United Arab Emirates

An analysis of Federal Decree-Laws No. 32 and 33 of 2025 and the UAE's broader 2025–2026 legislative reform programme Legislative Context The UAE's capital markets framework has, since its inception, been built on Federal Law No. 4 of 2000, which established the Emirates Securities and Commodities Authority and provided the foundational architecture for regulating securities, commodities, and investment activities onshore. Despite a series of regulatory updates, the framework was increasingly strained by the scale, cross-border complexity, and pace of financial innovation that now characterise UAE markets. The 2025-2026 reforms address these structural limitations through a coordinated package of primary legislation that touches every significant dimension of UAE’s financial regulatory architecture. The 2025-2026 reforms have four components, each of which affect capital markets participants to varying degrees: Federal Decree Laws No. 32 and 33 of 2025[1]: the centrepiece of the reforms, effective 1 January 2026, governing the new Capital Market Authority and the substantive regulation of UAE capital markets respectively. Federal Decree Law No. 20 of 2025: amendments to the Commercial Companies Law (“CCL”), effective 15 October 2025, introducing multiple share classes for limited liability companies, statutory drag-along and tag-along rights, a private placement pathway for private joint stock companies ("PrJSCs"), and a corporate re-domiciliation framework. Federal Decree Law No. 6 of 2025[2]: a comprehensive overhaul of the Central Bank Law, effective 16 September 2025, consolidating oversight of banking, insurance, payments, and fintech regulation under a unified supervisory framework. Federal Decree Law No. 10 of 2025[3]: a replacement of the 2018 AML/CTF framework, effective December 2025, expanding the Financial Intelligence Unit's operational powers and tightening obligations across financial institutions and virtual asset service providers. This Article focuses primarily on the Federal Decree Law No. 32 of 2025 Regarding the Capital Market Authority (“CMA Law”) and Federal Decree Law No. 33 of 2025 Regarding the Regulation of Capital Market (“Capital Market Law”), with specific analysis of the CCL amendments where they are directly relevant to capital markets activity. The Capital Market Authority: Institutional Reconstitution The CMA Law reconstitutes the Securities and Commodities Authority ("SCA") as the Capital Market Authority ("CMA"), an independent federal public authority with separate legal personality, which assumes all rights, obligations, contracts, and liabilities of the former SCA. All existing references to the "SCA" in legislation, contracts, and official documents are automatically substituted by "CMA" without further amendment. The institutional change is substantive, not cosmetic. For the first time, the CMA's core statutory objectives are embedded in primary law. These include: regulating, supervising, and developing the UAE's capital markets sector in accordance with the country's broader economic and policy objectives; protecting investors and market participants; enhancing market integrity, efficiency, and transparency; promoting fair competition; supporting sustainable economic growth; fostering innovation within a safe and well-governed environment; and positioning the UAE as an internationally competitive financial centre. Embedding these objectives in statute is legally significant, in any future challenge to CMA regulatory action, they provide a benchmark against which the reasonableness and proportionality of that action may be assessed. The CMA is also granted broader supervisory, investigatory, and enforcement powers than its predecessor, including the ability to impose a wider range of administrative sanctions and to conduct on-site inspections and information-gathering exercises with enhanced statutory backing. The CMA Law introduces express governance and accountability requirements applicable to the CMA itself. These include requirements relating to board composition and structural matters, information safeguarding obligations applicable to board members and all CMA staff, and external auditing requirements. These provisions are designed to reinforce institutional credibility and provide a framework for oversight of the regulator as well as by it. All entities and persons within scope of the new legislation must regularise their position within one year of 1 January 2026, i.e., by 1 January 2027, subject to extension by the CMA Board.[4] Pre-existing Cabinet decisions and SCA resolutions remain operative to the extent they do not conflict with the Decree-Laws, until replaced by new implementing resolutions. In practice, the substantive SCA rulebook carries over in the interim, and the transitional window is intended to give the CMA time to issue updated rules and regulated firms time to adapt their compliance frameworks accordingly. Firms that take a proactive approach to identifying gaps and engaging with CMA guidance during this period will be better placed than those who wait for formal requirements to crystallise. The Capital Market Law: Key Substantive Reforms An Expanded Regulatory Perimeter Article 2 of the Capital Market Law materially expands the CMA's jurisdictional reach. The provision expressly extends the scope of the Capital Market Law to: financial products dealt with within the UAE; financial activities practised within the UAE or by any person operating in a UAE financial free zone; licensed persons, approved persons, issuers (including foreign issuers), funds, and connected persons operating within the UAE; and any person targeting clients within the UAE, even where the activity is conducted from outside the UAE or from a financial free zone such as the DIFC or ADGM. Public sector issuances and activities within the exclusive purview of the Central Bank are expressly excluded from scope. Under the prior framework, regulatory reach was largely tied to domestic execution and physical presence, leaving meaningful uncertainty around the treatment of cross-border activity. The new provision resolves that uncertainty by making explicit that directing financial services, offers, or marketing at UAE investors, regardless of where the firm is incorporated or where the transaction is executed, falls within the CMA's regulatory perimeter. Firms currently relying on cross-border exemptions that were available under the old regime should not assume those exemptions automatically carry over; the CMA is yet to confirm whether or how existing exemptions will be preserved under the new framework. Foreign financial institutions, fund managers, and investment advisers with UAE investor bases should treat this change as a prompt to review their licensing and compliance