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Author: Dubai Legal Expert · info@dubailegalexpert.com · +971 52 728 2413 Published: 18 September 2026 · Last updated: 18 September 2026 Reading time: ~11 minutes

> Quick answer > In the UAE you generally cannot sue an onshore, Central Bank–licensed insurer straight away. First you file a written complaint with the insurer and wait out the response period. Then you complain to Sanadak, the Central Bank’s ombudsman, which is free for consumers. If you’re still unhappy, you escalate to the Insurance Dispute Resolution Committee (IDRC). For claims above AED 50,000, either side can then appeal to the Court of Appeal within 30 days.

Table of contents

1. Why you can’t go straight to court
2. The four-stage escalation route
3. Stage 1: The internal complaint to your insurer
4. Stage 2: Filing with Sanadak
5. Stage 3: The Insurance Dispute Resolution Committee
6. Stage 4: The Court of Appeal
7. Deadlines and fees at a glance
8. Two worked examples
9. Why complaints get rejected on technicalities
10. Is your insurer under Sanadak’s jurisdiction?
11. Evidence checklist
12. FAQs
13. Sources and references

1. Why you can’t go straight to court

Many policyholders, especially those used to UK, Indian or US systems, assume a denied claim means a lawsuit. In the UAE the order is fixed by law.

Federal Decree-Law No. 48 of 2023 on Regulating Insurance Activities replaced the 2007 insurance law. It was published on 31 October 2023 and took effect on 30 November 2023, and its biggest changes concern how insurance disputes are resolved. The Central Bank of the UAE (CBUAE) later set up Sanadak as the single gateway for these complaints. Sanadak began operating on 7 March 2024, taking over from the earlier Banking and Insurance Dispute Resolution Unit.

The practical result is set out in Sanadak’s own guidance. Complaints against banks can go directly to court, but complaints against insurance companies must go to Sanadak first. If you file in court first, you risk losing months on a claim that is inadmissible.

This is the single most common procedural mistake we see. It matters for motor, medical and property claims alike.

2. The four-stage escalation route

3. Stage 1: The internal complaint to your insurer

A rejection email from a claims handler is not the same thing as a formal complaint. Sanadak will turn away your case if you skip this step. The UAE government portal lists as grounds for rejection that the consumer never raised an official complaint with the insurer, or did not wait 15 calendar days after raising it.

Waiting period: older guidance from brokers and firms says 30 calendar days. Sanadak’s current online eligibility checker asks whether 15 calendar days have passed since you complained with no written response, or with a response you’re unhappy with. Always check the live eligibility tool on the day you file.

Your written complaint should:

• quote the claim number and policy number;
• ask for the specific policy clause relied on for the denial. Under the CBUAE Rulebook, when a claim is fully or partly denied, the insurer must explain its reasons in writing;
• request the surveyor’s or loss adjuster’s report, if one was used;
• state the amount you are claiming;
• be sent through a traceable channel, such as the insurer’s complaints email or portal, and never only by phone.

Tip: get a complaint reference number. You will need it on the Sanadak form.

4. Stage 2: Filing with Sanadak

Sanadak handles complaints about health, car, property, general, marine and life or investment insurance, among other products. Filing is online or through the app. Elderly consumers and people of determination can use the 800SANADAK call centre or visit in person.

Time limit to file: you have up to three years from the conduct complained of, or two years from when you became aware of it, whichever is longer. Exceptions may be considered in some circumstances.

What happens next: if the consumer has provided everything required, the insurer must review the complaint and give a resolution within five working days. Sanadak then contacts you with the outcome.

Watch the three-day trap. If you don’t object within three working days of receiving Sanadak’s decision, the complaint closes automatically. Diarise this the moment you are notified.

5. Stage 3: The Insurance Dispute Resolution Committee (IDRC)

If Sanadak’s outcome doesn’t resolve the dispute, you escalate to the IDRC through the same portal. Sanadak describes the IDRC as sitting within Sanadak and acting as the first instance for insurance complaints. Only insurance disputes are referred to it.

Key procedural points:

• Deadline to escalate: either party can appeal within 30 complete business days of Sanadak’s determination.
• Hearings: sessions can be held in person or remotely. The committee decides within 20 working days of receiving all documents and may extend this. Its decision is treated as a writ of execution.
• Missing a hearing: if you fail to attend without an acceptable excuse, the committee may decide the case or strike it off. A struck-off case can be re-registered within 30 days.

Because an IDRC decision is enforceable, it is often the real battleground. Prepare for it the way you would prepare for a court hearing, with a written memorandum, an indexed bundle and, where valuation is disputed, an independent expert report.

6. Stage 4: The Court of Appeal

This is where the AED 50,000 threshold matters. Article 101(5) of Decree-Law 48 of 2023 bars the insurer from appealing committee decisions in disputes of AED 50,000 or less; those decisions are final and immediately enforceable. Above that figure, the insurer may appeal to the Court of Appeal within 30 days, or the appeal is inadmissible. For claims over AED 50,000, both the insurer and the insured or beneficiary can appeal within 30 days.

The appeal skips the Court of First Instance entirely. For a policyholder with a mid-sized claim, the IDRC decision is therefore often the last word, which is why it pays to present the case properly the first time. See our guide on why a Dubai lawyer matters in UAE court proceedings.

7. Deadlines and fees at a glance

Fees: there are two published figures, so confirm on the portal at the time of filing.

• Sanadak’s FAQ states that initial complaints are free and appeals cost AED 500 each, refunded if the appellant wins.
• The 2024 resolution governing the committees sets a fee of 4% of the claim value for fixed-value disputes, with a minimum of AED 100 and a maximum of AED 30,000. Disputes of unspecified value carry a fixed AED 3,000 fee.

