Cartels 2026 Comparisons

The principal legislation governing cartel conduct and anti-competitive practices in the UAE is Federal Decree-Law No (36) of 2023 Regulating Competition (the “Competition Decree-Law”), which repealed Federal Law No (4) of 2012 Regulating Competition.

Key implementing instruments include the following.

• The Competition Decree-Law is supplemented by Cabinet Decision No (59) of 2026 issuing the new Competition Executive Regulation, which will enter into force on 31 July 2026 and replaces Cabinet Decision No (37) of 2014.
• Other important implementing regulations and sector-specific competition decisions include:
1. Cabinet Decision No (3) of 2025 on the Thresholds Related to the Implementation of Federal Decree-Law No (36) of 2023 Regulating Competition;
2. Ministerial Decision No (32) of 2026 on the Block Exemption of Exclusive Dealing Agreements in the Market for Food Promotion and Delivery Services through Digital Platforms;
3. Ministerial Decision No (74) of 2026 on the Prohibition of Increasing Prices of Land Transport Services and Port Operational Services During Emergency Circumstances;
4. Ministerial Decision No (82) of 2026 on the Adoption of the Technical Guide for the Mechanism of Calculating Increases in the Prices of Land Transport, Handling, Customs Clearance and Delivery Services in Line with Changes in Fuel Prices; and
5. Ministerial Decision No (96) of 2026 Regarding Granting a Temporary Exemption to Certain Agreements and Categories of Contracts Aimed at Ensuring the Continuity of Supply of Essential Goods and Services in Exceptional Circumstances.

Enforcement Agencies

Ministry of Economy (the “Ministry”)

This is the primary enforcement federal authority responsible for administering and enforcing the Competition Decree-Law. The Ministry, acting through its Competition Department, is responsible for supervising the implementation of the law, receiving and investigating complaints, monitoring anti-competitive practices and economic concentrations, requesting information and documents, and issuing recommendations and decisions regarding violations, exemptions and merger control matters.

Relevant authorities

These are the competent local emirate-level authorities, which may act where the relevant undertakings are situated in the same emirate and the impact of the practices does not extend beyond that emirate’s borders.

Sectoral regulatory agencies

The federal authorities are empowered under their governing legislation to regulate, monitor or supervise a specific economic sector in the UAE. Under the 2023 Decree-Law, their role has shifted toward closer co-ordination with the Ministry, as the new law applies to all economic activities unless specifically exempted by a Cabinet Decision.

The Competition Regulatory Committee (the” Committee”)

The Committee was established pursuant to the Competition Decree-Law as a specialised committee reporting to the Minister. The Committee is responsible for reviewing competition matters referred to it, providing opinions and recommendations on competition policy and legislation, considering exemption and concentration matters, and supporting the Ministry in implementing the Competition Decree-Law.

Liabilities

The Competition Decree-Law provides for administrative, civil and criminal liability for anti-competitive conduct, including cartel practices, abuse of dominance, abuse of economic dependence and violations of merger control requirements. The imposition of statutory penalties does not prejudice any more severe penalties under other laws, nor does it prejudice the right of the injured party to have recourse to the court to claim damages or compensation arising from violations of the Competition Decree-Law.

Criminal actions may not be instituted except at a written request of the Minister. The Minister may reconcile with a violator before bringing a criminal action to court, against payment of not less than double the minimum fine.

Penalties

Violations of the restrictive agreements, abuse of dominant position, abuse of economic dependence, or predatory pricing provisions may result in a fine of not less than AED100,000 and not exceeding 10% of the total annual sales of the undertaking in breach in the UAE during the last fiscal year. Where the annual total sales cannot be determined, the fine ranges from AED500,000 to AED5,000,000.

Violations of the merger control notification requirements (based on the new 2025 thresholds) may result in a fine ranging from 2% to 10% of the annual total sales of goods or services revenue realised by the undertaking in breach in the UAE during the last fiscal year. Where such sales or revenues cannot be determined, the fine ranges from AED500,000 to AED5,000,000.

The competent court may also order the temporary closure of the violating undertaking for a period ranging from three to six months, and may order publication of the judgment in at least two local daily newspapers at the expense of the violator.

Important Recent/Imminent Changes

The most significant imminent change is the issuance of Cabinet Decision No (59) of 2026 (the new Competition Executive Regulation), which will become enforceable on 31 July 2026 and introduces modernised procedures for investigations and exemptions. Further, Cabinet Decision No (3) of 2025 established new financial thresholds for merger control, which became fully operational in early 2025, significantly increasing the volume of mandatory filings for international transactions.

Injured parties may bring civil claims before the competent UAE courts seeking compensation for damages arising from violations of the Competition Decree-Law and the imposition of statutory penalties does not prejudice such right (Article 30 of the Competition Decree-Law). Competition-related actions are heard summarily and the competent court may order the suspension or stay of the relevant conduct pending the issuance of a final judgment (Article 31 of the Competition Decree-Law).

There is no specialist competition tribunal in the UAE and claims are heard before the ordinary civil courts. In practice, private competition enforcement remains relatively limited, with claimants often relying on prior findings or investigations by the Ministry of Economy as the basis for follow-on damages claims, although standalone private actions are legally permissible and governed mainly by the Civil Procedure Law (Federal Decree-Law No 42 of 2022 and its amendments).

The Competition Decree-Law does not use the term “cartel” expressly. Cartel conduct is primarily captured by Article 5 of the Competition Decree-Law, which prohibits agreements between undertakings whose subject, purpose or effect is to distort, lessen, prevent or restrict competition.

The core prohibited categories include:

• price-fixing directly or indirectly;
• collusive tendering or bidding in auctions, tenders and other supply offers (bid rigging);
• freezing or limiting production, development, distribution or marketing operations; and
• collusive refusal to purchase from or sell to a specific undertaking (Article 5(1) of the Competition Decree-Law).

Market or customer sharing and actions to obstruct market entry or exclude competitors are also prohibited (Article 5(2) of the Competition Decree-Law).

Certain categories are excluded entirely from the Competition Decree-Law’s scope under Article 4, including sectors where a Sectoral Regulatory Agency has its own competition rules, federal government-owned undertakings as determined by Cabinet resolution and emirate-level government undertakings operating solely within that emirate. Further, under Article 9 of the Competition Decree-Law, certain agreements or practices that are necessary to promote economic development or benefit consumers may be individually exempted by ministerial resolution, provided they do not result in the complete elimination of competition in the relevant market or a significant part thereof.

Under Article 11 of the Competition Decree-Law, categories of contracts may also be categorically exempted, as recently illustrated by the block exemption for digital food delivery platforms (Ministerial Decision No (32) of 2026) and the temporary crisis exemption for essential goods (Ministerial Decision No (96) of 2026).

