UAE Competition Law — What Businesses Must Know Guide 2026
UAE’s Federal Competition Law (Federal Law No. 4 of 2012, amended by Federal Law No. 36 of 2023) prohibits anti-competitive behaviour and regulates mergers. Understanding UAE competition law is essential for businesses operating in concentrated markets or considering M&A. This guide covers UAE competition law for businesses in 2026.
In this guide:
UAE Competition Law Overview
- Primary law: Federal Law No. 4 of 2012 on Regulating Competition; significantly amended by Federal Law No. 36 of 2023 to modernise and strengthen enforcement
- Regulator: Ministry of Economy (MoE) Competition Department; responsible for enforcement and merger notifications
- Scope: applies to any business activity that affects the UAE market, including international companies whose conduct has UAE market impact; some sectors have sector-specific competition oversight (telecoms — TRA; financial services — CBUAE)
UAE Competition Law Prohibitions
Restrictive Agreements
- Prohibited: horizontal agreements between competitors (cartel agreements) that fix prices; divide markets or customers; restrict output or capacity; coordinate bids (bid rigging in tenders)
- Prohibited: vertical agreements (between a supplier and distributor) that fix minimum resale prices (resale price maintenance); grant absolute territorial exclusivity that prevents parallel imports
- Exemption: agreements that improve production, distribution, or promote technical/economic progress may be exempted; apply to MoE for exemption decision
Abuse of Dominant Position
- Dominant position threshold: a business is presumed dominant if it controls 40%+ of the relevant market
- Prohibited conduct: predatory pricing (below cost to eliminate competitors); refusing to deal with competitors on essential facilities; tying arrangements; excessive pricing; discriminatory conditions applied to comparable customers
UAE Merger Control
- Pre-merger notification: required before completing a merger, acquisition, or joint venture that meets the thresholds below
- Thresholds: combined UAE market share of parties exceeds 40%; OR combined UAE annual turnover of the parties exceeds AED 3 million (note: relatively low threshold; many SME transactions may technically trigger notification)
- Process: notify MoE; MoE has 90 days to review; can approve, approve with conditions, or prohibit
- Gun-jumping: completing a merger before MoE approval (or without notifying when required) is a serious violation; substantial fines apply
UAE Competition Law Penalties
- Fines for prohibited agreements: AED 500,000-5,000,000; or 2-10% of annual UAE turnover (higher amount applies)
- Fines for abuse of dominance: AED 500,000-5,000,000
- Merger violations (gun-jumping or prohibited merger): up to 10% of annual UAE turnover
- Individual officers: can be held personally liable for competition violations; fines up to AED 1,000,000