A game-enhancer, not a game-changer: key takeaways on the new UAE Media Law penalties

Since it came into force in 2023, the new(ish) United Arab Emirates (UAE) Media Law (replacing its 1980s print-and-cinema predecessor) has included requirements for a broad range of media activities (undertaken in the UAE) to be licensed, with administrative penalties for breaches. The new UAE Cabinet Resolution (No. 42 of 2025, the “Resolution”) adds colour to the existing content by listing the specific breaches and penalties.  It is not, therefore, a game-changer, but more of a game-enhancer (or at least a more accurate positioning of goalposts).  As an ex-media regulator (previously working for a UAE media free zone authority), here are my seven key takeaways:

1.  Religion is top of the list: Derogatory and/or disrespectful treatment of religion or God in content carries the highest penalty (a fine of up to AED 1,000,000), indicating this is a priority concern for the Federal media regulator (the UAE Media Council).  Whilst I have always advised that content should not insult or mock religion, God/Allah or the Prophets, and particular care should be taken with the inclusion of religious scripts or places of worship in content, it is significant that disrespecting religion carries double the fine of disrespecting the State or State policies (which ranks at number two with penalties up to AED 500,000).  This mirrors the approach of the UAE Cybercrimes Law, where online contempt of religion is penalised by the largest fine of AED 1,000,000 (and up to seven years in prison).  Breach of privacy also ranks lower than anticipated as a “Category B” offence in the Resolution with a penalty of up to AED 100,000.   The clear priority order of the Resolution’s penalties list will be helpful for media organisations when drafting internal guidelines on how they will assess content and apportion risk (as internal policies should align with the Resolution). 
2. Not-breaking news; licenses are needed to carry out media activities in the UAE: The Resolution reiterates that licenses are required to perform media activities in the UAE (these can range from traditional broadcasters to social media platforms to individuals undertaking “digital media activities” to gaming companies).  This includes activities such as filming content without the required shooting permits or script approvals (with fines of up to AED 40,000).  There are also fines for repeated violation of practising an additional media activity not listed on the organisation’s license (i.e. the company or individual holds a media license, but it does not relate to all activities being undertaken) of up to AED 16,000 for each additional unlicensed activity.  This provides some clarity for media organisations and individuals (whether onshore in the UAE or in free zones) and reiterates the importance of ensuring that your license activities correspond to the reality of the activities undertaken.  This is a good opportunity to undertake a licensing audit of your organisation to ensure this is the case. 
3. Clear advertising and influencer content penalties: The Resolution deals with two points (i) advertising (in any format) that does not comply with the advertising conditions (Article 33 of the UAE Media Law) will be penalised by a fine of AED 10,000 (which can be doubled); and (ii) advertising through social media requires a license (with penalties of up to AED 20,000 – AED 50,000 for breach reaching the higher end of the bracket for committing the violation for a third time).  Advertising content (whether online/on socials or otherwise) should always be reviewed prior to publication to ensure compliance with the requirements (which include best practice standards such as not being vague or misleading, appropriately labelled as advertising, not promoting prohibited products, obtaining relevant additional approvals etc.). 
4. Focus on child-specific offences: In line with regional and global trends of ensuring a safe online environment for children, there are three specific child-related offences (although all in the lower category with penalties of up to AED 100,000).  These include a specific penalty for failing to age rate content (up to AED 50,000), anticipating that the age rating guidelines will be reissued by the UAE Media Council.  In the meantime, following international best practice in terms of protecting children from harmful content (including warnings, age ratings, appropriate scheduling or positioning of content) will ensure organisations do not fall foul of these broadly drawn obligations.
5. Reiterating empowerment of Emirate-level regulators: There are two levels of governance within the Resolution; the (highest level) Federal UAE Media Council and the “Competent Authorities” (which include Emirate-level media and free zone regulators).  The Competent Authorities have direct (and now, quantifiable) powers/obligations to impose fines for breaches of the UAE Media Law. This follows the recent trend of empowering Emirate-level regulators (such as media free zone authorities) to act autonomously when licensing (and penalising) media activities.  This will, of course, require clear and transparent Competent Authority-level compliance procedures to inform licensees of the rules, investigation processes, right to reply, decision-making, penalties and appeals (see below).
6. Right to appeal: Offenders will be informed of the relevant Resolution-specified penalty within 15 days of issue and will have a right to appeal to the UAE Media Council or Competent Authority (as relevant) within 15 days of being informed of said penalty. A final decision will be made within 15 days of the grievance being filed (with no response indicating a rejection of the appeal).  This process, whilst taking a relatively short period of 45 days in total, is potentially administratively burdensome for the relevant Emirate-level authorities as it will require the establishment of a separate appeals body (with independence from the original decision maker) and process (and a reasonably quick turnaround time for decision-making).
7. New Content Committee: A permanent Federal-level Committee will be established to review and decide on potential content violations (which will not, it seems, be decided at an Emirate level, as is the case with licensing breaches).   The Committee members will be media specialists, appointed by the Chairman of the UAE Media Council.  At this stage, it remains unclear whether the Committee will actively monitor content or simply respond to complaints made by the public, and how the Committee will interact with other Emirate-level media regulators. 

In conclusion, the recommended action points for media organisations are: 

1. Align internal content guidelines (in terms of assessing content and apportioning business risk) with the Resolution’s content penalties schedule
2. Carry out a licensing audit to ensure all business activities are covered by the relevant media licenses and permits
3. Review advertising content to ensure compliance with the rules and ensure appropriate licenses are held for online/influencer content
4. Follow international best practice in protecting children from inappropriate content  
5. Familiarise yourself with your regulator’s compliance processes, penalties and appeals structure

Saarah Badr is Senior Counsel at Bird & Bird (having spent eight years in-house in the media & entertainment industry) and available to discuss any of the issues highlighted above.