Anti-trust law Dubai: UAE competition rules for investors

Which competition rules should a Dubai investor check in 2026?

Start from the Ministry’s competition legislation list, checked 9 November 2026, and retain the instrument number beside any advice:

The Ministry lists all four instruments. Ask for the current government-fee calculation separately from your legal-advice quote.

What conduct does UAE competition law address?

The law addresses restrictive agreements, abuse of dominance and economic concentrations. Article 5 includes price fixing, bid collusion and market/customer allocation; Article 6 addresses abuse, rather than treating size alone as wrongdoing. Article 3 includes activities outside the UAE affecting competition inside it. Article 12 provides for an application at least 90 days before completion where its conditions apply. This is not a guaranteed approval period. Source: official indexed law text, checked 9 November 2026; complete current procedure requires legal confirmation.

If your arrangement involves a property business, ask:

Have the adviser assess the actual arrangement. The A2A agreement guide explains a different contract relationship; a cooperation label does not answer the competition question.

What are the economic-concentration thresholds?

Cabinet Decision 3/2025, Article 3, checked 9 November 2026, sets alternative thresholds for the Article 12 test:

Article 2 separately uses an over-40% ratio for dominance. Dominance and a notification assessment are different questions. Use the relevant UAE-market sales, not the deal price or the company’s entire global turnover.

Fictional arithmetic example: suppose an adviser has established the relevant UAE market and included parties. Sales of AED 180 million plus AED 140 million total AED 320 million, above the sales threshold. The addition does not establish that your deal is notifiable: the market definition, scope, structure and any applicable exclusions still need assessment. Falling below both thresholds doesn’t settle whether other conduct complies with the law.

What should go in the review file?

Send your adviser a file that answers these questions:

1. Describe the proposed transaction or arrangement in plain language, with draft agreements and proposed signing/completion dates.
2. Map legal entities, owners, control relationships and the assets or shares changing hands.
3. Give the adviser financial statements and a source-labelled sales breakdown; identify missing or estimated inputs.
4. Describe products/services, customers, geography and possible alternatives without asserting a market definition yourself.
5. Ask for a written scope, threshold and filing assessment, including the current instrument versions and any authority consultation needed.
6. Reconcile closing conditions, required approvals and contractual dates before making an irreversible commitment.

If the file includes a property acquisition, keep the SPA and unit-document checks separate. For development rights, the Musataha guide helps identify the agreement being reviewed. Neither supplies competition clearance.

Please identify the current competition instruments, relevant market and included entities; explain whether an application or exemption assessment is needed; and give the government-fee basis, required documents, authority route and closing restrictions in writing.

Where should you take a competition concern?

Use the official Ministry of Economy & Tourism competition legislation/service routes and the Dubai government business-rights directory. The directory links competition complaints and exemption enquiries. Ask the Ministry which service and current requirements apply.

Keep dated documents, describe observable events and ask the authority or adviser which route fits. Avoid presenting similar prices or an unpopular contract term as proof of collusion. A rental dispute or cancelled-project issue may require a different authority and evidence file.

FAQ

Is Federal Law 4 of 2012 the current starting point?

No. Start with the replacement 2023 decree-law and check the later instruments in the official directory. Do not copy a legacy guide's references without checking them.

Does buying a Dubai apartment automatically require merger clearance?

Describe the actual assets, business and control changes to an adviser; an apartment price alone cannot answer the scope question.

Is a 40% market share proof that a company broke the law?

No. A threshold or market position does not establish a violation. A legal assessment needs the relevant facts and applicable provisions.

Can I budget a fee or assume approval within 90 days?

Get the current official fee assessment and a timetable for your transaction. The law’s advance-filing requirement doesn’t promise approval within 90 days.