Under Article 37 of the Competition Decree-Law, the prescriptive period for complaints about anti-competitive practices is five years from the date of their commission, except for practices proven to be continuing and whose harmful effects on competition last for more than five years. For ongoing cartels, the limitation period therefore does not begin to run until the practice ceases.

The Competition Decree-Law is silent on the limitation period for private damages claims. Based on general principles of UAE law, such claims would likely be subject to the applicable limitation periods under the UAE Civil Transactions Law or the UAE Commercial Transactions Law, depending on the nature and legal characterisation of the claim, rather than to a competition-specific limitation period.

For procedural purposes, any stakeholder may file a written complaint against a decision issued pursuant to the Competition Decree-Law with the Minister, the chairman of the Relevant Authority, or the chairman of the Sectoral Regulatory Agency, as the case may be, within 15 working days of being notified of the decision. The complaint must be accompanied by all supporting documents and must be decided upon within 30 days from its filing date; failure to respond within that period shall be regarded as a dismissal of the complaint (Article 34(1) of the Competition Decree-Law). The complainant may then appeal the dismissal of the complaint before the competent court within 30 days of being notified of the dismissal, or upon lapse of the time limit without a response (Article 34(2) of the Competition Decree-Law).

The Competition Decree-Law applies to all undertakings in relation to their economic activities in the UAE, to the exploitation of intellectual property rights inside and outside the UAE, and to economic activities practised outside the UAE and affecting competition in the UAE (Article 3 of the Competition Decree-Law). This broad “effects doctrine” allows UAE competition authorities to investigate and enforce against foreign conduct where it gives rise to anti-competitive effects within the UAE market, irrespective of where the conduct occurred or where the relevant undertakings are established. Certain sectors and entities are excluded from the scope of the Competition Decree-Law under Article 4, including sectors regulated by sectoral regulatory agencies having their own competition rules, certain federal government-owned undertakings and certain emirate-level government-owned entities.

As regards the allocation of jurisdiction within the UAE, the Relevant Authority at the emirate level may consider anti-competitive practices where the undertakings concerned are located within the same emirate and the effects of the conduct do not extend beyond that emirate (Article 21(1) of the Competition Decree-Law). In all other cases, jurisdiction rests with the Ministry of Economy. The Relevant Authority must notify the Ministry of such matters and the Ministry may participate in their review and consideration (Article 21(2) of the Competition Decree-Law).

The Competition Decree-Law does not expressly recognise or codify principles of international comity. Article 3 applies the law to economic activities carried out outside the UAE that affect competition within the UAE without providing any express deferral or co-ordination mechanism in favour of foreign jurisdictions investigating the same conduct. The Competition Decree-Law also does not establish any formal framework for co-operation, information sharing or mutual assistance with foreign competition authorities.

In practice, comity considerations arise through general principles of public international law and regulatory co-operation. The UAE has recently established a formal framework for global co-operation. In November 2025, the UAE officially joined the International Competition Network (ICN), a global body of 140 competition authorities. This membership enables the UAE to co-ordinate on cross-border enforcement and leverage international expertise.

Further, the Ministry of Economy has begun establishing bilateral mechanisms, such as the Memorandum of Understanding (MoU) signed with the Egyptian Competition Authority (ECA) in 2025. This renewable four-year agreement provides for the exchange of investigative procedures and information regarding anti-competitive violations.

While the Ministry retains full discretion to enforce against foreign conduct affecting the UAE market, irrespective of parallel foreign proceedings, these new international and bilateral memberships signal a move toward more structured regulatory co-operation.

Under the Competition Decree-Law, the UAE competition regime prohibits all restrictive agreements under Article 5, including price-fixing, bid-rigging and market allocation, without prescribing specific enforcement priorities among them. Enforcement is overseen by the Ministry of Economy, which is empowered under Article 18 to investigate anti-competitive practices either following a complaint or on its own initiative (ex officio).

Although the Competition Decree-Law applies to conduct affecting competition within the UAE, even where carried out abroad, enforcement activity has primarily focused on domestic market practices and sectors with direct consumer impact, including food security, retail and construction, with limited publicly available evidence of co-ordinated international cartel investigations to date.

In practice, the UAE competition regime has recently moved towards more active enforcement. On 19 April 2026, the Ministry of Economy announced the referral of a poultry cartel matter to the Federal Public Prosecution following findings of alleged collusion to manipulate poultry prices, after carrying out approximately 15,480 inspection tours across UAE markets. As there is currently no formal leniency or immunity programme under the Competition Decree-Law, enforcement remains driven primarily by regulatory inspections, complaints and ex officio investigations rather than self-reporting by cartel participants.

The Ministry of Economy publishes guidance documents and public materials relating to competition law compliance, anti-competitive practices and complaint procedures under the Competition Decree-Law. These include the “Guidelines for Submitting Competition Complaints” issued in December 2025, as well as regular enforcement announcements, awareness materials and updates on cartel practices and price manipulation published on the Ministry’s official website and media centre. The Competition Regulatory Committee is also required under Article 17(5) of the Competition Decree-Law to prepare an annual report on the Committee’s activities to be presented to the Minister, though such reports are not necessarily made publicly available in full.

The principal published materials include:

• Guidelines for Submitting Competition Complaints (issued in December 2025), which provide guidance on filing complaints, jurisdiction, supporting evidence and the Ministry’s review procedures;
• Regulation of Competition Legislations portal, which provides access to the Competition Decree-Law, Cabinet Decision No (59) of 2026, issuing the Executive Regulation and related cabinet or ministerial decisions and regulations;
• official competition complaint portal, through which businesses and consumers may submit complaints relating to anti-competitive conduct and restrictive practices; and
• media releases and enforcement announcements relating to cartel practices, inspections, price manipulation and consumer protection enforcement actions.

The Ministry of Economy is the primary enforcement authority and may open investigations either on its own initiative (ex officio) or upon receipt of a complaint from any stakeholder (Articles 18(4) and 32 of the Decree-Law; Articles 19–20 and 26 of the Executive Regulations). Upon receiving a complaint, the Ministry examines it within 15 working days and either accepts or rejects it; if accepted, the respondent is notified and given up to 30 working days to respond. Investigations must be completed within 90 working days (extendable by 30 working days). The Ministry may request information and documents from undertakings, conduct market monitoring and seek technical opinions from Relevant Authorities and Sectoral Regulatory Agencies in respect of the practices and actions under investigation (Article 20 of the Decree-Law). The Ministry may also refer the initial findings to the Competition Regulatory Committee for a technical recommendation before issuing a final decision.

Additionally, law enforcement officers appointed under Article 35 of the Decree-Law, by resolution of the Minister of Justice, are empowered to investigate and establish violations.

The Competition Decree-Law and the Executive Regulations grant the Ministry of Economy broad investigatory and inspection powers regarding anti-competitive practices. While the UAE regime does not expressly use the term “dawn raids” as it is used in EU or US competition enforcement, the Executive Regulations provide for on-site inspections and evidence-gathering measures that operate similarly to dawn raid powers in other jurisdictions.

