Allocation Of Competition Law Enforcement Powers In The UAE

Over the past years, the UAE's competition law regime has undergone a period of significant transformation. The first major step came with the adoption of the new Competition Law, which modernized the UAE's competition regime by introducing revised substantive and procedural rules governing anti-competitive agreements, abuse of dominance, and merger control.

Prior to the introduction of the new Competition Law, enforcement remained modest, particularly in the field of merger control. This was primarily due to the high notification threshold of 40% market share as well as the numerous exemptions from the application of the old Competition Law. This changed significantly in 2025 with the (1) the new Competition Law abolishing nearly all exemptions, and (2) the adoption of Cabinet Decision 3/2025, which introduced a turnover-based merger notification threshold in addition to the existing market share threshold. Given the UAE's position as one of the Middle East's principal investment