frameworks. The jurisdictional reach of the Capital Market Law is broader than the prior regime, and the position on cross-border exemptions remains to be clarified by the CMA through implementing regulations. Statutory Prospectus Liability Article 29 of the Capital Market Law introduces a unified statutory prospectus liability regime applicable to all issuers of securities in the UAE. Statutory liability is expressly imposed on the issuer's board of directors, executive management, and advisers for any failure to provide required information, or for providing misleading or inaccurate information, within the prospectus, each within the scope of their respective competence. The liability standard is stringent and leaves no room for ambiguity: if the information is wrong or missing and falls within a party's area of responsibility, that party is exposed. For intentional conduct, the Capital Market Law imposes criminal sanctions including imprisonment of not less than one year and substantial financial penalties. Prior to this reform, prospectus liability in the UAE was derived primarily from SCA regulatory rules and exchange requirements rather than primary statute. While liability existed, the legal basis was indirect and its scope was uncertain. Article 29 resolves that uncertainty entirely, placing prospectus liability on a clear and direct statutory footing for the first time. Issuers, their boards, and their advisers should review diligence processes, verification procedures, and sign-off frameworks in light of the direct statutory exposure now imposed by Article 29. Comfort letter and verification frameworks developed under the old regime may need updating. Underwriting banks, in particular, should consider whether their existing diligence records and verification materials are sufficiently robust to support available defences Inside Information and Delayed Disclosure Article 33(2) of the Capital Market Law permits an issuer to delay the public disclosure of inside information where it has reasonable grounds to believe that immediate disclosure would cause serious harm to its interests or those of its shareholders. To invoke the delay, the issuer must submit a justified written request to the CMA (for unlisted securities) or to the relevant exchange, the Abu Dhabi Securities Exchange ("ADX") or Dubai Financial Market ("DFM"), in respect of listed securities. The CMA or exchange may accept, reject, or subsequently amend or revoke the decision to delay. This is a welcome and practical provision: the ability to manage the timing of sensitive disclosures in a structured and legally compliant manner is important for issuers managing complex corporate events. Complementing this is the substantially strengthened market abuse framework under Article 37, which codifies a more granular and behaviourally precise set of prohibited market conduct offences. These include: entering into transactions with the intent to deceive or mislead investors or the market; employing manipulative trading practices; disseminating false or misleading statements about a financial product or issuer; inciting or spreading rumours capable of affecting the price or value of securities; and exploiting inside information, with the prohibition capturing both direct and indirect dealings by persons in possession of material non-public information. The CMA is underpinned by a significantly enhanced enforcement apparatus, including robust surveillance and investigation tools, graduated administrative sanctions, and direct criminal referral powers. Administrative penalties may reach up to AED 200 million or ten times the illicit gains realised or losses avoided, whichever is higher. The CMA may also impose warnings, suspend or cancel licences, and publish imposed penalties. The enhanced penalty regime is a material change from the prior framework and substantially elevates the consequences of non-compliance. All regulated firms should review their market conduct policies and training programmes in light of the broadened offences and significantly increased sanctions. Price Stabilisation Safe Harbour Article 37(2) of the Capital Market Law codifies a statutory safe harbour for price stabilisation activities conducted in connection with securities offerings. The provision states that the exercise of price stabilisation controls, procedures, or mechanisms for which controls have been issued by the CMA or Capital Market Institutions shall not constitute a violation of the Capital Market Law or of the provisions of Federal Decree-Law No. 32 of 2021 on Commercial Companies that prohibit the influencing of securities prices. This resolves a longstanding and practically significant ambiguity. Under the prior framework, investment banks conducting standard IPO stabilisation programmes operated in a theoretically exposed position, with comfort derived from regulatory practice and structural workarounds, including the frequent appointment of independent third-party stabilisation managers, rather than a clear statutory exclusion. Article 37(2) eliminates that structural uncertainty and places the safe harbour on an explicit primary legislative basis. Investment banks acting as stabilisation managers in UAE public offerings should update their stabilisation documentation, internal procedures, and disclosure materials to reflect the new statutory framework. The codification of the safe harbour may also remove the need for certain structural arrangements that were historically used to manage stabilisation risk. Systemically Important Licensed Persons and Recovery The Capital Market Law introduces a dedicated regulatory framework for entities designated as Systemically Important Licensed Persons. The CMA has full discretion to determine which firms fall within this category based on criteria including size and market share, complexity, interconnectedness with other market participants, and potential systemic impact. Designated firms are subject to enhanced prudential requirements, including capital, liquidity, governance, and risk management obligations, as well as recovery and resolution planning requirements. The CMA is granted a comprehensive toolkit of early-intervention and resolution powers. In resolution, it may: remove or appoint management; terminate, assign, or vary contracts; write down or convert debt; transfer assets and liabilities to third parties or bridge entities; impose temporary stays on termination rights; and conduct orderly wind-downs with a statutory hierarchy of claims. These powers may be exercised before formal insolvency proceedings are initiated, giving the CMA meaningful tools to intervene at an early stage and manage a firm's failure in an orderly manner. Firms of a size or complexity that could attract systemic importance designation should begin assessing their