Powers of Inspection

The Ministry (or Relevant Authority) may conduct field research at the premises of undertakings under investigation, enter those premises and examine all records, documents and files (including electronic files) and take samples where necessary, provided such inspections are carried out by employees holding judicial police officer status. These on-site inspection powers are the functional equivalent of dawn raids; they are provided for in Article 23(7) of the Executive Regulations and are conducted without prior notice to the undertaking.

Procedural Requirements

A formal inspection report must be prepared that records the date, time, location and subject of the inspection; the identities and roles of all persons present; the statements of those heard; the names of the inspecting officers; and the specific documents and data reviewed. Those present must be permitted to review the report, which must be signed by all parties; any refusal to sign is recorded in the report.

Obligations of Firms and Employees

Undertakings are required to co-operate with the competent authorities during the investigation process. Preventing enforcement employees from performing their duties, withholding information or data relevant to the investigation, or providing or destroying misleading information is a criminal offence punishable by a fine of AED50,000 to AED500,000 under Article 27 of the Competition Decree-Law.

Interviews

The Ministry may hold meetings with parties and other relevant persons during the investigation. Such interviews are conducted by judicial police officers and formally documented in official minutes, recording the date, time, location, subject and nature of the alleged practices and the statements and identities of all participants. Parties are entitled to review the minutes, and any refusal to sign is noted in the record. Refusal to co-operate exposes the party to liability under Article 27 of the Competition Decree-Law.

Role of Outside Counsel

The Competition Decree-Law and Executive Regulations do not expressly regulate the presence of outside counsel during inspections or interviews. However, parties may request copies of, or access to, documents and data related to the complaint through their legal representatives acting under a duly authenticated power of attorney, unless the documents are confidential.

Copies of Seized Material

Parties or their duly authorised legal representatives may request copies of documents and data related to the complaint or access to them, provided that the Ministry may refuse such requests where this would conflict with confidentiality obligations.

Electronic Documents and Personal Devices

Article 23(7) of the Executive Regulations authorises the competent inspection officers to examine records, documents and files, including electronic files, at the premises of the undertaking under investigation. The Executive Regulations do not contain detailed provisions distinguishing between corporate and personal devices, nor do they expressly regulate the scope or limits of access to personal electronic devices or personal information during inspections.

Home/Residential Searches

The inspection powers are expressly limited to the premises of the undertaking under investigation. There is no express provision in the Decree-Law or Executive Regulations authorising residential or home searches.

The Competition Decree-Law imposes penalties for withholding information or data relevant to an investigation, or providing or destroying misleading information or data, with fines ranging from AED50,000 to AED500,000 under Article 27. In practice, the obligation to preserve relevant evidence arises once an undertaking becomes aware of an investigation, complaint, inspection or request for information by the Ministry or a Relevant Authority.

The Competition Decree-Law does not prescribe a formal document retention or litigation hold regime. However, defence counsel would typically advise the immediate preservation of potentially relevant documents and the suspension of routine deletion practices in accordance with general UAE evidence preservation principles.

The Competition Decree-Law and the Competition Executive Regulation do not contain detailed provisions governing the role of legal counsel during cartel investigations, inspections or interviews. However, parties and individuals subject to investigation generally retain rights to legal representation under UAE law, and external counsel commonly assist undertakings during investigations conducted by the Ministry.

Under the Competition Executive Regulation, legal representatives acting under a duly authenticated power of attorney (POA) are expressly recognised and may exercise the following rights on behalf of their clients:

• filing complaints (Article 20(1) of the Competition Executive Regulation);
• submitting exemption notifications (Article 4(2)(a) of the Competition Executive Regulation);
• filing merger control applications (Articles 10(2) and 11 of the Competition Executive Regulation);
• signing and reviewing field inspection minutes (Article 23(7)(f) of the Competition Executive Regulation);
• requesting copies of or access to complaint-related documents, unless those documents are confidential (Article 24(4) of the Competition Executive Regulation); and
• withdrawing complaints on behalf of the complainant (Article 22(1) of the Competition Executive Regulation).

In practice, defence counsel would typically assess the scope of the investigation, co-ordinate responses to information requests, preserve potentially relevant evidence, manage communications with the Ministry and advise employees participating in interviews or meetings.

The Ministry gathers evidence through formal information requests, oral hearings and on-site inspections. It may request additional data or documents from parties within 20 working days (extendable) (Article 23(2) of the Competition Executive Regulation), hold formally hearings with parties and relevant persons conducted by judicial police officers (Articles 23(5) and (6) of the Competition Executive Regulation) and conduct field inspections at the undertaking’s premises examining all records, documents and files including electronic files (Article 23(7) of the Competition Executive Regulation).

The Ministry may also appoint specialised experts at the complainant’s expense (Article 23(8) of the Competition Executive Regulation). Obstruction, withholding of information, or destruction of data is a criminal offence punishable by a fine of AED50,000 to AED500,000 (Article 27 of the Competition Decree-Law).

The Competition Decree-Law contains no express provisions on attorney-client privilege, legal professional privilege, or the privilege against self-incrimination in the context of competition investigations. Privilege in the UAE is governed primarily by general principles of UAE law, including Federal Decree-Law No 34 of 2022 on the Regulation of the Legal Profession and Federal Decree-Law No 35 of 2022 on Evidence. These laws impose a duty of confidentiality on lawyers regarding information obtained during their professional practice, though the concept of “privilege” as a right to withhold evidence from the State is more limited than in common law systems.

Communications with in-house counsel are generally regarded as more uncertain, given that in-house lawyers are employees of the undertaking rather than independent practitioners, and UAE law does not definitively resolve whether in-house legal advice attracts privilege equivalent to that of external counsel. The privilege against self-incrimination may be available to individuals in the context of any criminal proceedings under the UAE Criminal Procedural Law, but its application to compulsory information-gathering procedures in administrative competition investigations is not addressed in the Competition Decree-Law. Undertakings should therefore seek specific legal advice on privilege claims before responding to information requests.

Non-cooperation with the Ministry’s investigatory process is expressly sanctioned under the Competition Decree-Law and the Competition Executive Regulation. Where a respondent fails to submit its response to a complaint or provide requested documents within the prescribed timeframe, the Ministry must issue a formal notice requiring compliance within ten working days, warning that failure to respond will expose the respondent to legal liability under Article 27 of the Competition Decree-Law and that the Ministry may proceed to determine the matter based solely on the complainant’s evidence (Article 23(3) of the Competition Executive Regulation). Obstruction of enforcement officers, withholding of information, or providing or destroying misleading data constitutes a criminal offence punishable by a fine of AED50,000 to AED500,000 (Article 27 of the Competition Decree-Law).

