UNITED ARAB EMIRATES Law and Practice Contributed by: Francesco Bulleri, Beshoy Mounir, Sultan Bahriddini and Noora Al Doseri, ADG Legal
The UAE National Strategy for Artificial Intelligence 2031 The UAE National Strategy for Artificial Intelligence 2031, introduced in October 2017, reinforces the need for strong governance and effective regulation, recog - nising that the increasing adoption of AI creates risks to society, cybersecurity vulnerabilities, and broader economic and operational exposure. The strategy envisages the development of governance frame - works, regulatory review mechanisms and interna - tional co-operation to ensure AI systems are deployed safely and responsibly. The DIFC Data Protection Regulations The DIFC Data Protection Regulations, introduced in 2020, were amended in 2023 to address the use of autonomous and semi-autonomous systems (such as AI) in the context of personal data processing, high - lighting both its growing importance and the associ - ated risks. The framework requires organisations to adopt appropriate safeguards to protect personal data, and regulates how data is used in digital and communication services, including obligations around transparency and privacy-focused configurations to align with evolving AI applications. Other Key Developments Regarding AI Developments relating to AI governance and regu - lation continue to emerge in the UAE. In 2025, this included the introduction of mechanisms designed to support the integration of AI into the legislative pro - cess through the Regulatory Intelligence Office. The UAE has also established dedicated governmen - tal bodies and initiatives focused on AI development and governance, including the Ministry of State for Artificial Intelligence and the UAE AI Office, which have played a key role in developing national AI strat - egies, ethical guidance and broader governance initia - tives. While the UAE has seen increasing policy and regulatory attention directed towards AI governance and responsible AI use, there is currently no generally applicable UAE legislation expressly requiring specif - ic corporate governance structures for AI oversight, such as prescribed board composition requirements, dedicated AI committees or formalised AI governance frameworks.
In practice, responsibility for AI-related strategy, risk management and oversight would typically fall with - in the remit of the board of directors under general corporate governance principles, often supported through internal risk, audit, technology or compliance functions. 8.3 Liability Exposures Arising From AI Use There is no standalone AI regime in the UAE that tack - les liability exposures for boards and officers arising from AI use, or any specific enforcement authorities. AI-related liability issues are addressed through exist - ing legislation, such as the following. Federal Decree-Law No 25 of 2025 (the “Civil Transac - tions Law”) provides a general framework for liability arising from negligent conduct, which may extend to situations where harm results from the design, deploy - ment or oversight of AI systems. Federal Decree-Law No 45 of 2021 on Personal Data Protection plays a key role in the AI context by requir - ing organisations to handle personal data in a lawful and controlled manner. It also obliges entities to put in place appropriate controls to reduce the risk of AI sys - tems producing outputs that breach applicable laws. Federal Decree-Law No 38 of 2021 on Copyright and Neighbouring Rights, together with Cabinet Decision No 47 of 2022, forms the core federal IP framework applicable to AI-related assets, including algorithms, inputs and outputs. This regime is particularly relevant in regulating the use of third-party intellectual prop - erty, which is often embedded in AI systems that rely on large datasets and existing content. 8.4 Key Disclosure Requirements for AI Use At present, there are no mandatory disclosure require - ments relating to AI use, strategy, governance, risks, incidents or controls.
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