exposure now, before formal designation criteria are published. Recovery planning, governance documentation, and capital planning frameworks should all be considered as early priorities. Investor Protection Fund and Settlement Guarantee Fund Article 44 of the Capital Market Law requires the CMA to establish an Investor Protection Fund, an independent legal entity with separate legal personality and financial liability, the purpose of which is to protect investors' funds against risks determined by the CMA. The CMA is responsible for issuing a decision regarding the fund's establishment, operational mechanisms, management, membership conditions, financial resources, obligations towards investors, risks covered, eligibility periods, and dissolution mechanisms. Separately, Article 45 permits the central clearinghouse to establish a Settlement Guarantee Fund, also with independent legal personality, the purpose of which is to guarantee the settlement of transactions executed on the market, subject to CMA-approved controls. These mechanisms are a structural improvement over the prior regime, which lacked equivalent statutory investor compensation or settlement guarantee arrangements, and are designed to deepen confidence among the full range of investors engaging with UAE markets. Whistleblower Protections Article 60 of the Capital Market Law introduces robust whistle-blower protections. Any person may report suspected violations to the CMA, to a Capital Market Institution, to their employer, to the compliance officer of their employer, or to judicial authorities. Persons making such reports are afforded immunity from criminal, civil, and contractual liability arising from the act of reporting, as well as protection from compensation claims and adverse employment consequences. This provision is designed to encourage the reporting of misconduct from within regulated firms and is likely to increase the volume and quality of information reaching the CMA through internal channels. Regulated firms should review their internal whistle-blower and speak-up frameworks to ensure they are consistent with Article 60 and that employees are aware of both the internal and external reporting channels available to them. Collective Investment Schemes Article 38 of the Capital Market Law establishes a revised framework for investment funds. Funds now enjoy independent legal personality and ring-fenced financial liability, strengthening the structural integrity of UAE-domiciled funds and the protections available to fund investors. Funds may be established in one of two forms: as an investment fund established and licensed by a CMA decision; or as a recognised form of commercial company, established in accordance with applicable UAE company laws, with prior CMA approval. This dual-track structure provides meaningful flexibility for fund sponsors in designing their fund vehicles. Virtual Assets Article 39 of the Capital Market Law formally integrates virtual asset trading into the capital markets regulatory perimeter. The CMA assumes federal supervisory responsibility for virtual asset activities in the onshore UAE, and trading of any virtual asset is prohibited unless it has been approved and listed by a CMA-licensed virtual asset platform operator registered with the CMA. The existing delegation arrangement to the Dubai Virtual Asset Regulatory Authority ("VARA") is preserved pending amendment or repeal, meaning the UAE's multi-regulator approach to digital assets continues within a clearer federal framework. Implementing regulations are expected and will define much of the practical operation of this regime. Firms operating in the virtual asset space, whether as issuers, platform operators, or advisers, should closely monitor CMA publications as implementing regulations take shape. The licensing requirements, the interface with VARA's existing framework, and the precise scope of the approved asset list will all be critical details that the primary law leaves to secondary legislation. Criminal Settlement Mechanism Article 75 of the Capital Market Law introduces a pre-prosecution criminal settlement mechanism. Prior to initiating criminal proceedings, the CMA may settle with a violator in respect of crimes under the Capital Market Law, subject to controls to be issued by Cabinet decision. If settlement is not achieved or the violator rejects its terms, the CMA is required to refer the matter to the public prosecution. The public prosecution may also settle after proceedings commence, but before final judgment is delivered. This mechanism gives the CMA a more proportionate and commercially sensitive enforcement pathway, enabling resolution of serious matters without necessarily resorting to criminal prosecution, while preserving the ability to escalate where appropriate. Commercial Companies Law: Capital Markets Implications The October 2025 amendments to the CCL are a distinct legislative framework, but their relevance to capital markets activity is direct. Three changes are of particular note. Private Placements for Private Joint Stock Companies Article 32 of the CCL, as amended, permits PrJSCs to raise capital through regulated private placements on UAE financial markets for the first time, without the need to conduct a full public offering. Prior to this reform, PrJSCs had no clear domestic pathway for accessing institutional capital short of a full listing, a structural gap that regularly drove issuers towards offshore structures or parallel vehicles. The reform closes that gap and is expected to deepen the pipeline of growth-stage companies able to access UAE capital markets and, in time, to graduate to the ADX or DFM. The practical operation of the private placement framework is contingent on implementing regulations from the CMA, which remain outstanding. The shape of those regulations, including eligibility criteria, investor categorisation, disclosure requirements, and any resale restrictions, will determine how commercially viable this new pathway proves in practice. Market participants with an interest in this area should monitor CMA publications closely. Statutory Investor Rights and Multiple Share Classes Article 14 of the CCL, as amended, introduces statutory recognition of drag-along and tag-along rights, which may now be embedded directly in a company's constitutional documents rather than relying on private shareholders' agreements with historically uncertain enforceability. Multiple share classes are also now available in limited liability companies. These changes bring UAE corporate governance tools meaningfully closer to the structures available in leading investment jurisdictions, reducing transaction friction and providing materially stronger and more reliably enforceable protections for private equity and venture capital investors in