfer, clearing, or other means specified by the Central Bank. The drawer’s credit record is marked if a cheque is returned due to insufficient funds or if partially paid. The Central Bank of Bahrain will issue a decision defining the cases and procedures of this marking, its duration, and procedures for its removal. Article (465 bis 1): A cheque marked by the drawee for insufficient funds or partially paid is an enforceable document under the Execution Law in Civil and Commercial Matters issued by Decree-Law No. (22) of 2021. The Minister of Justice, after approval by the Supreme Judicial Council, may issue a decision regulating the rules and procedures for executing a cheque marked by the drawee for insufficient funds or partially paid. Article (491 bis): Violators of paragraph (1) of Article (491) shall be fined not less than two hundred dinars and not more than two thousand dinars. Any holder of a blank cheque who completes the cheque details and presents it for payment shall be fined not less than ten percent of the amount recorded on the cheque and not more than twice that amount, with the fine not less than five hundred dinars and not exceeding ten thousand dinars in all cases. Article Three The Central Bank of Bahrain shall determine, in coordination with relevant authorities, the stages for implementing the partial payment of cheque values as stipulated in paragraph (1) of Article (465 bis) of Article Two of this law, after ensuring the technical arrangements and readiness of drawees necessary to effectively ensure partial payment of cheques.

In a landmark move that positions Bahrain at the forefront of digital asset regulation in the region, the Central Bank of Bahrain (CBB) launched the Stablecoin Issuance and Offering (SIO) Framework under Rulebook Volume 6, effective July 2025, establishing a comprehensive licensing and regulatory regime for stablecoin issuers. As of July, the Kingdom of Bahrain joins a select group of jurisdictions that have enacted comprehensive regulatory frameworks for stablecoin issuers. What are stablecoins? A stablecoin refers to a type of crypto-asset that is often tied one-to-one to a specific currency or asset in the material world. To illustrate, this means that a stablecoin linked to the American dollar would be worth $1. True to its name, this assurance in the form of collateral intends to be stable in value, in comparison to cryptocurrencies. Currently, there are four variations: namely, algorithmic, commodity-backed, crypto-backed, and fiat-backed stablecoins. In July 2014, the crypto-backed stablecoin, BitUSD, was issued relative to BitShares’ blockchain. Later in October 2014, Tether Limited issued digital tokens, the USDT, backed by the American dollar in physical reserve–and currently maintains its status as the world’s largest stablecoin. Since, hundreds of stablecoins have been issued.[1] A look into Bahrain’s SIO Module In the Bahraini legal context–as introduced by the SIO Module[2]–approved stablecoins means fiat-backed stablecoins issued by a licensee under the SIO Module.[3] Fiat-backed stablecoins seek to maintain stable value through reserve assets, referenced to a single fiat currency or multi-currency.[4] Accordingly, reserve assets are held as security by stablecoin issuers.[5] Notably, the SIO regulatory framework allows for single-currency fiat-backed stablecoins. This regulatory framework establishes a licensing regime which shall be read and applied in conjunction with Volume 6 of the CBB Rulebook, including but not limited to, the Anti-Money Laundering and Combating Financial Crime Module (AML), the Fit and Proper Requirements Module (FM), and the High-Level Controls Module (HC).[6] Under Volume 6 of the CBB Rulebook, licensing and regulatory procedures for crypto-asset services were also previously established.[7] The SIO Module extensively addresses the governing, enforcement and redressal mechanism for stablecoin issuance and offering. Chapters SIO-2 and SIO-3 encompass licensing procedures and conditions. Paragraph SIO-2.1 comprehensively outlines the requirements for the applicant to be submitted by the potential licensee. This is paired with a non-refundable license application fee of BHD 100 (One Hundred Bahraini Dinars).[8] In line with SIO-1.1.6, a licensed stablecoin issuer’s eligibility follows a two-pronged assessment[9] i. Type of stablecoin that may be issued: Stablecoin issuers may issue single-currency fiat-backed stablecoins pegged to the Bahraini Dinar (BHD), United States Dollar (USD), and or any other fiat currency upon obtaining approval of the CBB.[10] As a requisite, the value of the reserve assets backing the approved stablecoin–with minimum requirement of equal to par value–is to be observed by the stablecoin issuer.