Find a Competition & Merger Control Lawyer

Competition law in the UAE governs mergers, agreements between competitors, and abuse of a dominant market position, aiming to protect competitive markets rather than any individual competitor.

It is a comparatively young, federal regime, substantially reformed in the last few years, which means genuinely current knowledge matters more here than in more settled areas of UAE law.

Federal Decree-Law 36 of 2023 replaced the earlier Federal Law 4 of 2012 and took effect on 29 December 2023, establishing the current framework for UAE competition law.

Businesses and lawyers still relying on guidance written for the 2012 law risk missing the current thresholds and mechanisms that now actually apply.

The Executive Regulations to Federal Decree-Law 36 of 2023 were issued under Cabinet Resolution 59 of 2026 and took effect on 30 July 2026, filling in the operational detail of the 2023 law.

A lawyer with current knowledge of both the law and its Executive Regulations is better placed to advise accurately than one working from the 2023 law alone.

Cabinet Decision 3 of 2025 sets the merger notification thresholds: a filing is generally required where the parties’ combined UAE turnover exceeds AED 300 million, or their combined UAE market share exceeds 40%.

These thresholds are alternative rather than cumulative, meeting either one can trigger a notification obligation, independent of whether the transaction otherwise looks straightforward.

Where a transaction meets the relevant threshold, the parties generally need to notify the Ministry of Economy and Tourism before completing the deal.

A lawyer can assess early whether a specific transaction is notifiable, since building this assessment into deal timelines from the outset avoids delay later.

The Ministry of Economy and Tourism enforces UAE competition law, covering merger review, dominance investigations and restrictive agreement inquiries.

This is a distinct authority from the UAE’s financial regulators, VARA, the DFSA, the FSRA and the CBUAE, a competition matter and a financial regulatory matter are handled by entirely separate authorities even when they arise from the same underlying business.

The DIFC and ADGM, as financial free zones, fall outside the federal competition regime, and neither has enacted its own competition law.

This does not mean conduct connected to these free zones is automatically beyond reach, mainland-affecting conduct can still be caught by UAE competition law even where it originates from a DIFC or ADGM entity.

A point widely misunderstood, including by some advisers, is that the UAE has no leniency or immunity programme for parties who come forward about a competition law violation.

Instead, the only available route is a post-detection settlement mechanism, a materially different proposition from a leniency application that could secure immunity before detection.

The settlement mechanism allows a party to resolve a matter after detection by acknowledging the violation and paying a penalty of at least double the applicable minimum.

Because this requires both an admission and an elevated penalty, deciding whether to pursue settlement or contest a finding is a genuinely significant strategic decision, not a routine formality.

Agreements between competitors that restrict competition, such as price fixing or market allocation, are generally prohibited under the current framework.

Abuse of a dominant position covers a business with substantial market power using that position in ways that harm competition, assessed on the specific facts rather than a fixed formula.

A transaction between two companies headquartered outside the UAE can still trigger a UAE notification obligation if their combined UAE turnover or market share meets the relevant threshold.

International deal teams sometimes overlook this UAE-specific filing requirement when focused on larger jurisdictions, a lawyer with current UAE competition experience should be brought in early on any deal with meaningful UAE revenue.

Given the absence of a leniency route to soften the consequences of a violation, a proactive competition compliance programme is generally worth building before an issue arises, not after.

This typically covers training on pricing and distribution practices, record-keeping, and a clear internal escalation process if a concern arises.

A competition investigation can begin with an information request from the Ministry of Economy and Tourism, prompted by a complaint, a merger review, or a market study.

Organised records and a clear internal process for responding to such requests generally put a business in a stronger position from the outset.

Distribution, franchise and agency arrangements are a common source of competition law questions, particularly around exclusivity, resale price restrictions and territorial limits.

A lawyer can review these agreements for competition law risk alongside the commercial and franchise-specific considerations covered on our Franchise page.

LEXNOVA is not a law firm and does not provide legal advice. Legal Connect exists to help you describe a competition or merger control matter clearly, then explore potentially suitable lawyers from our network.

We consider whether your matter is a merger filing, a compliance review or an investigation, with every potential match reviewed by a person before an introduction.

Fees vary based on whether the matter is a straightforward merger filing assessment, a full notification, or a contested investigation.

LEXNOVA does not set or control fees, this is communicated directly by each professional, and it is reasonable to request a clear estimate before engaging anyone.