UAE-incorporated entities. Corporate Re-domiciliation The new Article 15 of the CCL establishes a framework for corporate re-domiciliation, permitting companies to transfer their commercial register and licensing to a different competent authority — including from foreign jurisdictions into the UAE, while preserving the same legal entity and its existing contractual relationships. There is no requirement for liquidation or reincorporation, and there is no discontinuity of legal personality. For regional groups seeking to consolidate their structures, or for foreign businesses considering establishing a UAE anchor entity, this is a new and commercially significant option that was previously unavailable. Key Considerations for Market Participants The transitional window runs until 1 January 2027, but a number of the changes described in this article have immediate compliance implications. The following sets out the priority considerations by market participant type. Licensed Financial Intermediaries Map existing licences against the Capital Market Law's revised activity definitions. Gaps are more easily addressed proactively than reactively, and the CMA is likely to expect regulated firms to have conducted this exercise. Review conduct of business policies, governance arrangements, and fitness and propriety assessments for senior staff against the elevated CMA expectations embedded in the new framework. Assess whether your firm could attract designation as a Systemically Important Licensed Person and, if so, begin preliminary recovery planning work ahead of any formal regulatory requirement. Ensure AML/CTF procedures have been updated in line with the new AML Law and associated FIU requirements. These obligations are already in force. Review and update internal whistle-blower and speak-up frameworks to reflect the protections and reporting channels now codified in Article 60. Issuers and Prospective Issuers Revisit prospectus diligence frameworks, verification procedures, and board sign-off processes in light of the direct statutory liability imposed by Article 29. Boards should be satisfied that their internal disclosure controls are robust and that each party signing off on a prospectus is comfortable with the statutory exposure attaching to their respective area of responsibility. PrJSCs with capital raising plans should engage advisers to monitor and assess the private placement framework as CMA implementing regulations are published, and to evaluate whether the domestic route under Article 32 offers advantages over offshore alternatives. Companies considering conversion from LLC to PrJSC, or a cross-authority re-domiciliation under Article 15, should evaluate whether these pathways now offer a commercially attractive route to restructuring. Investment Banks and Financial Advisors Update IPO stabilisation documentation, internal procedures, and disclosure materials to take full advantage of the statutory safe harbour now codified in Article 37(2). Consider whether structural arrangements previously used to manage stabilisation risk remain necessary under the new framework. Reassess compliance frameworks for cross-border offerings directed at UAE investors. Article 2's expanded jurisdictional perimeter means UAE compliance obligations may extend further than your existing framework assumes, and the CMA's position on cross-border exemptions is yet to be confirmed. Advise clients with virtual asset ambitions on the new CMA licensing requirements and the continued VARA delegation arrangement, and monitor CMA publications for the implementing regulations that will define the operational framework. Foreign Entities and Investors Assess whether cross-border activities directed at UAE clients — including fund marketing, investment advisory services, and solicitation of investments — fall within the CMA's expanded jurisdictional perimeter under Article 2, and take licensing or exemption advice accordingly. Consider the re-domiciliation framework as a potential tool for consolidating regional group structures into the UAE without the cost and disruption of liquidation and reincorporation. Establish a structured process to monitor CMA Board resolutions and implementing regulations. The primary legislative framework is in place, but much of the practical operation of the new regime, including key licensing requirements, exemptions, and the virtual asset framework, will be shaped by secondary legislation that is still to come. Conclusion The enactment of the CMA Law and the Capital Market Law, taken together with the concurrent reforms to the Commercial Companies Law, the Central Bank Law, and the AML/CTF framework, represents the most comprehensive overhaul of the UAE's financial regulatory architecture since the establishment of the SCA in 2000. The reforms mark a structural shift from a rulebook-driven and interpretive regime to one that is statutory, consolidated, and enforcement-oriented: statutory prospectus liability, a codified market abuse framework, enhanced penalty powers, and new recovery and resolution tools all point in the same direction. For market participants, the reforms bring both opportunities and obligations. The areas of new legal certainty reduce transaction risk and create a more predictable operating environment. At the same time, the expanded regulatory perimeter, the significantly increased penalty regime, and the new obligations applicable to systemically important firms materially raise the compliance bar. The central challenge of the period ahead will be navigating the transition thoughtfully. The primary legislative framework is in place and clear in its direction. However, a significant body of implementing regulation remains to be issued, and the practical shape of several key provisions, including the virtual asset framework, private placement rules, cross-border exemptions, and systemic importance criteria, will only become clear as that secondary legislation emerges. Firms that engage early, monitor CMA guidance closely, and take a proactive approach to remediation will be better positioned than those who wait. We will continue to monitor developments as implementing regulations are issued and will publish further analysis as the framework develops. We welcome the opportunity to discuss the implications of these reforms for your specific circumstances.   Author/s Evgeny Yafasov Partner – HAS Law Firm Chirag Chhabra Associate – HAS Law Firm   [1] Federal Decree Law No. 32 of 2025 Regarding the Capital Market Authority and Federal Decree Law No. 33 of 2025 Regarding the Regulation of Capital Market. [2] Federal Decree Law No. 6 of 2025 Regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business. [3] Federal Decree Law No. 10 of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing. [4] Article 83 of the CMA Law.

