UAE Trends and Developments Contributed by: Winsome Cheung and Haykel Hajjaji, Covington & Burling LLP
Supply chain and localisation considerations Supply chain resilience has become a major policy priority, particularly in response to recent global dis- ruptions. Authorities are encouraging local production of essential medicines and medical products, as well as diversification of sourcing strategies. For companies, this presents both opportunities and expectations. Local manufacturing and technology transfer may provide advantages in regulatory and procurement contexts but require careful assessment of feasibility, scale, and cost. Commercial structures and market entry The evolution of the life sciences regulatory environ- ment has coincided with broader reforms to the UAE’s commercial and corporate framework. Companies entering the market must consider corporate struc- turing, distribution models, commercial agency rules, and competition law. Although reforms have increased flexibility in owner- ship and commercial structures, regulated activities still require alignment between corporate form and regulatory approvals. The identity of the licensed enti- ty, its operational location, and the scope of author- ised activities must all be consistent across corporate and regulatory documents. Distribution arrangements remain a key consideration. While reforms have reduced some of the rigidity of his- toric commercial agency rules, legacy arrangements and sector‑specific norms continue to shape market entry strategies. Digital health and technology integration Digital health continues to grow across the UAE health- care system. Telemedicine and remote care services are supported by established federal and Emirate‑lev- el regulatory frameworks addressing licensing, stand- ards of care, data security, and professional liability. These frameworks have enabled continued adoption of digital healthcare services beyond the pandemic, with telehealth increasingly integrated into routine care. Providers must meet the same clinical and ethi- cal standards as in‑person care, and certain services
remain restricted where physical examination is nec- essary. In parallel, the UAE’s national strategy for artificial intelligence is shaping the development and deploy- ment of AI‑enabled tools in diagnostics, research, and healthcare delivery. Regulatory expectations centre on transparency, accountability, and human oversight, which will influence future approvals of AI‑driven medical technologies. Data protection and health data governance Data governance is a critical consideration for life sciences operators in the UAE. The Federal Personal Data Protection Law applies to the processing of per- sonal and sensitive health data, including clinical trial and genetic data. Although executive regulations continue to develop, organisations are expected to implement governance frameworks aligned with international data protection standards. Particular focus is required for cross‑bor- der data transfers, data localisation, and breach noti- fication obligations. Health data is also governed by federal and Emir- ate‑level frameworks, including Federal Law No 2 of 2019, and regulations issued by the Abu Dhabi Department of Health and the Dubai Health Author- ity. Health data must remain confidential and may not be stored, transferred, or processed outside the UAE. The transfer of health data is also regulated by Ministerial Decision No 51 of 2021, which sets out restrictions and exemptions relating to the transfer of health data. Approval from the Emirate-level regula- tors is required for the transfer of health data outside of the UAE in certain cases. For companies operating across multiple jurisdictions, aligning UAE‑specific requirements with global data governance programmes remains challenging – par- ticularly where research or digital health operations rely on centralised data platforms. Outlook The UAE life sciences sector is characterised by rapid regulatory evolution, significant public investment and strategic direction. While the regulatory environment is
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