UAE Competition Law — Anti-Monopoly Rules for UAE Businesses 2026
UAE Federal Law No. 4 of 2012 on Competition Regulation (as amended by Federal Decree-Law No. 36 of 2023) governs competition and anti-monopoly rules in UAE. UAE’s competition law framework is becoming increasingly active. This guide covers UAE competition law for businesses in 2026.
In this guide:
UAE Competition Law Framework
- Federal Law No. 4 of 2012 (as amended 2023): prohibits anti-competitive agreements and abuse of dominant market position
- Enforcement authority: UAE Ministry of Economy (MoE) Competition Department
- Exemptions: certain sectors exempt: oil and gas, telecom (regulated separately), financial services, government entities
- Free zone applicability: UAE competition law applies to free zone companies if their conduct affects the UAE domestic market
Prohibited Anti-Competitive Conduct
- Price fixing: agreements between competitors to fix prices (horizontal price fixing) are prohibited; cartel-equivalent
- Market allocation: agreements to divide UAE market geographically or by customer segment between competitors
- Output restriction: agreements limiting production volume to maintain high prices
- Bid rigging: coordinating tender bids to predetermined winners
- Abuse of dominant position: dominant companies cannot impose unfair terms, predatory pricing, or refuse access to essential facilities
UAE Merger Control
- Mandatory filing: mergers and acquisitions involving UAE parties above certain turnover thresholds must be notified to UAE MoE BEFORE completion
- Thresholds: combined UAE market turnover of parties exceeds AED 300M (approximately); check current thresholds with UAE competition counsel
- Review period: MoE has 90 days to approve, conditionally approve, or block a notified transaction
UAE Competition Law Penalties
- Anti-competitive agreements: fines of 10% of annual revenues of offending company in relevant market; can be cumulative
- Abuse of dominant position: similar fines; plus corrective measures (divestiture, behavioural remedies)
- Failure to notify merger: fines up to AED 5M; transaction may be unwound
Competition Law Compliance for UAE Businesses
- Trade association participation: be careful of information sharing between competitors at UAE industry events or trade associations; even indirect price discussions can be problematic
- Distribution agreements: vertical restraints (exclusive territories, minimum resale price maintenance) are regulated; seek UAE competition advice before implementing
- Dominant company considerations: if your UAE business is dominant in a market (30%+ market share), additional care required in pricing and terms