The United Arab Emirates is no longer simply a strong aviation market. It is building a legal and industrial ecosystem for civil aviation, drones, defence technology and next-generation aerospace. That is visible not just in legislation, but in the market itself. Dubai Airshow 2025 described a week of breakthroughs, strategic partnerships and industry-shaping discussions. EDGE said it unveiled 42 new products there across air, space, autonomy, propulsion, radar and secure communications; and the UAE’s sustainable aviation fuel policy targets 700 million litres of domestic SAF production annually by 2030. For lawyers, investors, OEMs, MRO providers, drone operators and defence contractors, the real point is this: the UAE is not difficult because it is overregulated. It is difficult because civil aviation, dual-use controls, defence licensing and foreign ownership rules can overlap in the same project. The framework is anchored in the Civil Aviation Law, which official sources now describe as amended by Federal Decree-Law No. 12 of 2024, the GCAA Law of 1996, the 2022 drone law, the 2021 non-proliferation controls law and its 2024 executive regulations, the 2019 weapons and military materiel law, and the 2021 strategic impact regime. Civil aviation in the UAE is mature, but it is not static The civil side of the regime is relatively legible. The Civil Aviation Law remains the foundation of the UAE aviation framework, while the GCAA remains the federal authority responsible for executing that law. But the mistake outsiders make is assuming that “mature” means “settled.” Official UAE sources now refer to the Civil Aviation Law as amended in 2024, which is a reminder that this framework continues to evolve alongside the industry it regulates. For market participants, the real legal question is not abstract sovereignty over airspace. It is licensing, operating permissions, continuing airworthiness, training, safety supervision and regulatory timing. One technical point is worth stating plainly because professionals care about it and non-specialists often miss it: the official English legislation portal itself says the Arabic text prevails in the event of inconsistency. In this sector, that matters. When the question is scope, penalty, or classification, translation is not a clerical issue; it is a legal one. Drones are not a side issue anymore The UAE’s drone framework is one of the clearest signs that aerospace regulation is moving from aircraft law to airspace management. Federal Decree-Law No. 26 of 2022 applies to all UAVs and related activities across the UAE, including free zones, and assigns the GCAA a central role in creating a unified register and approving the conditions for permits and certificates. That is already more than hobby regulation. It is the architecture of a managed operating environment. The penalties confirm the seriousness of the regime. Operating activities without registration can attract fines of AED 50,000 to AED 500,000. Conducting design, manufacture, testing, trading or related commercial activities without the required licence or permit can trigger fines of AED 100,000 to AED 2,000,000. More serious conduct, including operations in restricted or prohibited areas or conduct jeopardising airspace safety, can lead to imprisonment of six months to five years and or fines up to AED 1,000,000. What makes the UAE interesting is that the regime is strict in theory and granular in practice. The GCAA’s operational rules for individual users require registration, confine smaller recreational drones to approved zones, require line-of-sight operations, cap altitude at 400 feet above ground, limit flying to daytime and good weather, and prohibit operations within 5 km of airport perimeters. More recent GCAA recreational rules also point pilots to accredited training and the UAE Drones platform. In parallel, the regulatory conversation has already moved to U-space service providers at federal level and U-space airspace in Dubai’s 2025 UAS regulation. In other words, the UAE is not merely permitting drones; it is building traffic rules for them. The real legal dividing line is export control Many aerospace businesses assume they are safely on the civil side of the fence until a software module, sensor, propulsion component, encryption feature, maintenance dataset or engineering support package pushes them into dual-use territory. That is where the UAE’s non-proliferation regime matters. Cabinet Resolution No. 97 of 2024, the executive regulation under Federal Decree-Law No. 43 of 2021, defines “permit” in a way that reaches import, export, re-export, transshipment, in-transit shipping, transport between ports and brokerage. Even the structure of the executive regulation is revealing: it contains dedicated articles on records keeping, inspection procedures, seizure, detainment of commodities and appeals. This is not symbolic legislation. It is a functioning compliance system. The territorial point matters too. The law applies across the UAE, including free zones. That single detail is enough to upset a common assumption that a free zone structure somehow neutralises export-control risk. It does not. In practice, the harder questions are often not about shipping a finished product out of the country, but about technical data, end-user documentation, re-export chains, brokerage arrangements and whether a transaction has drifted from “commercial aviation support” into a controlled technology transfer. Defence regulation in the UAE is a national security regime, not just a sectoral one Federal Decree-Law No. 17 of 2019 is broader and sharper than many readers expect. “Military materiel” is defined to include aircraft, boats, submarines, machinery, equipment, devices, unmanned systems, ammunition, explosives and weapons used for military purposes, as well as related parts, spare parts, technology and manufacturing devices. That definition matters because it collapses the comfortable distinction between a finished platform and the technology stack behind it. The operational reach of the law is equally broad. Article 3 provides that possession, acquisition, carrying, import, export, re-export, transit, trans-shipment, trade, manufacture, repair, transportation