[11] ii. Requirements relating to the eligibility and obligations of the stablecoin issuer: Chapter SIO-3 lays down eight core licensing conditions to be met. A key point of clarification hereunder is the prerequisite for the stablecoin issuer to be locally incorporated as a Bahraini Joint Stock Company (BSC) with financial resources that are always equal or exceeding the minimum requirement as prescribed in Chapter 4 of the SIO Module, and compliant with pre-operational and licensing requirements.[12] The CBB shall issue a decision regarding a completed application within sixty (60) calendar days, in accordance with Articles 44 to 47 of the CBB Law. Integral to fiat-backed stablecoins, Chapter 6 of the SIO Module necessitates the specific composition, custody and management of reserve assets. These reserve assets are to be held with a third party–a bank, investment firm or custodian[13]–arranged by a written contract.[14] Outside of the general powers and obligations awarded to stablecoin issuers, Chapter 6 also addresses holders of the approved stablecoins. Briefly summarised, the key characteristics are as follows: Grants the direct legal right to redeem the approved stablecoin for the pegged fiat currency, at par value.[15] Mandates legitimate redemption requested to be processed at par value and completed within five (5) business days.[16] Discourages high fees or charges that may deter clients from exercising their right to redemption.[17] Additionally, requires reasonable basis for any imposition.[18] Requires the establishment and implementation of relevant policies and procedures for redemption. Sets disclosure requirement of redemption policy and procedure.[19] Issuance or offering yield from interest or reward from the investment of reserve assets.[20] In further interest of potential holders of such an approved stablecoin, Chapter 7 provides for the preparation of a non-technical reliable and accurate stablecoin whitepaper–aside from its guidelines on marketing, following whitepaper publication–intended to enable potential clients to make a well-informed decision (see Appendix C, SIO Module).[21] Reflecting a spirit of risk-based oversight and investor protection, the framework includes custody arrangements,[22] recovery plans (see Appendix D, SIO Module),[23] and adherence to global best practices in financial stability–wherein the CBB places prudential requirements,[24] issues stringent reporting measures,[25] contingent to scale and risk, impose limitations and/or restrictions, and classify an approved stablecoin as a “significant stablecoin” (see Appendices D and F, SIO Module).[26] The same is reflected in its approach to technology governance–requiring secure infrastructure and standard cybersecurity control (see Appendices A and B, SIO Module).[27] Preparatory measures, including the addressing of planned and unplanned system outages, is efficiently incorporated. The CBB retains enforcement powers, pursuant to Part 11 of the CBB Law, including the authority to impose administrative sanctions, financial penalties as detailed in Appendix E of the SIO Module, and where applicable, criminal sanctions for serious violations in accordance with the CBB Law. Licensees must notify the CBB and where required under the SIO Module, obtain prior written approval from the CBB, for any material change to their business operations or management structure. The SIO Module offers a clear, rigorous and trustworthy framework, requiring an extensive pre-approval process and heavy documentation. Resultantly, such an approach promotes transparency–effectively reducing ambiguity–and accountability, given the legal certainty and clarity. SIO: A comparative regulatory perspective Despite the introduction of digital assets and increased adoption of stablecoins, countries are yet to codify regulatory frameworks to address stablecoin integration. For instance, along with many others, while Circle’s USDC is a popular stablecoin pegged to the American dollar, the United States of America is yet to sign its federal stablecoin legislation–the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act–into law following its approval in June 2025.[28] Similarly, the United Kingdom does not yet have a dedicated stablecoin regime, however, if it meets the definition of e-money, it may fall within the scope of the Electronic Money Regulations 2011 and the Payment Services Regulations 2017. Hong Kong is at the precipice–with its Stablecoins Ordinance–regarding fiat-backed stablecoins pegged to the Hong Kong Dollar.[29] In contrast, China had officially banned cryptocurrencies, including stablecoins, but is appearing to gain ground.[30] The following section explores the current frameworks adopted across the globe, as per the date of this article. This comparative overview of country profiles aims to provide additional insights and gain knowledge on existing practices. Accordingly, hereunder is an assessment of countries that have officially enacted law relating to the issuance and licensing of stablecoins. Asia i. Japan Japan, through its Financial Services Agency (FSA), regulates stablecoin issuance in accordance with the recently amended Payment Services Act, effective as of June 2023. “Electronic payment instruments (EPIs)” corresponds to stablecoins in the national legislation. EPI providers must be registered by the Prime Minister, including foreign EPI service providers with a representative in Japan. The legislation addresses four types of EPIs: with currency-denominated assets–wherein activity in Japanese yen or foreign currency will be carried out in Japanese yen or foreign currency–akin to fiat-backed stablecoins.