UAE Law and Practice Contributed by: Amir Alkhaja, Areen Jayousi, Gulsun Ozmen and Alia AlMarzooqi, Habib Al Mulla & Partners
8.3 Role and Authority of the Data Protection Agency The UAE Data Office was established as the com - petent supervisory authority under the PDPL and is responsible for enforcing the law, issuing binding deci - sions and guidance, and administering the data pro - tection register. The UAE Data Office has the power to investigate complaints from data subjects, conduct audits of data controllers and processors, issue com - pliance notices and impose administrative penalties, including significant fines for breaches of the PDPL. Within the DIFC, the Commissioner of Data Protection exercises equivalent supervisory and enforcement functions; within the ADGM, those functions are per - formed by the Office of Data Protection. The most significant near-term legislative development across the UAE’s general legal landscape is Federal Decree-Law No 25 of 2025, which comprehensively revises the UAE Civil Transactions Law, the principal statute governing contract, tort and obligations law in the UAE, and which comes into force on 1 June 2026. The new law makes material amendments to core provisions, including those governing force majeure, hardship, contractual liability and the general theory of obligations, and businesses with existing long-term contracts governed by UAE law should review their agreements in light of these changes, particularly pro - visions addressing supervening events, price adjust - ment mechanisms and remedies for breach. Corporate Tax 9. Looking Forward 9.1 Upcoming Legal Reforms Civil Transactions Law The UAE’s corporate tax regime remains in a period of active development. The Federal Tax Authority contin - ues to issue guidance on the application of key provi - sions, including the free zone qualifying income rules, transfer pricing documentation requirements and the QDMTT, and further implementing decisions and clarifications are anticipated, particularly in relation to cross-border transactions, the interaction between the corporate tax regime and the UAE’s expanding network of double tax treaties, and the treatment of specific industry sectors.
Artificial Intelligence Regulation The UAE is actively developing a regulatory framework for artificial intelligence (AI), consistent with its Nation - al AI Strategy 2031. Sector-specific AI guidance has been issued in certain regulated industries, including financial services and healthcare, and broader hori - zontal AI legislation is anticipated in the near term, with businesses deploying AI systems in the UAE, particularly in areas involving automated decision- making, employment or the processing of personal data, encouraged to monitor legislative and regulatory developments closely. AML/CFT and Beneficial Ownership Transparency The UAE has undertaken substantial reform of its anti- money laundering and counter-terrorism financing framework in recent years, and continued refinement is expected. Enhanced beneficial ownership transpar - ency requirements applicable to both onshore and free zone entities are already in force; further align - ment with Financial Action Task Force (FATF) recom - mendations and active enforcement by the supervi - sory authorities, including the Central Bank, the SCA and the Ministry of Economy, is anticipated. Competition Law Federal Decree-Law No 36 of 2023 significantly updated the UAE’s competition regime, expanding the scope of merger control notification obligations and enhancing the Ministry of Economy’s investiga - tive and sanctioning powers. The full implementation of the 2023 law – particularly after the issuance of its implementing regulations in 2026 – including enforce - ment guidance, is ongoing, and businesses consid - ering mergers, acquisitions or commercial arrange - ments that may affect competition in UAE markets should take careful account of the updated thresholds and procedural requirements.
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