and disposal of weapons, ammunition, explosives, military materiel and hazardous substances are not permitted without the relevant licence or permit. The licensing authority may refuse to grant or renew licences and may add restrictions, and the law establishes a dedicated Weapons and Hazardous Substances Office within the national security structure. This is exactly the point at which a conventional commercial mindset becomes dangerous: in the UAE defence space, regulatory discretion is part of the system, not an exception to it. The penalty landscape is even more revealing. Unlicensed trading in, importing, exporting or manufacturing explosives or military materiel can trigger temporary imprisonment and a fine of at least AED 500,000. The unauthorised leakage or publication of plans, drawings, documents, information or data relating to weapons, ammunition, explosives or military materiel can attract life imprisonment and a fine of at least AED 500,000. Even repair activity without a licence is criminalised. For defence contractors and technology suppliers, the message is obvious: this is not a back-office licensing exercise; it is a core national-security compliance issue. Foreign ownership is liberal in the UAE, except where it is not The UAE has rightly advertised its openness to full foreign ownership across much of the economy. Official government guidance confirms that foreigners can establish companies with 100 percent ownership in many mainland activities. But aerospace and defence readers should focus on the carve-out, not the headline. Cabinet Resolution No. 55 of 2021 places security, defence and activities of a military nature on the list of “strategic impact” activities. For those activities, the Ministry of Defence and Ministry of Interior may determine not only the percentage of national participation in capital, but also the percentage of national participation on the board. That is a sophisticated control tool, and it tells you everything about how the UAE balances investment openness with sovereign oversight. This is why structuring questions in the UAE cannot be left to corporate housekeeping at the end of a transaction. The ownership analysis may change depending on whether the activity is genuinely civil, dual-use, defence-adjacent or plainly military. Free zone location, shareholder mix, board composition, licensing sequence and the identity of the actual operating entity all matter. The legal issue is not simply “Can a foreign investor own this?” It is “What exactly is the regulated activity, and who gets to say so?” The most interesting part of the UAE story is that policy, industry and regulation are moving together This is what makes the market more dynamic than a dry statute-by-statute summary suggests. On the civil side, the UAE’s 2023 sustainable aviation fuel policy aims to raise domestic SAF production capacity to 700 million litres annually by 2030, support research and development, create a national regulatory environment for production plants and build in-country value. The GCAA also states that its CORSIA implementing decree was the first legislation of its kind in the Arab region approved by the PMO. That is not a country sleepwalking into compliance. It is a country trying to shape regional practice. On the defence side, the industrial narrative is equally visible. Dubai Airshow 2025 described a week of breakthroughs, partnerships and industry-shaping discussions, while EDGE said it unveiled 42 new products across air, space, autonomy, propulsion, radar and secure communications, and that more than 53 percent of its revenue was export-driven. Even allowing for the promotional character of a company release, the strategic direction is clear: the UAE is building industrial depth, not merely acting as a procurement market. That matters legally because industrial depth generates more IP, more technology transfer, more data movement, more export-control touchpoints and more security review. Conclusion The UAE’s aerospace and defence framework is best understood as a system of classification and sequencing. Classification, because the outcome depends on whether a product or service is civil, unmanned, dual-use, defence-related or strategically sensitive. Sequencing, because approvals obtained in the wrong order can damage timetable, structure, cost and sometimes the viability of the deal itself. The businesses that succeed in this market are usually the ones that map those issues early: they classify products and data, separate civil from defence support, check export-control implications before sharing technology, address ownership and board constraints at the structuring stage, and treat drone operations as aviation activity rather than consumer tech. The UAE is open for aerospace and defence business. It is simply not casual about it.   Authors Ilya Dvorkin Partner, HAS Law Firm [email protected] Samara El Doukhei Paralegal, HAS Law Firm [email protected]

Introduction Rental disagreements are more common in Dubai than many people realize. With thousands of new tenancy agreements signed each year, most go smoothly, but issues still arise at the time of the lease. A landlord may increase rent without prior informing the tenant, and the landlord may face delayed rent payments or issues with damage to the property. Other common issues include eviction notices, maintenance responsibilities, or getting the security deposit back at the end of the lease. If these problems get worse, it often helps to talk to a landlord-tenant lawyer in Dubai. A lawyer can look over the tenancy agreement, review the communication between both sides, and explain how UAE tenancy laws apply to your case. For many residents, especially expatriates, the legal process can be confusing. Learning the basics of tenancy law is the first step. The Legal Framework Governing Tenancy in Dubai Landlord and tenant relationships in Dubai are primarily subject to Law No. 26 of 2007, later amended by Law No. 33 of 2008. Legal responsibilities of both the landlord and the tenants during the tenancy period are mentioned and explained under this law. The legislation addresses several key issues, including: procedures