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Deal by Design
Welcome to this edition of Law Update, focusing on the evolving M&A landscape across the MENA region. With deal activity and value continuing to grow, the region is seeing increased investor interest alongside a changing regulatory environment.
This edition explores key legal and market developments affecting M&A transactions, including regulatory reforms, foreign investment, governance, due diligence and deal structuring across the region.
In April 2025, Qatar published Law No. 6 of 2025 on Regulating Health Research (Health Research Law), establishing a comprehensive legal framework for the conduct of health research within Qatar. Whilst the law had immediate effect, it permitted existing research institutions, research review committees, biobanks, and researchers conducting health research at the time of its entry into force to regularise their status in accordance with its provisions within a 12-month period (i.e. by April 2026).
The Health Research Law applies to all health research activities, research institutions, research review committees, researchers, participants and biobanks. Health research covers the following activities:
The Health Research Law mandates that health research may only be conducted through research institutions and with the approval of research review committees. Researchers eligible to conduct health research must meet specific qualifications, be registered with licensed institutions, and have no convictions for crimes involving dishonesty or breach of trust.
The establishment and operation of research institutions and research review committees require licensing from the Ministry of Public Health, based on the approval of the National Committee for Health Research Ethics. The licensing process is subject to detailed requirements regarding institutional structure, staffing and management.
Clinical trials may only be conducted through a research institution. Clinical trials involving unregistered medical products, new uses or combinations of registered products, or novel medical procedures require a licence from the Ministry of Public Health and the approval of the National Committee for Health Research Ethics.
Principal investigators for such trials must also be licensed by the Ministry of Public Health, based on the approval of the National Committee for Health Research Ethics. In order to obtain the status of Principal investigator in clinical trials, such individuals must be licensed physicians or dentists who meet stringent qualification criteria, are registered with such licensed research institutions, and have no convictions for crimes involving dishonesty or breach of trust.
Research participants are subject to protection under the Health Research Law, including the right to free healthcare related to research participation, restrictions on the frequency of participation in clinical trials for healthy volunteers, and requirements for informed consent. Research institutions and researchers are obligated to maintain data confidentiality, avoid conflicts of interest, and promptly report adverse events. The selection of participants must be non-discriminatory, and participants retain the right to withdraw from research at any time.
With regard to handling data obtained during the research, the researcher, the principal investigator, and the research institutions are required to protect data confidentiality by: using encryption or anonymisation of identifying information; refraining from disclosing names in reports; restricting access to data; using locked cabinets to store files; and protecting computerised data systems.
Importantly, the Health Research Law imposes strict prohibitions on certain research activities, including:
Moreover, it prohibits the disclosure or publication of the results of genetic research that may have a harmful impact on society, particularly those that reinforce concepts of race or origin.
The use or funding of embryonic stem cells and induced pluripotent stem cells within Qatar is prohibited (even if they are derived from sources authorised outside of Qatar), for the following purposes:
Furthermore, the Health Research Law sets out detailed conditions for research involving gametes, surplus fertilised eggs, aborted or miscarried fetuses, children, persons lacking legal capacity, pregnant women, and the use of embryonic stem cells originating from surplus fertilised eggs from in-vitro fertilisation procedures.
The export of biological samples outside of Qatar for research purposes is strictly regulated, requiring permits and compliance with specific conditions to protect participants’ confidentiality and ensure public health benefits.
The National Committee for Health Research Ethics, which is established within the Ministry of Public Health, oversees ethical issues, approves licensing applications, and monitors adverse effects in research. A separate Health Research Oversight Committee is tasked with reviewing violations and recommending penalties.
The establishment and operation of biobanks is also regulated. In order to establish the same, a research institute must obtain a permit from the Ministry of Public Health and prior approval from the National Committee for Health Research Ethics. Moreover, a licence to establish biobanks will be issued only upon approval of the Minister.
The Health Research Law sets out various penalties for non-compliance. Administrative penalties include warnings, suspension of research activities, closure of institutions, and revocation of licences. In addition, criminal penalties vary by offence.
Settlement is permitted for certain offences — excluding the most serious — upon payment of half the maximum fine and rectification of the violation.
Further conditions with regard to the Health Research Law will be regulated in executive regulations that are yet to be issued.