The Competition Decree-Law and the Competition Executive Regulation impose confidentiality obligations regarding commercially sensitive information and trade secrets submitted to the Ministry. Ministry employees and parties involved in the complaint process are prohibited from disclosing confidential information where disclosure could harm commercial interests or conflict with the public interest (Article 19 of the Competition Decree-Law and Article 20(2) of the Competition Executive Regulation).

Parties seeking confidential treatment must clearly designate the relevant information as “confidential” and provide non-confidential summaries (Articles 4(5)(e) and 10(4) of the Competition Executive Regulation). The Competition Decree-Law does not draw a distinction between subjects of enforcement actions, third parties and witnesses for the purposes of this protection, and the confidentiality obligations appear to apply broadly to all information submitted to the Ministry in any capacity.

Defence counsel may raise legal and factual arguments at two key stages: first, within 30 working days of being notified of the complaint; and second, within 20 working days of receiving the preliminary investigation report, both of which must be responded to before a final report is issued (Articles 23(2) and 24(2) of the Competition Executive Regulation).

Notably, the Ministry is not bound by the legal characterisation or the parties named in the complaint, and may re-characterise the facts as it sees fit, making early substantive engagement critical (Article 23(4) of the Competition Executive Regulation). In substantive terms, counsel may argue that the conduct falls within the exclusions under Article 4 of the Competition Decree-Law, or qualifies for an individual exemption under Article 9 of the Competition Decree-Law on the basis that it promotes economic development or benefits consumers without completely eliminating competition.

Where enforcement action has been taken, any stakeholder may file an internal complaint with the Minister within 15 working days of notification of the decision and the complaint will be decided within 30 days (Article 34(1) of the Competition Decree-Law). The complainant may thereafter appeal to the competent court within 30 days (Article 34(2) of the Competition Decree-Law). Separately, reconciliation with the Ministry remains available before criminal proceedings are referred to court, requiring:

• a written agreement;
• an express admission of the violations;
• payment of not less than double the minimum applicable fine within 30 working days; and
• a commitment to cease the infringing conduct (Article 27 of the Competition Executive Regulation).

The Competition Decree-Law and the Competition Executive Regulation do not provide for a formal leniency regime of the type found in EU or US competition law, whereby a cartel participant may obtain full immunity from, or a reduction in, penalties in exchange for self-reporting and co-operation with the authorities. There is therefore no marker process, no automatic or discretionary leniency reduction and no published record of leniency applications.

The only similar mechanism is the reconciliation procedure under Article 33(2) of the Competition Decree-Law and Article 27 of the Competition Executive Regulation, which allows the Ministry to conclude a written settlement with a violator before criminal proceedings are referred to court, upon:

• payment of not less than double the minimum applicable fine;
• an express admission of the infringement; and
• a commitment to cease the anti-competitive conduct.

Reconciliation may be initiated either by the infringing undertaking or by the Ministry on its own motion (Article 27(2) of the Competition Executive Regulation), is binding on all signatories and is not subject to any form of appeal (Article 27(3) of the Competition Executive Regulation). Importantly, reconciliation does not extinguish civil liability for damages caused by the infringement (Article 27(6) of the Competition Executive Regulation).

There is no direct amnesty or immunity regime stipulated under the UAE competition law. However, the reconciliation procedure under Article 33(2) of the Competition Decree-Law, as described in 3.1 Leniency, is the closest equivalent, as it results in the suspension of criminal proceedings against the settling parties and the lapse of any interim or provisional orders issued in connection with the settled offences (Article 27(5) of the Competition Executive Regulation). However, it does not provide immunity from the outset and requires both an express admission of guilt and payment of a substantial financial amount. Criminal proceedings may not, in any event, be initiated (except for violations of Article 19 relating to confidentiality obligations) without a written request from the Minister or his authorised representative (Article 33(1) of the Competition Decree-Law), which affords the Ministry a degree of prosecutorial discretion. There is no published record of reconciliation or quasi-immunity being formally granted.

The Competition Decree-Law and the Competition Executive Regulation do not establish a formal whistle-blower regime with dedicated protections or financial rewards for informants. However, Article 26(4) of the Competition Executive Regulation provides that any person may report a violation of the provisions of the Competition Decree-Law and the Executive Regulation to the Ministry, the Relevant Authority or the Sectoral Regulatory Agency, as the case may be. This reporting right is broad in scope and is not limited to bid rigging or public procurement. The Ministry is not required to establish, nor does it appear to encourage, internal corporate hotlines for cartel reporting. No whistle-blower financial reward scheme exists and, based on general knowledge, there is no established market of whistle-blower counsel advertising or soliciting clients in the UAE in respect of competition matters.

Before or during an investigation, parties may contact the Competition Department at the Ministry of Economy & Tourism directly by email at competitiondepartment@economy.ae or by requesting a meeting, whether in person or via virtual platforms. The Ministry may hold formal meetings with any party to a complaint or any other relevant person whose participation is required to complete the investigation, without expressly distinguishing between current and former employees (Article 23(5) of the Competition Executive Regulation).

Such meetings are conducted by designated judicial police officers and the meeting minutes are recorded, indicating the date, time, subject and nature of the alleged practices, and the statements and identities of all participants; parties must be permitted to review and sign the minutes, with any refusal to sign recorded therein (Article 23(6) of the Competition Executive Regulation). Obstruction of enforcement officers or withholding of information constitutes a criminal offence punishable by a fine of AED50,000 to AED500,000 (Article 27 of the Competition Decree-Law).

The Ministry may request additional data or documents from the parties within 20 working days (extendable) and may conduct field inspections at the undertaking’s premises, examining all records, documents and files, including electronic files and taking samples where necessary, conducted by employees holding judicial police officer status (Articles 23(2) and (7) of the Competition Executive Regulation).

The burden of proof initially rests on the complainant, who must provide sufficient preliminary evidence to justify opening an investigation; thereafter, the competition authority’s investigative role expands to collect additional evidence in the public interest.

Physical evidence that may be requested includes:

• written agreements;
• meeting minutes;
• written or electronic correspondence;
• price lists;
• invoices;
• tender bids; and
• financial statements.

Non-physical or circumstantial evidence is also recognised where the alleged conduct leaves no tangible trace, provided such evidence is:

• logically coherent;
• frequent; and
• cumulatively consistent.

The Competition Decree-Law applies to economic activities practised outside the UAE that affect competition within the UAE (Article 3 of the Competition Decree-Law), meaning that undertakings present in the UAE may be required to produce documents and information available to them regardless of where those documents are physically located. All undertakings are obliged to provide data, information and documents requested by the Ministry for investigatory purposes and the Executive Regulation does not draw any distinction based on the location of the data (Article 26(3) of the Competition Executive Regulation). The Competition Decree-Law and the Executive Regulation contain no specific provisions addressing mutual legal assistance mechanisms or formal channels for co-operation with foreign authorities for the purposes of evidence gathering, nor do they specifically address the dynamics of cloud storage.