for raising the rent Rules for giving an eviction notice How to renew a tenancy agreement maintenance responsibilities Responsibilities for the security deposit If a dispute comes up and the parties cannot settle it on their own, the case can be taken to the Rental Disputes Settlement Centre (RDC). This tribunal is part of the Dubai Land Department and handles tenancy disputes. The RDC process often takes less time than going to court. However, you still need to have the correct documents and follow the required legal steps. Having an experienced landlord-tenant lawyer in Dubai can really help here. Situations That Commonly Lead to Tenancy Disputes Many tenancy disputes in the UAE start with everyday situations. A small disagreement can quickly turn into a formal dispute if the landlord and tenant see the contract differently. Some of the most common disputes include: Eviction notices Eviction is allowed in some cases, but there are strict rules. For example, if a landlord wants to evict for personal use or to sell the property, they usually need to give 12 months’ written notice through a notary public or by registered mail. Rent increase disputes Dubai’s rental rules set limits on when and how rent can go up. Most of the time, landlords have to give at least 90 days’ notice before renewing the lease. Unpaid rent If rent is not paid, landlords can start legal action through the RDC after giving the right notice. Security deposit disagreements Disagreements often happen when tenants move out, and money is taken from their deposit. Responsibilities regarding repairs and maintenance Often arguments arise between landlords and tenants over who bears the expenses for repairs, especially if these details are not mentioned in the tenancy agreements. A landlord-tenant lawyer in Dubai can help when such issues arise, leading to a solution or guidance according to UAE law. Why Many People Seek Legal Advice Early Landlords and tenants can represent themselves at the Rental Disputes Settlement Centre, but many people prefer to talk to a lawyer before starting. Usually, legal advice starts with a simple review of documents. These might include: the tenancy contract Ejari registration certificate payment records emails or written communication between the parties eviction notices or rent increase notices These documents often reveal where the issue began. For instance, a rent increase may not have included the correct notice period, or an eviction notice may not have followed the proper legal process. Lawyers who handle property disputes often see the same issues. Many conflicts happen just because one side is not sure about the legal rules in Dubai’s tenancy law. In tenancy disputes in the UAE, lawyers like Mrs. Awatif Al Khouri, who have experience with civil and commercial cases in the UAE, usually start by reviewing the tenancy agreement and related documents. Often, once everyone understands the legal position, both sides can settle without a long court process. Formal proceedings at the Rental Disputes Settlement Centre may be needed if negotiations between parties do not work out. Filing a Case Before the Rental Disputes Settlement Centre Either side can file a claim with the RDC if a tenancy dispute cannot be settled by negotiations. Below are a few simple steps to follow: Preparing the tenancy contract and Ejari certificate. Submitting identification documents and supporting evidence. Filing the case through the RDC system or through the Dubai REST application. Paying the required filing fee. Attending hearings scheduled by the tribunal. The RDC makes a decision, and these decisions are legally binding and can be enforced by the authorities. Practical Steps That Help Avoid Tenancy Disputes While there are legal solutions, it is always better to prevent disputes. Taking a few simple steps can make a big difference. Ensure the tenancy contract is properly registered with Ejari. Keep written records of important communication. Follow the correct legal procedure when issuing rent increases or eviction notices. Address maintenance concerns early and document them in writing. Seek legal advice before taking major legal action. Conclusion Dubai’s rental market is always changing, and disagreements between landlords and tenants can still happen even with clear contracts and rules. Knowing how tenancy law works in the UAE helps both sides protect their rights and avoid conflict. If a dispute does happen, talking to a landlord-tenant lawyer in Dubai can make your legal options clear. Experienced lawyers, like Mrs. Awatif Al Khouri, often help clients by reviewing tenancy agreements, settling disputes through negotiation, and representing them at the Rental Disputes Settlement Centre if needed. Getting legal advice early often leads to a quicker and more practical solution for both landlords and tenants. Author: Awatif Al Khouri

Real Estate Market in Dubai is one of the most attractive sector, an investment hub for investors and also for people planning to relocate. To maintain a sense of order and equity in this vibrant market, the Emirate has put in place a robust legal structure governing the interactions between landlords and tenants. This relationship is primarily anchored in Dubai Law No. 26 of 2007, as amended by Dubai Law No. 33 of 2008 (the "Tenancy Law"), and is supported by Dubai Decree No. 26 of 2013, which provides the mechanism for dispute resolution under Dubai tenancy regulations. Understanding the rules that protect both landlords and tenants is important. The article below is a breakdown of the landlord-tenant relationship to help navigate when disputes arise. I. The Basis of the Relationship: Transfer and Maintenance In most cases, landlords must handle major repairs and keep the building safe, unless both parties have a different written agreement under Dubai tenancy law. If a landlord doesn't fix these problems in a reasonable amount of time, tenants can tell the authorities about the problem or take legal action, like filing a rental dispute Dubai claim. The law also protects tenants from being treated badly. For example, Article 34 says that landlords can't turn off basic services like water, electricity, or air