8. Two worked examples

Illustrative scenarios based on common fact patterns, not specific client matters.

Example A: motor claim, AED 38,000. A car is written off after flash flooding. The insurer denies the claim on the ground that the driver entered a flooded road. The policyholder files an internal complaint and waits the required period. Sanadak’s review doesn’t settle it, so the case goes to the IDRC. The committee finds that the exclusion wording didn’t clearly cover the circumstances. Because the claim is below AED 50,000, the insurer cannot appeal and the decision is enforceable immediately. If the 4% committee scale applies, the fee is roughly AED 1,520.

Example B: commercial property claim, AED 400,000. A warehouse fire claim is cut by 60% for alleged under-insurance, known as the “average” clause. The policyholder brings an independent valuation to the IDRC. Whoever loses has 30 days to go to the Court of Appeal. At 4%, the fee would be AED 16,000, which is below the AED 30,000 cap. For claims this size, a well-built IDRC file matters because the Court of Appeal will review the same record.

9. Why complaints get rejected on technicalities

Sanadak can refuse a complaint before looking at the merits. Grounds include identical complaints already in progress, cases already before a court, matters outside the Central Bank’s mandate, complaints mainly about pricing, risk-management or AML policies, and disputes already settled with the insurer.

Two practical warnings:

1. Signing a discharge or settlement form after a part-payment can count as settlement. Read it carefully before signing.
2. Starting a court case first can knock out the Sanadak route. Sequence matters.

There is some good news. If a complaint is rejected and you fix the reason, you can file it again.

10. Is your insurer under Sanadak’s jurisdiction?

Sanadak hears complaints against financial institutions and insurers licensed by the Central Bank of the UAE. Most onshore motor, medical and home policies fall under it. However, insurers operating from the DIFC are licensed by the DFSA, and those in ADGM by the FSRA. Disputes with those insurers follow different routes, typically the policy’s own dispute clause and the DIFC or ADGM courts.

Check the licensing authority shown on your policy schedule before you start. If the dispute involves a business policy or a cross-border reinsurer, speak to our commercial and financial lawyers.

11. Evidence checklist

• [ ] Full policy wording, including the schedule and all endorsements (not just the certificate)
• [ ] Claim form and every piece of correspondence, with dates
• [ ] The written denial showing the clause relied on
• [ ] Your formal internal complaint and its reference number
• [ ] Police report (motor, theft, fire), medical reports (health), or photos and timeline (property)
• [ ] Surveyor or loss adjuster report, plus your own independent report if you dispute valuation
• [ ] Proof of payment of premiums
• [ ] Any disclosures made at inception, which are relevant if the insurer alleges non-disclosure

12. FAQs

Can I skip Sanadak if my claim is large?

Not for a Central Bank–licensed insurer. The route through Sanadak and the IDRC comes first whatever the value. Value only affects whether a later court appeal is available.

Do I need a lawyer for Sanadak?

Not legally. Many straightforward complaints are handled by consumers themselves. Legal help becomes worthwhile at the IDRC stage, when the claim is near or above AED 50,000, or when the insurer alleges fraud or non-disclosure.

Does a Sanadak complaint stop limitation periods running?

Don’t assume so. Treat every deadline in §7 as live, and get advice early if you are close to the two- or three-year mark.

Can a hospital or garage complain on my behalf?

Providers often dispute payments directly with insurers. For a Sanadak complaint in your name, you remain the complainant, but you can use their records as evidence.

What if the insurer ignores an IDRC decision?

The decision is treated as a writ of execution, so it can be enforced through the execution process, much like a court judgment. Our insurance lawyers can handle enforcement for you.

Need help with a denied claim? Our insurance lawyers in Dubai review policy wording, draft the Sanadak and IDRC submissions, and represent you before the Court of Appeal. You can also read more about insurance claim disputes in Dubai.

Contact Dubai Legal Expert

• Website: dubailegalexpert.com
• Email: info@dubailegalexpert.com
• Phone / WhatsApp: +971 52 728 2413

Related guides:

• Banking & Finance Law
• All UAE legal guides

This guide is general information on UAE law as at the date above and is not legal advice. Procedures and fees may change; confirm current requirements with Sanadak or a licensed UAE lawyer.

13. Sources and references

1. Federal Decree-Law No. 48 of 2023 Regulating Insurance Activities, CBUAE Rulebook — https://rulebook.centralbank.ae/en/rulebook/federal-decree-law-no-48-2023-regulating-insurance-activities
2. Sanadak, FAQs — https://sanadak.gov.ae/en/faqs/
3. Sanadak, What to Expect — https://sanadak.gov.ae/en/what-to-expect/
4. Sanadak, Resolution Process — https://sanadak.gov.ae/en/what-to-expect/resolution-process/
5. Sanadak, Regulations for LFIs and Insurance Companies — https://sanadak.gov.ae/en/regulations/for-lfis-and-insurance-companies/
6. UAE Government Portal, Raising complaints against financial institutions and insurance companies — https://u.ae/en/information-and-services/finance-and-investment/raising-complaints-against-financial-institutions-and-insurance-companies
7. Federal Administrative Decision No. 10-A/1/2024 on the Insurance Disputes Settlement and Resolution Committees (summarised by Chambers & Partners) — https://chambers.com/articles/uae-central-bank-regulates-insurance-disputes-with-sanadak
8. Al Suwaidi & Co., Summary of Decree-Law 48 of 2023 (Article 101 analysis) — https://alsuwaidi.ae/the-uae-insurance-federal-decree-no-48-of-november-2023-a-summary-of-the-most-significant-changes/