Three authorities may have jurisdiction over competition complaints: the Competition Department at the Ministry of Economy, the Economic Development Departments in each Emirate, subject to the conditions in Article 21 of the Decree-Law and Sectoral Regulatory Authorities, whether or not they have their own dedicated competition framework. Where a matter falls within the jurisdiction of a Relevant Authority, that authority must notify the Ministry, which may elect to participate in the proceedings within ten working days; jurisdiction reverts to the Ministry if the conditions for emirate-level jurisdiction cease to be met (Articles 21 and 22 of the Competition Decree-Law). All agencies are bound by the same confidentiality obligations regarding information exchanged among them, and the Ministry may request technical opinions from Relevant Authorities and Sectoral Regulatory Agencies on any matter under review (Articles 28 and 29 of the Competition Executive Regulation).

While Federal Decree-Law No 36 of 2023 focuses on establishing a domestic competition framework, the UAE Ministry of Economy has recently transitioned to an active stance on international cooperation. A major development occurred on 6 November 2025, when the UAE officially joined the International Competition Network (ICN). This accession allows the UAE to collaborate with over 140 competition authorities worldwide, facilitating:

• the exchange of technical expertise;
• enforcement strategies; and
• advanced practices in competition policy.

On a regional level, the UAE has begun establishing specific bilateral mechanisms, such as the Memorandum of Understanding (MoU) signed with the Egyptian Competition Authority in 2025. This agreement explicitly provides for the exchange of investigative procedures, market studies and information regarding anti-competitive violations. Such frameworks are designed to enhance the Ministry’s ability to monitor cross-border conduct and digital marketplaces through the sharing of intelligence and evidence.

Under Article 3 of the Competition Decree-Law, the Ministry retains jurisdiction to pursue anti-competitive conduct occurring outside the UAE where it affects competition within the UAE, irrespective of parallel foreign proceedings or decisions issued in other jurisdictions. Although the UAE has recently strengthened international co-operation through initiatives such as joining the ICN and entering into bilateral co-operation arrangements with foreign competition authorities, there is currently limited publicly available data regarding the practical extent of international co-ordination in cartel enforcement under the 2023 regime.

Criminal proceedings for competition law violations may not be initiated (with the exception of violations of Article 19 regarding confidentiality obligations) without a written request from the Minister of Economy or his authorised representative (Article 33(1) of the Competition Decree-Law). The Ministry is an administrative investigative body, not a judicial authority; investigations conclude with either the imposition of administrative fines by the Minister on violators or referral to the competent court for criminal penalties.

Before a case is referred to court, the Minister may offer reconciliation to the violating undertaking under the terms specified in Article 27 of the Competition Executive Regulation. This process requires a written admission of the violations, payment of an amount not less than double the minimum applicable fine within 30 working days and a formal commitment to cease the infringing conduct immediately. Once a case is referred, the competent criminal courts have sole jurisdiction to hear the matter and are empowered under Article 31 of the Competition Decree-Law to issue interim orders staying the conduct in question pending a final judicial judgment.

The imposition of penalties under the Competition Decree-Law does not prejudice the right of any injured party to bring civil proceedings before the competent court to claim damages arising from a violation (Article 30(2) of the Competition Decree-Law). Importantly, claims for financial compensation may not be included in an administrative complaint submitted to the Ministry of Economy; the Ministry’s role is strictly limited to investigating anti-competitive conduct and imposing administrative penalties. Consequently, damage claims must be pursued as independent actions before the competent civil courts.

Under Article 31 of the Decree-Law, competition-related civil claims are heard through expedited or summary proceedings. The court is empowered to issue interim decisions or injunctions to stay the relevant conduct pending a final judgment on the merits.

The standard and burden of proof, as well as pre-trial procedural rights, are governed by the general provisions of UAE law, specifically the Civil Procedure Law (Federal Decree-Law No 42 of 2022 and its amendments) and the Law on Evidence (Federal Decree-Law No 35 of 2022). The burden of proof rests on the claimant to establish the violation, the quantifiable harm and the causal link between them.

The Ministry of Economy is empowered to appoint one or more specialised experts to provide a technical opinion on any act or practice alleged to constitute a violation for the purposes of an investigation. Under Article 23(8) of the Competition Executive Regulation, these experts, typically appointed at the complainant’s expense, must submit a formal report within a timeframe determined by the Ministry. Complainants and defendants may also submit their own reports from accredited offices as part of their evidentiary package. These reports are subject to the standards of the UAE Law on Evidence, which requires experts to maintain independence and impartiality throughout the proceedings.

While the Competition Decree-Law does not restrict experts to specific disciplines, competition investigations and proceedings may involve economic experts, financial experts and technical specialists relevant to the sector concerned, depending on the nature of the alleged conduct and the issues under review. Such experts may assist in matters relating to:

• market definition;
• market power;
• pricing structures;
• competitive effects;
• turnover assessments; and
• sector-specific technical analysis.

Multiple parallel or simultaneous enforcement proceedings are expressly contemplated under Federal Decree-Law No 36 of 2023. Under Articles 30(1) and (2), the imposition of administrative or criminal penalties for a competition violation does not prejudice the application of more severe penalties under other laws, nor does it bar injured parties from initiating civil damages proceedings before the competent courts. Further, complainants may indicate whether a similar complaint has been submitted to other governmental or judicial authorities concurrently with or prior to the complaint submitted to the Ministry.

Reconciliation under Article 27 of the Competition Executive Regulation suspends criminal proceedings but expressly preserves civil liability for damages caused by the infringement (Article 27(6) of the Competition Executive Regulation). The Competition Decree-Law and Executive Regulation do not address the admissibility of evidence obtained in one set of proceedings in another; that issue is governed by the general rules of evidence under UAE law.

The Ministry has direct authority to impose administrative penalties on undertakings that violate the Competition Decree-Law; the specific quantum of those administrative penalties is to be determined by a separate Cabinet resolution (Article 23 of the Competition Decree-Law). In the context of economic concentrations, the Competition Executive Regulation expressly confirms that the Ministry, the Relevant Authority or the Sectoral Regulatory Agency has the right to impose administrative sanctions on parties that fail to notify a notifiable economic concentration (Article 18(1) of the Competition Executive Regulation). In addition to administrative penalties, criminal fines are imposed by the competent criminal courts following a referral by the Minister (Article 33(1) of the Competition Decree-Law).

For violations of the core cartel prohibitions under Articles 5, 6, 7, 8 and clauses (2) and (4) of Article 9 of the Competition Decree-Law, the criminal fine ranges from AED100,000 to 10% of the violating undertaking’s annual total sales in the UAE during the last ending fiscal year, or between AED500,000 and AED5,000,000 where annual sales cannot be determined (Article 24 of the Competition Decree-Law).

