Effective May 29, 2025, the Emirates Media Council implemented significant reforms to the UAE’s media regulations under Federal Decree-Law No. 55/2023, further detailed and operationalized by the Cabinet Resolution No. (20) of 2025 on Media Activities Regulation. This legislative update introduces a robust legal framework to govern digital media, particularly influencer marketing and online content creators. The reform aims to ensure quality control and compliance with national values while fostering the economic potential of the digital media sector. The new framework imposes substantial obligations on companies and individuals alike, especially regarding licensing, content regulation, and liability. This article outlines the most significant changes introduced by the May 2025 reform, highlighting key provisions of the law and the accompanying Cabinet Resolution.
I. Digital Licensing Requirements from May 2025
As of May 29, 2025, a critical change came into force: all natural or legal persons engaged in commercial activities on social media—such as sponsored posts, product placements, or affiliate marketing—are now subject to a dual licensing requirement. Specifically, they must hold a standard business license under commercial law and, additionally, a separate media license issued by the Emirates Media Council. This obligation is explicitly mandated by Articles 6 and 7 of Federal Decree-Law No. 55/2023, as further clarified and operationalized by the Cabinet Resolution No. (20) of 2025 on Media Activities Regulation, which details application procedures, fee structures, and compliance obligations. Violations can result in fines of up to AED 1,000,000, with repeat offenses punishable by up to AED 2,000,000, as set out in Article 23. This approach enhances transparency and regulatory oversight of digital media activities.
II. Content Standards and Sanctions under Articles 17–23
In addition to the dual licensing requirement, the law sets strict content obligations. Article 17 requires all media professionals to respect religious and cultural values, uphold national identity, and refrain from content that promotes hate speech, discrimination, or incitement to violence. Article 18 imposes additional standards to protect public morality and security. Notably, Article 19 introduces a mandatory age rating system for all media content, including social media posts, streaming platforms, and video content, requiring companies to display age ratings clearly. Article 20 mandates explicit disclosure of advertising and sponsored content—such as using hashtags like #ad or #sponsored—to ensure consumer transparency. Violations of these content rules can be punished under Article 23 with fines ranging from AED 1,000 to AED 1,000,000, or up to AED 2,000,000 for repeat offenses, as well as potential license suspension or business closure.
III. Technological Enforcement, Fee Exemptions, and Grey Areas
To facilitate enforcement, the Emirates Media Council is deploying AI-based systems to automatically detect and flag potentially non-compliant content (Article 9 and Executive Regulations). This technology supports companies in meeting their obligations under Articles 17–20 but requires robust internal review and documentation processes. The law also grants a three-year exemption from licensing fees for first-time applicants in the influencer sector (Article 24 and Executive Regulations), encouraging businesses to transition into the new licensing regime and invest in professional compliance structures. Nevertheless, interpretative challenges remain, especially regarding the scope of “commercial” activities under Article 6(1) and the distinction between private and commercial postings, creating potential legal risks for influencers and agencies.
IV. Recommendation for Companies
Companies engaged in influencer marketing or digital media production should carefully assess their activities to determine commercial status and apply for both business and media licenses as required. Internal compliance systems must be established to ensure adherence to content standards under Articles 17–20, including respect for cultural values, age ratings, and advertising disclosures. AI content monitoring tools may assist but cannot replace ultimate managerial responsibility. Contracts with influencers should include clear provisions on liability, licensing, and approval processes. Legal consultation is advised to clarify ambiguities, particularly regarding “commercial” definitions and private usage exemptions, to minimize liability risks.
V. Conclusion
The May 2025 amendments to Federal Decree-Law No. 55/2023, complemented by Cabinet Resolution No. (20) of 2025 on Media Activities Regulation, mark a pivotal development in UAE media law. Influencers and digital content creators are now subject to stringent regulatory standards comparable to traditional media companies. The dual licensing requirement, detailed content obligations, and strict penalties necessitate thorough preparation by businesses. The three-year licensing fee exemption period should be leveraged to build compliance capabilities and sustainable strategies. Failure to comply risks significant fines and reputational damage, extending beyond direct financial consequences.
