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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.
At WHX Dubai 2026 (formerly Arab Health), one theme stood out: wearable health technology is changing how healthcare is delivered in the Gulf region. The exhibition drew healthcare professionals from across the globe and highlighted the UAE’s growing role in digital health.
The UAE market now includes a range of wearable devices, from fitness trackers to devices that monitor blood glucose, cardiac rhythms, and sleep patterns. For healthcare organizations and technology companies, the UAE regulatory framework is clear: clinically oriented wearables are viable if they meet product, safety, data, and consumer protection requirements. The UAE’s health regulator, the Emirates Drug Establishment (the “EDE”), has consolidated oversight of medical products under a clear legislative framework, providing a defined route to market for wearables manufacturers. This article discusses some of these requirements and the practical implications of the wearable regulatory regime in the UAE.
Under Law 38/2024, “Medical Equipment” expressly includes wearable devices and products based on AI technology where the intended purpose is diagnosis, treatment, prevention, or other medical functions without a pharmacological, immune or metabolic effect. The intended use of a product determines its classification: if the wearable is marketed for medical or clinical purposes, it is regulated as Medical Equipment. General wellness products that are not intended to diagnose, treat, cure or prevent disease are classified as Health Care Products.
Two implications follow. First, regulated wearables must follow the Medical Product pathway, including EDE marketing approval, labeling, post-market vigilance, and advertising controls. Second, a wellness-only wearable must avoid claims that imply a medical function. Accurate definition at the outset helps companies establish a clear regulatory path depending on the type of product.
For wearable devices that meet the UAE definition of “Medical Equipment” (which includes wearable devices and AI-based products, as explained above) and are regulated as Medical Products under Law 38/2024 (“Regulated Wearables”), the core pathway is through EDE marketing approval via a UAE-licensed pharmaceutical establishment, supported by evidence which is proportional to the risk and intended use. Advertising related to the wearables must be pre-approved by EDE and align with cleared indications and risk disclosures.
Wearables are shifting care from episodic encounters to continuous monitoring, and when combined with AI analysis, this data can transform how healthcare services are delivered: a common topic of discussion at WHX Dubai amongst UAE health regulators.
In the UAE, providers can use Regulated Wearables to support early detection of deterioration, titration of therapies, and virtual chronic-care pathways. AI-powered analysis of wearable data enables pattern recognition across large patient populations, predictive alerts for clinical deterioration, and personalized treatment recommendations based on real-time metrics. This combination of continuous data streams and intelligent analysis allows clinicians to intervene earlier, allocate resources more efficiently, and tailor care plans to individual patient needs; if a device is used to inform diagnosis or treatment, it should be positioned and maintained as Medical Equipment under Law 38/2024.
Additionally, consideration must be given to the data generated by wearables. It is usually classed as “health data” when it relates to an identifiable person’s health status. Federal Law No. 2 of 2019 on the Use of ICT in Health Fields and Cabinet Resolution No. 32 of 2020 govern how such data is collected, stored, processed, and exchanged. In practice, this requires health data to be hosted and processed on approved infrastructure, subject to strong security controls, and restricting cross-border transfers unless permitted by the competent health authority or applicable adequacy/consent mechanisms.
Secondary uses of health data such as clinical research, algorithm improvement, or population health analytics should rely on consent or another lawful basis and must follow de-identification and access-control requirements where direct identifiers are not needed. Interoperability with UAE health information exchanges should be planned from the outset so that clinicians can use wearable data without requiring manual workarounds.
For patients, continuous data streams can potentially reduce hospitalizations, improve adherence, and shorten time to intervention. Real-world examples presented at WHX Dubai showed measurable improvements in chronic disease management using wearable-enabled care pathways.
For businesses, the priority is to build evidence that links device outputs to clinical outcomes, implement transparent patient notices that explain how data is used, and maintain governance that supports ongoing model updates without exceeding the device’s authorized indications.
UAE consumer protection rules must also be considered and apply to both medical and wellness wearables, and they cover providers, advertisers, and e-commerce channels. Providers must supply accurate labeling and Arabic-language consumer materials, truthful pricing and advertising, invoices with prescribed content, and reliable warranty and after-sales support. Where defects implicate safety, providers must notify authorities and consumers and execute recalls.
Cabinet Resolution No. 66 of 2023 translates these principles into operational requirements for sales, warranties, promotions, and marketplace responsibilities. For Regulated Wearables, these consumer duties apply alongside the medical product rules in Law 38/2024.
The outlook for wearables in the UAE and the broader Gulf region is positive. Law 38/2024 recognizes wearable Medical Equipment and provides pathways for innovative products, including fast-track marketing approval and conditional or emergency authorizations in defined circumstances. National databases, track-and-trace, and pharmacovigilance infrastructure reduce systemic risk and build trust. Consumer regulations provide clear rules for the protection of consumers and truthful advertising.
Practical steps for businesses seeking to enter the UAE wearables market include:
With sound preparation, the UAE offers a clear route to market for wearable health technology.
It was clear from WHX Dubai that wearable health technology, combined with AI-driven analytics, is becoming a core part of how healthcare will be delivered in the UAE and across the region. For healthcare professionals and organizations, the UAE offers an exciting landscape for wearables, the key is understanding and adhering to the regulatory requirements for speedy and safe advancement of emerging technology.