There is no formal plea bargaining procedure under the UAE Competition Law. The closest equivalent is the reconciliation mechanism under Article 33(2) of the Competition Decree-Law, which is available before criminal proceedings are referred to court. Reconciliation must be in writing and signed by the infringing parties,  and must include an express admission of the offences committed, a commitment to pay an amount not less than double the minimum applicable fine within 30 working days and an undertaking to cease the infringing conduct; it becomes effective only upon proof of payment of the agreed amount (Article 27 of the Competition Executive Regulation).

Reconciliation is binding on all signatories and is not subject to any form of challenge or appeal (Article 27(3) of the Competition Executive Regulation); it results in the suspension of criminal proceedings and the lapsing of all interim or provisional orders, but does not extinguish civil liability for damages caused by the infringement (Articles 27(5) and (6) of the Competition Executive Regulation). Failure to comply with a concluded reconciliation agreement entitles the Minister to refer the case to the criminal courts (Article 27(7) of the Competition Executive Regulation).

The imposition of penalties under the Competition Decree-Law does not prejudice the application of any more severe penalty prescribed under any other applicable law, nor does it prejudice the right of any injured party to bring civil proceedings before the competent court to claim damages arising from the violation (Article 30 of the Competition Decree-Law). Upon conviction, the court may also order the closure of the undertaking’s premises for a period of not less than three months and not more than six months, and may order publication of the judgment wording once or twice in at least two local daily newspapers at the violator’s expense (Article 29 of the Competition Decree-Law).

Beyond competition law, the Executive Regulation of Federal Law No (11) of 2023 on Federal Government Procurement expressly categorises anti-competitive practices (including bid-rigging, price-fixing and collusion) as violations that harm procurement integrity, and provides that suppliers involved in such practices may be blacklisted for a minimum of five years from participating in any federal tender, exposed to a financial penalty of up to 10% of annual sales or contract value and have existing contracts revoked with performance bonds confiscated (Articles 30(1)(a), 41 and 51 of Cabinet Resolution No (122) of 2024). Reconciliation under Article 33(2) of the Competition Decree-Law may partially mitigate these collateral effects by halting criminal proceedings, though its impact on procurement debarment remains subject to the discretion of the relevant Federal Agency or Central Procurement Unit, as the reconciliation mechanism does not bind separate procurement authorities.

For violations of the core cartel prohibitions under Articles 5, 6, 7, 8 and clauses (2) and (4) of Article 9 of the Competition Decree-Law, the applicable criminal fine ranges from AED100,000 to 10% of the violating undertaking’s annual total sales in the UAE during the last ending fiscal year, or between AED500,000 and AED5,000,000 where annual sales cannot be determined (Article 24 of the Competition Decree-Law).

For failure to notify a notifiable economic concentration under Article 12, fines range from 2% to 10% of annual sales or revenues, or between AED500,000 and AED5,000,000 where this cannot be computed (Article 25 of the Competition Decree-Law). Upon conviction, the court may additionally order closure of the undertaking for three to six months and/or publication of the judgment in at least two local daily newspapers at the violator’s expense (Article 29 of the Competition Decree-Law). The Decree-Law and Executive Regulation do not prescribe a specific formula for calculating fines; the court retains discretion within the statutory ranges. The Ministry’s role in criminal proceedings is primarily that of investigator and complainant, given that criminal proceedings may not be initiated without a written request from the Minister (Article 33(1) of the Competition Decree-Law).

Given the relatively recent implementation of Federal Decree-Law No (36) of 2023, there is no publicly available record of criminal sanctions, fines, custodial sentences, or extraditions imposed to date for cartel conduct in the UAE. However, a significant development occurred on 19 April 2026, when the Ministry of Economy announced the referral of a poultry cartel matter for criminal proceedings following an investigation into alleged price manipulation, representing the first major public cartel enforcement action under the current regime.

The Competition Decree-Law does not provide for custodial sentences for competition violations; available sanctions are limited to fines, closure of premises and publication of judgments (Articles 24–29 of the Competition Decree-Law). Based on publicly available information, no individual is known to have served a custodial sentence or been extradited to or from the UAE in connection with a cartel offence. The UAE maintains extradition treaties with various jurisdictions, albeit extradition generally depends on the principle of dual criminality, which may limit extradition in cartel matters, given the absence of imprisonment sanctions under UAE competition law.

Neither the Competition Decree-Law nor the Competition Executive Regulation makes any express provision for an effective compliance programme to be considered a mitigating factor in the imposition of administrative or criminal sanctions. There is no statutory framework equivalent to those found in some EU member states or the United States, whereby a demonstrated culture of compliance may reduce fines or otherwise influence penalty calculations.

In the absence of such provisions, undertakings cannot rely on compliance programmes as a statutory basis for reduced penalties. Nevertheless, the Ministry of Economy has increasingly emphasised preventative awareness and compliance culture in its public guidance and awareness initiatives. In practice, undertakings may seek to rely on internal compliance policies, employee training programmes and remedial measures during investigations, reconciliation discussions or court proceedings in order to demonstrate good-faith conduct and co-operation, although no published UAE precedent currently confirms a formal reduction of penalties on this basis.

The Competition Decree-Law does not provide for mandatory consumer redress or restitution as a sanction in governmental enforcement proceedings. The available sanctions in enforcement proceedings are limited to administrative and criminal fines, closure of premises and publication of judgment (Articles 23–29 of the Competition Decree-Law). The right to claim compensation for harm suffered as a result of a competition violation is reserved for injured parties pursuing civil proceedings before the competent court, and the existence of such private litigation does not form part of any governmental enforcement order under the Competition Decree-Law (Article 30(2) of the Competition Decree-Law).

Any stakeholder may file a written internal complaint about a decision issued pursuant to the Competition Decree-Law with the Minister, the chairman of the Relevant Authority or the Sectoral Regulatory Agency within 15 working days of notification of the decision; the complaint must be decided upon within 30 working days and failure to respond is deemed a dismissal (Article 34(1) of the Competition Decree-Law). The complainant may then appeal the dismissal to the competent court within 30 days; no court appeal may be filed without first exhausting the internal complaints process (Articles 34(2) and (3) of the Competition Decree-Law). Notably, reconciliation agreements are expressly excluded from any form of challenge or appeal (Article 27(3) of the Competition Executive Regulation).

There is no publicly available data on the frequency or outcome of such appeals.

The Competition Executive Regulation provides the following indicative statutory timelines:

• the Ministry must examine a complaint within 15 working days of receipt and notify the complainant of acceptance or rejection;
• upon acceptance, the respondent is given up to 30 working days to respond;
• the investigation must be completed within 90 working days (extendable by 30 working days);
• the preliminary investigation report must be shared with parties, who are given up to 20 working days to respond;
• the final investigation report must be prepared within 20 working days thereafter (extendable by ten working days); and
• the Minister’s decision must be issued within 15 working days of receiving the final report (Articles 21, 23 and 24 of the Competition Executive Regulation).

