Merger Control 2026

UAE Law and Practice Contributed by: Alex Saleh, Asad Ahmad, Khaled Abu Orabi and Khaled al-Khashab, GLA & Company

7. Third-Party Rights, Confidentiality and Cross-Border Co-Operation 7.1 Third-Party Rights See 3.9 Pre-Notification Discussions With Authori - ties . 7.2 Contacting Third Parties The Competition Department may contact third par - ties in any way it considers appropriate. This can include phone calls, emails, written letters (which can be sent by mail or electronically) or interviews with third parties (interviews are most likely to take place at the offices of the Competition Department). Where basic information about an economic concen - tration is published on the relevant authority’s website, interested parties may submit views, supporting data or documents within 15 business days from the date of publication or invitation, as applicable. Any formal objection must be supported by relevant evidence and documents. The authority examines the objec - tion from a formal perspective within five business days and, if the objection is accepted for review, may require the parties to the economic concentration to respond within ten business days. 7.3 Confidentiality The Competition Law requires the Ministry’s employ - ees to take steps to keep sensitive information (which could cause serious damage if disclosed) confidential. In this regard, the Ministry’s employees are not per - mitted to disclose any information reviewed as part of the notification application unless the disclosure is to the concerned parties or at the request of the relevant authorities. Violating the confidentiality duties could, under the Competition Law, lead to a fine of between AED50,000 and AED200,000 being imposed. Confidential documents submitted as part of the noti - fication application should be marked “confidential” and non-confidential summaries should be provided to allow sufficient understanding of the confidential content. The same approach applies to confidential materials submitted in complaints or related proceed - ings.

7.4 Co-Operation With Other Jurisdictions There is no obligation for or prohibition of, the Ministry to co-operate with other regulators in other jurisdic - tions. 8. Appeals and Judicial Review 8.1 Access to Appeal and Judicial Review Any concerned party can request the Minister review a competition decision adopted by them within 14 days of the date the applicant became aware of the decision. The request should be in writing, explain the grounds on which it is being made and attach all nec - essary supporting documents. The Competition Committee will, in return, review the request and submit its recommendations to the Minis - ter within ten days of the date on which the application was referred. The Minister should adopt a final decision within 30 days of the request being filed. If a decision is not adopted within this timeframe, the request will be con - sidered to be rejected. Decisions issued by the Minister can be appealed before the competent court within 60 days of the con - cerned parties being notified of the Minister’s deci - sion. However, the Minister may enter into a settlement with “undertakings” that have breached the Competition Law, except for breaches involving unauthorised dis - closure of confidential information protected under the Competition Law. Under Cabinet Resolution No 59 of 2026, settlement with breaching “undertakings” is subject to the fol - lowing. The settlement must be in writing, signed by the breaching parties and include an express acknowl - edgement by the breaching undertakings of the offences committed in breach of the Competition Law. • The settlement must require payment of the amount determined by the authority within 30

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