conditioning, no matter what the disagreement is about. This strengthens tenant rights in Dubai. Maintenance Responsibilities: One of the most common points of contention in Dubai is the responsibility for repairs. Article 16 clarifies that the landlord is responsible for the maintenance and repair of any "defects or faults" that affect the tenant's intended use of the property throughout the duration of the lease. This includes significant issues such as: Problems like faulty plumbing and leaks Electrical malfunctions can also be an issue. Structural flaws in the building that affect safety Many contracts have a "minor maintenance" clause, which means tenants pay for small repairs under a certain amount, like AED 500. Unless both parties agree in writing, the responsibility of major repairs usually lies with the landlord, reflecting standard Dubai rental law guide practices. These problems need to be fixed within a reasonable time by the landlord; if not, the tenant can report the issue to the authorities or take legal action. It provides protection to the tenants from unfair landlord behavior and strengthens tenant rights in Dubai. II. Eviction Process and Tenant Protection Eviction is a sensitive area of the law, and Dubai provides definitive rules to prevent arbitrary displacement under Dubai tenancy law. Tenants have a "Right to Renewal" if they have fulfilled their contractual obligations, which means a landlord can't refuse to renew a lease without a valid, legally recognized reason, an important aspect of tenant rights in Dubai. Article 25(1) states that a landlord can only request eviction before the contract ends under specific circumstances Unauthorized Subletting: Renting out the property to someone else without getting written approval from the landlord. Illegal Use: Using the property in ways that go against public order or accepted moral standards. Damage and Endangerment: Making changes that could risk the property’s safety, or causing damage either on purpose or by being careless. Breach of Contract: Failing to follow any part of the lease within 30 days after being asked to correct the problem. Commercial Abandonment: For business premises, leaving the property unoccupied for 30 consecutive or 90 non-consecutive days in a single year. These provisions balance landlord rights in Dubai with tenant protections. Eviction Upon Expiry (12-Month Notice): If a landlord wants to reclaim the property for reasons other than the tenant breaking the lease, Article 25(2) requires a strict notice period under Dubai landlord-tenant law. Acceptable reasons include: Demolition or Reconstruction: Required by urban development or chosen by the owner with the right permits. Major Maintenance: This applies when repairs or upgrades cannot be completed while the tenant is living in the property, and a technical report confirms this. Personal Use: The owner can end the tenancy if they want to live in the property or have a close family member move in, as long as they show they do not have another suitable place to live. Sale of the Property: The owner can end the tenancy if they plan to sell the property. The landlord must give the tenant at least 12 months' notice in these situations. For this notice to be legally binding in Dubai, it must be sent by a Notary Public or registered mail, which is very important under Dubai tenancy regulations.. III. Dispute Resolution: The Role of the RDSC When a relationship breaks down, whether due to "apartment malfunctions" or "unjust eviction," the Rental Disputes Settlement Center (RDSC) serves as the specialized judicial forum for the resolution of any rental dispute or landlord-tenant dispute in Dubai. Established by Dubai Decree No. 26/2013, the RDSC was created to provide a "simple and expeditious mechanism" for settling rental conflicts in Dubai and its free zones under Dubai rental law guide principles. The Process of Resolution: The RDSC is designed to favor mediation over litigation initially. The Arbitration and Reconciliation Department was established according to Article 10 of the law. It facilitates settlement through mediation and documents the settlement through a binding contract, and if the settlement fails, it proceeds to the judge for a formal ruling. If the RDSC determines that an eviction was wrongful, for example, if the tenant was evicted by the landlord for personal use but then immediately re-leased the property to a new tenant, the former tenant may be entitled to compensation for the moving costs, the difference in rent for a new property, and also for inconvenience, further reinforcing tenant rights in Dubai. IV. Practical Advice for Landlords and Tenants To keep a good working relationship and avoid a landlord-tenant dispute in Dubai, the RDSC, both landlords and tenants can follow these practical tips under the Dubai landlord-tenant law guide:: Keep Good Records: Landlords should keep proof for any reason they might need to evict a tenant. Tenants should save copies of maintenance requests and rent payments. Register with Ejari: In Dubai, it is required by law to register every tenancy contract through the Ejari system as part of Dubai tenancy regulations. Formal Correspondence: Do not rely only on instant messaging for important notices. For eviction notices, use a Notary Public to ensure they meet the requirements of Article 25. Access to Property: Tenants in Dubai have the right to remain in their home and keep all the benefits of their lease until the eviction process is finished, according to the tenant rights in Dubai. Conclusion In Dubai, landlords and tenants are required to obey the law. The restrictions are there to protect landlords' money and make sure they can get their property back when they need to, as long as they follow the Dubai tenancy law. The legislation also performs a superb job of preventing renters from being kicked out unfairly and from living in substandard conditions. So, both sides need to be well familiar with Dubai Law No. 26 of 2007. The Rental Dispute Settlement Center (RDSC) is where landlords and tenants may go to settle any issues. This makes the real estate market in Dubai work more smoothly, clearly, and confidently. Author: Awatif Al Khouri