This indicates a minimum statutory investigation timeline of approximately nine to 11 months from complaint acceptance to ministerial decision, before any internal appeal or court proceedings. Given the nascent state of the enforcement regime, no average or historical data is available on the end-to-end duration of cartel investigations, including court proceedings and any appeals.

The Competition Decree-Law expressly preserves the right of any injured party to bring civil proceedings before the competent court to claim damages arising from a violation of its provisions, independently of any administrative or criminal penalties imposed (Article 30(2) of the Competition Decree-Law). Such claims are heard summarily by the competent civil courts, which may also issue interim decisions that stay or suspend the relevant conduct pending a final judgment (Article 31 of the Competition Decree-Law).

While Article 37 of the Competition Decree-Law sets a five-year prescriptive period for administrative complaints to the Ministry, private civil actions for damages are subject to the limitation periods set out in the UAE Civil Transactions Law. The Competition Decree-Law does not prescribe specific threshold requirements or forms of relief for civil claims beyond the right to damages; those matters are governed by the general provisions of UAE civil procedure law as well as the Law on Evidence. Given the emerging enforcement regime, there is no publicly available record of civil damages claims being brought or concluded under the Decree-Law.

The Competition Decree-Law and the Competition Executive Regulation contain no provisions for collective or class actions in the context of competition law claims. UAE civil procedure law does not provide for a general class action mechanism of the type found in common law jurisdictions.

While the UAE Consumer Protection Law allows the Ministry and certain authorised associations to act in the collective interest of consumers, they do not have a recognised standing to bring collective claims for competition damages under the current framework; standing is limited to the “injured party” as contemplated by Article 30(2) of the Competition Decree-Law, which, based on general UAE civil procedure principles, refers to a party that has itself suffered a direct and personal injury as a result of the violation. Accordingly, collective or representative actions for cartel damages are not currently available in the UAE.

The Competition Decree-Law and the Competition Executive Regulation contain no specific provisions addressing the standing of indirect purchasers or the availability of “passing on” defences in private civil damages claims. These questions would be determined by the competent civil court applying the general principles of UAE civil liability law, under which claimants must establish a direct causal link between the violation and the damage suffered.

In the absence of specific legislative guidance, the treatment of indirect purchaser claims and passing on arguments remains untested under the current enforcement regime and there is no published case law addressing these issues in the UAE competition law context.

The Competition Decree-Law and the Competition Executive Regulation do not contain express provisions on the admissibility of evidence obtained during governmental competition investigations in subsequent civil proceedings. The admissibility of such evidence would be governed by the general rules of evidence under UAE civil procedure law, which do not contain a specific bar on the use of regulatory investigation material in civil litigation. However, the strict confidentiality obligations imposed on the Ministry and all parties to competition proceedings (Article 19 of the Competition Decree-Law, Article 20(2) of the Competition Executive Regulation) may limit the extent to which documents and information gathered during an investigation can be produced or relied upon in private civil proceedings without the written consent of the information’s owner or pursuant to applicable legislation.

Given the emerging state of competition enforcement under the Competition Decree-Law, effective since December 2023, there is no publicly available data on the frequency with which private civil competition claims proceed to completion, or are dismissed or settled in the UAE. The Competition Decree-Law does not establish a specific discovery process for civil competition claims, and the UAE civil procedure law does not recognise broad pre-trial disclosure or discovery mechanisms of the type found in common law jurisdictions.

However, under the UAE Law of Evidence, a party may request that the court order the opposing party, or, in certain circumstances, a third party, to produce specific documents relevant to the dispute. Evidence is otherwise generally presented through party submissions, court-appointed experts and documentary evidence filed before the court.

No publicly available data exists regarding the typical timeframe for resolution of private competition claims under the current regime.

The Competition Decree-Law and the Competition Executive Regulation contain no specific provisions on the recovery of attorneys’ fees in private civil competition proceedings. Under general UAE civil procedure principles, courts have discretion to order the unsuccessful party to pay the successful party’s legal costs, including attorneys’ fees, though such awards are typically modest and determined at the court’s discretion rather than on the basis of actual fees incurred.

However, Federal Decree-Law No (34) of 2022 on the Regulation of the Legal Profession (specifically Article 49) and its Implementing Regulation (Cabinet Resolution No 8 of 2025, Article 31) have introduced a significant change by expressly permitting success fee arrangements. Under these provisions, an attorney and client may agree on a fee calculated as a percentage of the value achieved (capped at 25%), provided the agreement is in writing and stipulates that fees are not due if the case is lost. Outside such contractual agreements, attorneys’ fees in civil competition claims continue to be governed by the general rules governing civil litigation costs in the UAE.

The Competition Decree-Law and the Competition Executive Regulation contain no specific provisions governing the liability of unsuccessful claimants for defence costs or attorneys’ fees in civil competition proceedings.

Under general UAE civil procedure principles, the court has discretion to order costs against the unsuccessful party, though cost awards tend to be at modest fixed or discretionary amounts rather than full indemnity. There is no specific regime applicable to collective or representative actions, as such actions are not currently available under UAE competition law. The appointment of specialised experts during a governmental investigation is expressly at the complainant’s expense (Article 23(8) of the Competition Executive Regulation), though this relates to the investigative rather than the civil litigation phase.

In private civil competition proceedings, the ordinary UAE civil appellate framework applies. Judgments issued by the Court of First Instance may generally be appealed before the Court of Appeal, which reviews both factual and legal issues. Recent amendments to the UAE Civil Procedure Law have introduced more streamlined procedural requirements for appeals, including stricter requirements regarding the submission of appeal grounds and supporting materials at the time of filing.

Final review is available before the Court of Cassation (or Supreme Court, depending on the jurisdiction), which principally reviews questions of law, jurisdiction and procedural validity rather than factual findings. Separately, administrative decisions issued pursuant to the Competition Decree-Law remain subject to the mandatory grievance and judicial review process under Article 34 of the Competition Decree-Law. Given the relatively recent implementation of both the 2023 competition regime and the procedural reforms, there is currently no publicly available data regarding the frequency or outcome of appeals in private competition litigation.

The Competition Decree-Law does not treat information sharing as a standalone cartel offence. However, the broad definition of “Agreements” – including agreements, arrangements, consortia or practices between undertakings, whether written or verbal, explicit or implicit, public or confidential – means that exchanges of competitively sensitive information may fall within Article 5 of the Competition Decree-Law where their subject, purpose or effect is to distort, lessen, prevent or restrict competition, including through price fixing, market allocation or co-ordination of commercial conduct. The Ministry has not issued specific guidance on information-sharing practices and, given the emerging state of enforcement under the 2023 regime, there is no publicly available enforcement record that specifically addresses such conduct.

Although the Federal Decree-Law No (36) of 2023 Regulating Competition and its Executive Regulation do not contain standalone provisions specifically addressing algorithmic pricing or AI-facilitated collusion, the issue is expressly recognised in Ministerial Decision No (96) of 2026 Regarding Granting a Temporary Exemption to Certain Agreements and Categories of Contracts Aimed at Ensuring the Continuity of Supply of Essential Goods and Services in Exceptional Circumstances.

