A new mandatory permit for influencers based in the United Arab Emirates.

As of February 1, 2026, any influencer operating in the United Arab Emirates (UAE), whether a citizen, resident, or temporary visitor, must hold an advertising permit before publishing any promotional content on social media.

This new permit (Advertiser Permit) marks a complete paradigm shift: where almost all jurisdictions worldwide are content with reactive declarative obligations, the UAE imposes a prior licensing system, transforming commercial influencing into a regulated activity subject to administrative authorization, similar to broadcasting or print media.

I. The Legislative Architecture: A Methodical Construction in Several Stages.

The Emirati regulatory framework is not the result of an isolated initiative or a circumstantial reaction. It is the product of a progressive normative construction, spanning nearly a decade, which has methodically broadened the scope of obligations imposed on digital content creators.

The major turning point came with the adoption of Federal Decree-Law No. 55 of 2023 on Media Regulation, which came into force on December 1, 2023.

This text, which repeals Federal Law No. 15 of 1980 on Publications and Printed Matter, now constitutes the framework law applicable to all media activities in the UAE. Article 3 of the Decree-Law stipulates that its provisions “_apply to all persons, establishments and media institutions, press bodies and media free zones carrying out media activities within the territory of the State_.”

The definition adopted by the legislature for “_media activities_” is intentionally broad: it encompasses “_the production, dissemination, printing or publication of media content_”, which content may take an audio, video or digital format, and the activity may be carried out for a fee or free of charge. This last point is crucial for practitioners, as it means that the mere publication of unpaid promotional content (a gifted product, a free stay, an unboxing) falls within the scope of the law.

Article 2 of the Decree-Law sets out the objectives pursued by the legislator with remarkable clarity.

The text aims to “_regulate all media activities in the State, in all their types and forms, to strengthen the media status of the State and to establish a stimulating environment for the growth of the media sector_”, to “_develop a modern legislative and media investment environment that accompanies global developments in the media sector and enhances the attractiveness of the media sector in the State_”, and to “_improve media content in the State in a manner that contributes to the development of the media sector_”. The ambition here is evident: it is not just about regulating, but about building an attractive ecosystem for media professionals, including influencers.

Article 7 of the Decree-Law regulates the conditions for issuing licenses and permits to practice. The applicant must have full legal capacity, be of good moral character and conduct, not have been convicted of any crime or offense affecting honor or trust, meet media content standards, not have had a license previously suspended or canceled, and pay the prescribed fees.

In free zones, Article 8 provides for a specific regime: media activities must, in principle, be carried out within the geographical limits of the free zone, and when they are carried out outside, the laws and regulations in force in the country apply. Persons and establishments licensed in free zones remain subject to the control and supervision of the competent authority to ensure their compliance with the provisions of the Decree-Law.

The latest institutional development, and not the least: Federal Decree-Law No. 11 of 2025, adopted in December 2025, created the National Media Authority (NMA).

This new federal entity merges the UAE Media Council, the National Media Office, and the Emirates News Agency (WAM) into a single regulator. Article 5 of the founding Decree-Law stipulates that the NMA “_replaces the UAE Media Council in the exercise of the powers assigned to it under Federal Decree-Law No. 55 of 2023 on Media Regulation or any other legislation_.”

II. The Advertising Permit (Advertiser Permit).

This is the centerpiece of the new system. Launched during 2025 and becoming mandatory on February 1, 2026, after the expiration of a grace period, this permit is issued by the National Media Authority.

The permit is required for “_any person - influencer, content creator or digital marketing professional - in the UAE who publishes advertisements or promotional content on social media, whether paid or unpaid_.”

Three distinctive elements merit attention.

Firstly, the territorial and personal scope is remarkably broad. The permit is required for any natural person creating advertising content from within the UAE, regardless of their nationality, residency status, or length of stay. A French influencer visiting Dubai for a few days, who publishes promotional content during their stay, is subject to this obligation in the same way as a permanent resident. For visitors, a Visitor Advertiser Permit is available, at a cost of 500 AED for a duration of three months, renewable once for an additional three months. Obtaining this visitor permit is mandatory through an accredited local agency.

Secondly, there is no minimum follower threshold to trigger the obligation. The permit applies uniformly to all content creators, regardless of the size of their audience. Whether an influencer has 500 or 5 million subscribers, the obligation is the same. This universal approach radically distinguishes itself from foreign systems, which tend to primarily target creators with significant audiences or measurable commercial influence.

Finally, the initial free nature of the permit acts as an incentive for voluntary compliance.

For UAE citizens and residents who register on time, the permit is free for the first three years, before being charged at the annual rate.

The conditions for obtaining the permit are as follows:

- Be fully legally capable and at least 18 years old. - Have good conduct and not have been convicted of offenses affecting honor or integrity, except in cases of rehabilitation. - Hold a valid commercial license for an electronic media activity issued by the competent authority (minors may operate under the license of a legal guardian). - Have successfully completed awareness and training programs organized by the Council. - Not have outstanding financial debts to the Council. - Fulfill any other conditions or requirements determined by the Council. - Not have previously violated media content standards.

III. Obligations Imposed on Licensed Influencers.

The obligation of advertising transparency is naturally the central piece of the system. All promotional content must be explicitly identified as such, including unpaid promotions.

The advertising permit number must be visibly displayed on all social media profiles used for promotional purposes. All accounts used for advertising must be registered with the NMA.

Published content must, in particular, respect religious beliefs, the sovereignty and symbols of the State, the country's political orientations, the foreign relations of the UAE, and Emirati culture and national identity. The dissemination of rumors, false or misleading information, or any content likely to incite violence or discord is strictly prohibited.

Certain categories of advertising require additional approval from specific sectoral authorities. Four sectors are concerned: health, finance, real estate, and education. For these areas, obtaining the advertising permit is not sufficient: the content creator must obtain prior approval from the competent sectoral authority before any publication.

For brands and agencies: before engaging or compensating an influencer for a campaign, proof of their advertising permit should be requested. Internal marketing teams and legal departments must also verify that the company's official social media accounts are covered, and that employees acting as brand ambassadors are themselves licensed if necessary. Marketing agencies that produce content or manage advertising campaigns may also be required to secure their own license or register with the authorities.

IV. A Graduated but Severe Sanction Regime.

Article 23 of Federal Decree-Law 55/2023, the full text of which is available on the uaelegislation.gov.ae portal, provides that in the event of violation, offending persons, establishments or media institutions are subject to one or more of the following administrative penalties: a warning; an administrative fine “of a minimum of one thousand (1,000) AED and a maximum of one million (1,000,000) AED”, the fine being “doubled in the event of recidivism, without exceeding two million (2,000,000) AED” and the cancellation of issued licenses, permits and authorizations.

The text further provides that the offender may be required to bear the costs of removal and compensation for damages resulting from the violation. Paragraph 3 of Article 23 adds a clarification of considerable importance for the assessment of legal risk:

“_the application of the administrative penalties referred to in paragraph 1 of this article shall not prejudice the penalties or sanctions provided for in other legislation_.”

Decision No. 42/2025 also establishes a permanent committee for violations of media content standards within the regulator. This committee, composed of three to seven members specializing in the media field, is responsible for examining violations of content standards and imposing appropriate administrative sanctions. In determining the sanction, it must take into account the seriousness of the violation in its media, economic, political, and social aspects.

Thus, any promotional activity carried out from the territory of the UAE, including during a mere professional trip of a few days, is subject to this regime. However, Dubai has become a major destination for content creators, and press trips, brand events, festivals, and commercial collaborations are multiplying there.

Ignorance of these obligations exposes one to very real legal and financial risks.