[31] ii. Singapore Singapore, through Monetary Authority of Singapore (MAS), regulates fiat-backed stablecoins by an amendment to the Payment Services Act 2019, effective as on 4 April 2024. In the domestic context, stablecoins are referred to as “digital payment tokens (DPT)” wherein licensees would carry a business of providing a digital payment token service.[32] This framework regulates single-currency stablecoins (SCS) issued in the country, pegged to the Singapore Dollar or currencies of the G10. Notably, it distinguishes MAS-regulated stablecoins and other tokens which are not classified as MAS-regulated stablecoins. Such tokens refer to SCS which are not issued by banks and are in circulation, with a value not exceeding S$5 million, or tokenised bank liabilities and/or other types of stablecoins; including SCS issued outside of Singapore. Regardless of this differentiation, stablecoins are subject to the DPT regime under the Payment Services Act. A standout element of key requirements relating to the composition, segregation and custody of reserve assets is the reliance on a minimum credit rating. Europe (with reference to the EU) i. Switzerland Known as the first country to issue guidelines relating to the issuance of stablecoins, through its Financial Markets Supervisory Authority (FINMA), Switzerland published a supplement to guidelines relating to initial coin offerings as early as in September 2019.[33] Introducing changes, FINMA issued guidance immediately effective on 26 July 2024. The key changes include the establishment of minimum requirements for default guarantees of banks and necessitating the adequate verification of all stablecoin holders by stablecoin issuers or the supervising financial intermediary. It is deemed the payment claims generally made against stablecoin issuers and/or any licensing requirements will fall under the purview of the Banking Act and/or the Collective Investment Schemes Act, with steep obligations under the Anti-Money Laundering Act. ii. European Union The EU, by way of the Market in Crypto-Assets Regulation (MiCA), fully implemented legislation as of December 2024.[34] With an aim to govern crypto-assets, it established licensing and regulatory requirements for crypto-asset service providers (CASPs). MiCA introduces a tri-classification: (i) electronic or e-money tokens (EMTs): fiat-backed stablecoins with heavy regulatory requirements (ii) asset-referenced tokens (AMTs) which may be backed multi-currency and excludes algorithmic stablecoins, and (iii) any other cryptocurrency excluding EMTs and AMTs. MiCA introduces a regional system that would unify services across all Member States through one authorisation system.[35] EU Member States shall implement the regulation through their complementing national law and by their national agencies i.e., the National Competent Authority (NCA), and other governing bodies where necessary, namely, the European Banking Authority, the European Securities and Markets Authority, the European (and national) Central Bank. Middle East (and refers to the GCC) i. United Arab Emirates Following the United Arab Emirates (UAE), Bahrain is the second in the GCC and the Middle East to implement regulations for stablecoins. The UAE, through the Central Bank of the UAE’s Payment Token Services Regulation, established rules and conditions for fiat-backed regulated stablecoin activity, effective from 21 August 2024. Nationally recognised as “payment tokens”, the UAE legislation accounts for Dirham payment tokens (pegged to the Dirham) and foreign payment tokens (pegged to foreign fiat currency).[36] According to its licensing regime, a person may be a Dirham Payment Token Issuer or apply for a Foreign Payment Token Issuer Registration. With the exception of Financial Free Zones, the regulation applies to any natural or legal person seeking to offer and engage in services related to fiat-backed payment tokens. These payment token services (and licensing) are divided into activities of payment token issuance, payment token conversion, and payment token custody and transfer. Regarding other types of stablecoins, under the regulation, the issuance, promotion, and performance of services relating to algorithmic stablecoins are prohibited. It is also of significance that the Emirate of Dubai governs commodity-backed stablecoins through its Virtual Asset Regulatory Authority. SIO Bahrain: A brief analysis Bahrain’s regulatory framework for stablecoins is distinct in several ways compared to other countries, highlighting its proactive and comprehensive