The Decision provides that exempted co-operation may not include any form of co-ordination regarding prices, discounts, costs, profit margins or pricing elements (whether directly or indirectly), “including through systems or algorithms” (Article 4(1)(b)). This indicates that the Ministry is aware of the potential competition risks associated with algorithmic co-ordination and has expressly excluded such conduct from permissible co-operation, even within the crisis-exemption framework.

No investigations or enforcement actions involving AI or digital forensic tools have been publicly reported to date.

UAE competition law treats monopolisation and cartel conduct as distinct categories of anti-competitive behaviour. The Competition Decree-Law prohibits the abuse of a dominant position by an undertaking holding dominance in the relevant market or a substantial part thereof, where such conduct has the object or effect of distorting, restricting, lessening or preventing competition (Article 6 of the Competition Decree-Law). A dominant position may exist where an undertaking exceeds the market share threshold prescribed by the Cabinet or otherwise has the ability to harmfully influence the market. Separately, Article 7 of the Competition Decree-Law prohibits the abuse of economic dependence when customers or suppliers lack reasonable alternatives. These provisions operate independently from the cartel prohibitions under Article 5, and monopolisation is therefore not treated as a cartel offence under UAE competition law.

Recent ministerial decisions issued under Federal Decree-Law No (36) of 2023 indicate heightened regulatory attention to the food supply, logistics and digital platform sectors. For example, Ministerial Decision No (74) of 2026 addresses unjustified price increases in land transport, food delivery and port operational services during emergencies, while Ministerial Decision No (32) of 2026 grants a block exemption for certain exclusive dealing arrangements in the food promotion and delivery platform sector. Further, Ministerial Decision No (96) of 2026 establishes a temporary exemption framework for co-operation related to essential goods, transport and logistics services during exceptional circumstances.

These developments suggest that sectors linked to essential supply chains, transportation, logistics, food distribution and digital commerce are currently areas of increased regulatory focus. As the enforcement regime continues to develop, broader retail, e-commerce and technology-enabled platform markets may also attract closer scrutiny from competition authorities.

The Competition Decree-Law and the Competition Executive Regulation do not contain specific provisions addressing the preservation of evidence stored on messaging applications or chat platforms, nor has the Ministry issued formal guidance concerning ephemeral communications. However, the general investigatory powers under the Competition Executive Regulation extend to the examination of all records, documents and electronic files during inspections and investigations (Article 23(7) of the Competition Executive Regulation).

Further, the Competition Decree-Law prohibits the withholding, destruction or provision of misleading information or data relevant to an investigation, and violations may result in fines ranging from AED50,000 to AED500,000 (Article 27 of the Competition Decree-Law). These obligations would likely apply equally to relevant electronic communications maintained through messaging applications or digital communication platforms.

The Competition Decree-Law does not expressly address “no poach” agreements or labour market allocation as a specific category of cartel offence. However, the broad prohibition on agreements whose subject, purpose or effect is to distort, lessen, prevent or restrict competition – including agreements to share markets or segment customers on any basis that negatively affects competition – could in principle be applied to labour market allocation arrangements (Article 5(2)(a) of the Competition Decree-Law).

The Ministry has not issued specific guidance on no poach agreements and no enforcement action in this area has been publicly reported under the current legislative framework; the issue, therefore, remains untested under UAE competition law.

As explained in 3. Leniency, Immunity and Whistle-Blower Regimes, there is no formal leniency or amnesty regime under UAE competition law and, accordingly, no data is available on leniency filing trends. The Ministry does have express authority to conduct ex officio market monitoring and investigations: it may conduct periodic monitoring of markets and request data, information and documents from undertakings for the purposes of market studies or investigatory proceedings on its own initiative, independently of any complaint (Article 26(3) of the Competition Executive Regulation). Further, any person may report a violation to the Ministry, the Relevant Authority or the Sectoral Regulatory Agency (Article 26(4) of the Competition Executive Regulation).

Given the emerging enforcement regime, no data is available on the relative frequency of ex officio versus complaint-driven investigations.

Considering the emerging state of competition enforcement under the Competition Decree-Law, which entered into force in December 2023, there is no publicly available data on the domestic-versus-cross-border breakdown of cartel investigations. The Competition Decree-Law has broad extraterritorial application, extending to economic activities conducted outside the UAE that affect competition within the UAE (Article 3 of the Competition Decree-Law), indicating that cross-border cartel conduct affecting UAE markets may fall within the Ministry’s jurisdiction.

The UAE has also recently increased its international competition co-operation efforts, including through accession to the International Competition Network (ICN) and the conclusion of a bilateral Memorandum of Understanding with the Egyptian Competition Authority concerning co-operation, exchange of expertise and co-ordination on competition matters. However, given the relatively recent implementation of the current regime, the practical extent of cross-border cartel enforcement and international investigative co-ordination remains to be tested.

The Competition Decree-Law and the Competition Executive Regulation do not contain ESG-specific competition law mandates or formal guidance concerning the interaction between ESG initiatives and cartel enforcement. However, Article 9 of the Competition Decree-Law permits exemptions for agreements or practices that contribute to economic development, improve competitiveness, enhance production or distribution systems, or generate consumer benefits, provided that such arrangements do not impose restrictions beyond what is necessary or result in the complete elimination of competition. In principle, certain ESG- or sustainability-related co-operation arrangements could potentially fall within this exemption framework, subject to assessment and approval by the Ministry.

To date, however, the Ministry has not issued specific guidance regarding ESG co-operation or sustainability agreements, and undertakings seeking to rely on ESG-related justifications for collaborative conduct would likely need to pursue the formal individual exemption process.

The UAE has taken a notable legislative step to address crisis-related co-operation and supply chain disruptions. Ministerial Decision No (96) of 2026 Regarding Granting a Temporary Exemption to Certain Agreements and Categories of Contracts Aimed at Ensuring the Continuity of Supply of Essential Goods and Services in Exceptional Circumstances grants a temporary exemption for certain agreements and arrangements between undertakings aimed at ensuring the continuity of production, supply and distribution of essential goods and services (including food, transport and logistics services) during emergencies or exceptional circumstances, provided such co-operation is necessary, proportionate and temporary, and does not involve price co-ordination or a substantial restriction of competition.

In parallel, Ministerial Decision No (74) of 2026 Regulating Price Increases for Certain Land Transport, Logistics and Port Operational Services During Emergency Circumstances prohibits providers of land transport and port operational services from increasing prices during emergency circumstances without prior Ministry approval, reflecting the Ministry’s concern about price exploitation during supply disruptions (Article 4 of Ministerial Decision No (74) of 2026). These measures demonstrate that the Ministry is actively addressing the risks of both crisis cartelisation and opportunistic pricing amid ongoing supply chain and inflationary pressures.