United Arab Emirates. Comprehensive data protection. Federal Decree-Law

UAE PDPLFederal Decree-Law No. 45 of 2021 on the Protection of Personal Data

In force
Partly verifiedMedium confidence. Executive Regulations and penalties decision not verified as issued; market-quoted fine figures (AED 50k–5m) could not be traced to a primary source. Text URL on uaelegislation.gov.ae assumed from portal pattern; Arabic PDF also on u.ae assets.

§1Summary

Synopsis

The onshore federal data protection law for the UAE, setting consent as the default lawful basis with listed exceptions, data subject rights, security duties and restrictions on transfers abroad. Much of the operational detail is left to Executive Regulations which have not yet been issued, so enforcement has been minimal.

Key themes
  • consent
  • lawful bases
  • data subject rights
  • DPO
  • breach notification
  • records of processing
  • cross-border transfers
  • automated processing
Unique features

Excludes government data, health data and banking/credit data already covered by their own laws, and does not apply in the DIFC and ADGM free zones. Penalties are to be fixed by a Cabinet decision rather than in the law itself.

SaaS relevance

Applies to controllers and processors outside the UAE that process data of people in the UAE, so a SaaS serving UAE users is in scope even without local presence.

§2Obligations

Extraterritorial
Yes
Breach notification
Data Office promptly on awareness (procedure to be set by Executive Regulations); data subjects in some cases
DPO
Conditional
Cross-border transfers
Adequacy (Data Office-approved countries) or listed exceptions/contracts; details await Executive Regulations
Maximum penalty
To be set by Cabinet decision (not yet published)

§3Dates

Key dates
  • Adopted
  • In force
  • Issued Sept 2021; in force 2 Jan 2022; Executive Regulations (due within 6 months) still unpublished as of 2026; Cabinet penalty decision not published

§4Text and authority

Text
Authority
UAE Data Office

§5Where it applies

Domestic law of
United Arab Emirates
Also applies in

§6Sources and verification

Sources consulted
Verification

Medium confidence.

Partly verifiedMedium confidence. Executive Regulations and penalties decision not verified as issued; market-quoted fine figures (AED 50k–5m) could not be traced to a primary source. Text URL on uaelegislation.gov.ae assumed from portal pattern; Arabic PDF also on u.ae assets.