approach to regulating digital assets. Comprehensive Framework and Early Adoption: Bahrain has launched a forward-looking regulatory framework for stablecoin issuance and offering, positioning itself as a leader in digital asset regulation in the region. The CBB has established a comprehensive licensing and regulatory regime for single-currency fiat-backed stablecoin issuers under Rulebook Volume 6. This early adoption and comprehensive approach contrasts with countries that are yet to adopt a stance, besides the creation of a relevant framework. Regional Leadership and Specific Focus: In the Middle East, Bahrain closely followed the United Arab Emirates in implementing stablecoin regulations. Bahrain’s focus on creating a clear and structured regulatory path for fintechs, financial institutions, and investors to participate confidently in a strictly regulated stablecoin ecosystem further distinguishes it. While the UAE’s regulations recognise stablecoins as payment tokens, and its framework broadly addresses fiat-backed stablecoin activities, Bahrain’s initiative underlines its commitment to bridging regulatory gaps and fostering innovation while maintaining financial stability and consumer protection. Specific Licensing and Compliance Requirements: Bahrain’s regulatory framework includes detailed licensing conditions and compliance requirements, such as the requirement for stablecoin issuers to be incorporated in Bahrain as Bahraini Joint Stock Companies (BSC) and to maintain financial resources in accordance with the minimum prescribed requirements under the CBB Rulebook Volume 6. This level of specificity in regulation ensures a robust and secure environment for stablecoin operations, which is not always evident in other jurisdictions. By implementing these measures, Bahrain not only stands out as a regional leader in stablecoin regulation but also sets a benchmark for other countries aiming to integrate stablecoins into their financial systems while ensuring regulatory compliance and consumer protection. Conclusion The regulation of and relating to stablecoins is complex and evolving alongside the growing need for country-level regulations. As evidenced by the wide use of stablecoins globally, it is imperative for countries to establish clear regulatory frameworks in the face of potential collapses and volatility despite the promise of stability, like the USDC had previously lost its dollar peg. Bahrain’s proactive approach in legislating stablecoin issuance and offerings demonstrates its commitment to fostering innovation while maintaining financial stability and consumer protection. By bridging a significant regulatory gap, the SIO Framework positions Bahrain as a leader in digital asset regulation in the Gulf, providing a clear path for fintech, financial institutions, and investors to participate in the stablecoin ecosystem confidently. Authors: Saad Al Doseri Srivani P. Nair [1] Spencer Feingold, ‘Stablecoin surge: Here’s why reserve-backed cryptocurrencies are on the rise’ (World Economic Forum, 3 June 2025), last accessed 10 July 2025. [2] CBB Rulebook, Volume 6: Capital Markets, Stable Issuance and Offering Module. [3] Central Bank of Bahrain Rulebook (CBB), Volume 6: Capital Markets, Glossary History, p.3. [4] CBB Rulebook, Volume 6: Capital Markets, Glossary History, p.14. [5] CBB Rulebook, Volume 6: Capital Markets, Glossary History, p.34. [6] Supra note 2, para SIO-A.1.2. [7] CBB Rulebook, Volume 6: Capital Markets, Crypto-Asset Module. [8] Supra note 2, para SIO-2.1.2. [9] Supra note 2, para SIO-1.1.6. [10] Supra note 2, para SIO-1.2.1. [11] Supra note 2, para SIO-1.2.2. [12] Supra note 2, paras SIO-3.1(1) and (4). [13] Supra note 2, para SIO-6.4.1(b). [14] Supra note 2, paras SIO-5.3.3 and 6.4.8. [15] Supra note 2, para SIO-6.5.1. [16] Supra note 2, para SIO-6.5.2. [17] Supra note 2, para SIO-6.5.4. [18] Supra note 2, para SIO-6.5.6. [19] Supra note 2, paras SIO-6.5.5 and 6.5.6. [20] Supra note 2, para SIO-6.6. [21] Supra note 2, Chapter SIO-7. [22] Supra note 2, Chapter SIO-10. [23] Supra note 2, Chapter SIO-9. [24] Supra note 2, para SIO-4.2. [25] Supra note 2, para SIO-8.1. [26] Supra note 2, para SIO-8.2. [27] Supra note 2, Chapter SIO-9. [28] Legal Nodes Team, ‘Stablecoin Issuance Regulation in 2025 (US, UK, EU, Asia, Latin America)’ (Legal Nodes, 29 April 2025) accessed 9 July 2025. [29] Eddie Yue, ‘Robust and Sustainable Development of Stablecoins’ (Hong Kong Monetary Authority, 23 June 2025) accessed 9 July 2025. [30] Reuters, ‘China’s tech giants lobby for offshore yuan stablecoin, sources say’ (Reuters, 3 July 2025) accessed 9 July 2025. [31] Payment Services Act (Act No. 61 of 2022). [32] Payment Services Act 2019 (Amendment Act), Section 6(5)(vi). [33] FINMA, ‘FINMA publishes ‘stable coin’ guidelines’ (FINMA, 11 September 2019) accessed 9 July 2025. [34] Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023. [35] Supra note 28. [36] Central Bank of The UAE Rulebook, Payment Token Services Regulation (2024).

