UAE Competition Law Overhaul: Mandatory Merger Control Takes Effect 30 July 2026
The United Arab Emirates has entered a new era of competition enforcement. Cabinet Decision No. 59 of 2026, the long-awaited Executive Regulations of Federal Decree-Law No. 36 of 2023 on the Regulation of Competition, was issued in April 2026 and comes into force on 30 July 2026. It replaces the outdated Cabinet Resolution No. 37 of 2014 and fundamentally reshapes how mergers and acquisitions are cleared in the country.
A mandatory and suspensory regime
For the first time, merger control in the UAE is both mandatory and suspensory. Parties to a qualifying transaction must notify the Ministry of Economy and cannot complete the deal — transferring ownership, exercising voting rights or integrating operations — until clearance is obtained. This “standstill” obligation aligns the UAE with mature jurisdictions and demands early legal planning for any deal touching the Emirates.
The new notification thresholds
A filing is triggered where either of two alternative tests is met: the parties’ combined annual sales in the relevant UAE market exceeded AED 300 million in the previous financial year, or their combined market share exceeds 40% of the relevant market. A 40% share also creates a presumption of dominance under Cabinet Decision No. 3 of 2025.
Timelines and penalties
The Ministry has 10 business days to confirm whether a notification is complete, followed by a formal review period of 90 days that may be extended by a further 45 days. Failure to file carries serious consequences: fines ranging from 2% to 10% of relevant annual sales in the UAE, or between AED 500,000 and AED 5,000,000 where sales cannot be determined.
What businesses should do now
With the deadline days away, any company contemplating an acquisition, joint venture or restructuring with a UAE nexus should assess immediately whether a filing is required and build clearance timing into its deal calendar. Gun-jumping — closing before approval — is now a genuine risk. At Dubai Legal Expert, our commercial team advises acquirers, sellers and investors on notification strategy, thresholds analysis and engagement with the Ministry of Economy.
Facing a transaction that may require merger clearance? Speak to our commercial litigation and corporate lawyers in Dubai. For a confidential assessment, contact Dubai Legal Expert.
