AI Regulation in the UAE

For this informative page, we will dive in the latest regulatory developments in various jurisdictions within the UAE, categorizing them as:

• The Financial Free Zones – The Dubai International Financial Centre (DIFC) and the Abu Dhabi Global Market (ADGM)

• United Arab Emirates – The remainder of the UAE outside the Financial Free Zones

The Financial Free Zones

The ADGM and DIFC have not introduced specific AI regulations but have made amendments to their existing data protection laws to address AI-related developments. For example, Article 10 of the DIFC Data Protection Regulations now governs personal data processed by autonomous and semi-autonomous systems, requiring deployers and operators of these systems to meet certain obligations.

In 2023, the ADGM partnered with Mohamed bin Zayed University of Artificial Intelligence (MBZUAI) to enhance the role of AI in achieving regulatory outcomes in the financial sector.

Although neither the DIFC nor the ADGM have issued any AI-focused regulations, other existing DIFC and ADGM laws will apply to AI developments, such as:

• The DIFC Intellectual Property Law – which indicates that AI software would not be patentable.

• Article 432 of the UAE Penal Code – which enforces penalties for unauthorized trade secret disclosures, applicable in both DIFC and ADGM jurisdictions.

Mainland UAE

UAE does not have a unified law regulating AI, but various decrees and guidelines illustrate the country’s commitment to AI leadership. Key milestones include the appointment of his Excellency Omar Sultan Al Olama as Minister for AI in 2017, to enhance oversight and strategic direction in relation to AI at a federal level, and the release of the UAE National Strategy for AI 2031, aimed at making the UAE a global leader in AI by 2031. In 2018, Law No. 25 of 2018 empowered the Cabinet to issue interim licenses for AI projects where no regulatory framework existed.

In 2024, the Artificial Intelligence and Advanced Technology Council (AIATC) was established to oversee AI projects, research, and investments in Abu Dhabi. Additionally, the AI Office published several non-binding guidelines, such as the Deepfake Guide (2021), AI Ethics Guide (2022), AI Adoption Guideline in Government Services (2023), and the Responsible Metaverse Self-Governance Framework (2023).

Regulatory Collaboration and Events

In 2021, Mainland UAE and free zone financial regulators jointly issued the Enabling Technologies Guidelines, providing governance frameworks for technologies such as AI, cloud computing, and biometrics. Furthermore, both Abu Dhabi and Dubai have created government bodies and initiatives to promote AI, such as the AI Retreat in Dubai, which gathers global experts to discuss AI adoption in the UAE.

Final Observations

Currently, the UAE government has introduced guidelines that focus on promoting best practices for the use of AI. These laws also empower government and ministry bodies to establish frameworks regulating AI deployment. It is expected that these guidelines will evolve into a more robust regulatory structure. However, while AI-related regulations are emerging, existing laws not initially designed for AI may be insufficient. These non-specific AI laws may not align with the unique challenges posed by AI, highlighting the need for more specialized and updated regulations to properly govern its usage.