The Kingdom of Bahrain has taken positive steps towards protecting individuals from personal and data theft with the introduction of the amendments brought along by Legislative Decree No. (3) of 2025. Founding Partner Saad Al Doseri and Trainee Lawyer Noor Fathalla provide their insight on the recent amendments to Bahrain’s Penal Code. Saad and Noor’s article has been published in The Oath, 20 February 2025 – a link to their article as published may be found here. The Legislative Decree No. (15) of 1976 promulgating the Penal Code (the “Penal Code”) has been amended by Legislative Decree No. (3) of 2025 (the “Amendments”), which considerably broadens the scope of the definition of theft to efficiently reflect today’s rising concerns regarding cybercrime and the theft of modern electronic devices. The Amendments The Amendments added the following clauses to the Penal Code: New Clause (12) to Article (380): Any mobile phone, or laptop, or tablet, or any other electronic, magnetic, optical, or electrochemical device, a tool integrating communication and computing technologies, or any device capable of receiving, transmitting, processing, storing, and retrieving data at high speed. Third paragraph to Article (380): The minimum penalty prescribed in the preceding two paragraphs shall be imprisonment for no less than one year if the theft involves the devices or tools mentioned in Clause (12) of this Article with the intent to obtain the information, data, or images that they contain. Second and third paragraphs to Article (396): The penalty shall be imprisonment for a term not exceeding two years or a fine not exceeding five hundred dinars if the crime involves a mobile phone, laptop, tablet, or any electronic, magnetic, optical, electrochemical device, or a tool integrating communication and computing technologies or any device capable of receiving, transmitting, processing, storing, and retrieving data at high speed. The penalty shall be imprisonment for a term not exceeding two years and a fine not exceeding five hundred dinars, or either of these penalties if the devices or tools mentioned in the preceding paragraph are seized to obtain the information, data, or images they contain. Previous Clauses The previous Penal Code has specified eleven (11) circumstances of theft in which the minimum prison sentence is three (3) months. Some of these circumstances include theft in places of worship or residence, theft in modes of transportation, a marina, or an airport, armed theft, theft through misrepresentation, and more. What Do the Amendments change? Evidently, the circumstances listed do not specify cybercrime nor the theft of modern electronic devices. Thus, the Amendments added an additional clause (12) to Article 380 to explicitly criminalise the theft of a mobile phone, laptop, tablet, or any electronic, magnetic, optical, electrochemical device, or any device integrating communication and computing technologies, or any other device capable of rapidly receiving, transmitting, processing, storing, and retrieving data (“Modern Electronic Devices”). The Amendment included an additional minimum sentence of one (1) year if the theft of said devices was with the intention of obtaining information, data, or images. Furthermore, Article 396 was amended to include two additional paragraphs: To explicitly criminalise the unintentional theft or the theft of lost Modern Electronic Devices with a maximum sentence of two (2) years or a maximum fine of BHD500 (Five Hundred Bahraini Dinars); and A maximum sentence of two (2) years or a maximum fine of BHD500 (Five Hundred Bahraini Dinars) or both, should the said theft occur with the intention of obtaining information, data, or images. Was the Penal Code Amendments Necessary with the existing Law No. 60 of 2014 on Information Technology Crimes? The Amendments to Bahrain’s Penal Code, introduced by Legislative Decree No. (3) of 2025 complements this existing framework by addressing modern electronic device theft and cybercrimes. While Law No. 60 of 2014 focuses broadly on IT-related crimes, the Amendments expand the Penal Code’s scope to include detailed provisions for the theft of devices capable of storing and processing data, such as mobile phones and laptops. This addition is crucial as it provides specific penalties for device theft with the intent to access stored information, thereby enhancing legal protections against technological misuse and aligning with the broader objectives of Law No. 60 of 2014. The Amendments were set in place to maintain the relevancy of the Penal Code and adapt to current developments. The risks of modern theft, such as financial crimes through electronic means and the breach of personal data, have naturally risen with the increased use and possession of Modern Electronic Devices. Thus, it is necessary to stay vigilant and aware of any scams. Conclusion The recent Amendments to Bahrain’s Penal Code, introduced by Legislative Decree No. (3) of 2025 mark a significant step forward in addressing the evolving landscape of cybercrime and electronic device theft. These changes specifically target the theft of mobile phones, laptops, tablets, and other modern electronic devices, providing clear legal consequences for such actions. By imposing stricter penalties for thefts committed with the intent to access sensitive information, the Amendments enhance the legal framework and align closely with the overarching objectives of Law No. 60 of 2014 on Information Technology Crimes. This proactive approach ensures that Bahrain’s legal system remains robust and relevant in the face of technological advancements and the associated risks of data breaches and cyber-related financial crimes, thereby offering greater protection to individuals and their personal data. Authors: Saad Al Doseri, Founding Partner, Al Doseri Law Noor Fathalla, Trainee Lawyer, Al Doseri Law