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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.
This article is in furtherance to our previously published Article UAE Introduces Mandatory Advertiser Permit for Content Creators.
The Advertiser Permit was introduced by the UAE Media Council under Decision No. (3) of 2025 and Federal Decree-Law No. (55) of 2023 on Media Regulation, and requires citizens, residents and visitors alike to hold a permit before publishing advertising content on social media in the UAE.
Issuance of the permit is currently free of charge for the first three years, after which renewal is subject to a fee of AED 1,000 per year. A Citizen or Resident Advertiser Permit is valid for one year and is renewable, while a Visiting Advertiser Permit is valid for three months, extendable once for a further three months (a maximum of six months in total), with issuance and renewal each subject to a fee of AED 500. A permit that is not renewed expires 30 days after the end of its validity period.
This article examines a question that is critical for businesses representing influencers, content creators, and marketing personnel in the UAE. Who is required and eligible to hold the advertiser permit?
The Advertiser Permit is issued to sole establishments and equivalent single-individual-shareholder entities, rather than to companies or multi-shareholder structures. The National Media Authority has confirmed that the permit is only available where the underlying trade licence is held by a single individual in their personal capacity, that is, through a sole establishment. It is not available where the trade licence is held by a corporate entity or by more than one individual.
An individual does not always need to hold a trade licence in their own name to obtain an Advertiser Permit. The National Media Authority recognises two distinct routes to the permit:
In other words, eligibility relies on one of these two routes being satisfied, either the applicant personally holds the requisite sole-establishment-style trade or freelancer licence, or an approved agency contracts with the individual.
Holding a qualifying entity type is not, by itself, sufficient. The National Media Authority has also specified which commercial activities must be recorded on the licence for each Economic Development Department. The approved combinations are set out below:
| Emirate / Authority | Licence Type | Approved Commercial Activity |
|---|---|---|
| Dubai (Department of Economy and Tourism) | Sole Establishment / Professional Trader Licence | Blogging; Advertising; Marketing Management; Content Creator |
| Dubai (Department of Economy and Tourism) | Sole Establishment / Professional Licence | Marketing Management; Online Advertising Services; Online News Services |
| Abu Dhabi (Department of Economic Development) | Sole Establishment / Freelance | Advertising Services via Websites; Marketing Operations Management; Social Media Account Management |
| Abu Dhabi (Department of Economic Development) | Single Person Company / Abu Dhabi Trader | Social Media Marketing Services |
| Abu Dhabi (Department of Economic Development) | Single Person LLC | E-commerce via Social Media |
| Sharjah (Economic Development Department) | Sole Establishment | Advertising Services via Websites |
| Sharjah (Economic Development Department) | Limited Liability Company | E-commerce through Social Media |
| Sharjah (Economic Development Department) | Single Person LLC | Marketing Operations Management; Social Media Account Management |
| Ajman (Department of Economic Development) | Sole Establishment / Single Person LLC | Marketing Operations Management; Social Media Account Management; Advertising Services via Websites |
| Umm Al Quwain (Department of Economic Development) | Sole Establishment | Advertising Services via Websites |
| Umm Al Quwain (Department of Economic Development) | Limited Liability Company | Marketing Operations Management |
| Umm Al Quwain (Department of Economic Development) | Single Person LLC | Social Media Account Management |
| Ras Al Khaimah (Department of Economic Development) | Sole Establishment / Ghadan Licence (citizens) / Sole Establishment / Forsa Licence (residents) / Single Person LLC | Advertising Services via Websites |
| Fujairah (Fujairah Municipality) | Sole Establishment / Single Person Company / Limited Liability Company | Advertising Services via Websites |
| Free Zones | Any UAE free zone commercial licence, provided it is issued under a sole establishment | Relevant electronic media activity, submitted to the National Media Authority to complete the Advertiser Permit application |
In every case, a licence held by more than one shareholder, or by a corporate shareholder, will not qualify, irrespective of the Emirate or the specific entity type.
Position for Companies
Where a company represents influencers, content creators, and marketing personnel, the company cannot apply for the Advertiser Permit on behalf of the individuals, because it is not eligible for it and the individuals will themselves need to apply for the advertising permit depending on whether they fall in the visitor or resident category. This applies equally to group entities, holding companies, and operating companies with multiple or corporate shareholders, even where those companies are actively involved in producing or commissioning advertising content for social media.
This does not mean that companies fall outside the regulatory framework entirely. Separately from the Advertiser Permit, a company publishing advertising content on social media may instead require a media licence from the UAE Media Council, if its trade licence includes media-related commercial activities. Whether this is triggered depends on the specific activities recorded on that company’s trade licence and should be checked on a case-by-case basis.
For groups structured with multiple or corporate shareholders, in other words, the standard ownership models used by most established businesses, the practical route to lawfully publishing advertising content on social media in the UAE is not to obtain an Advertiser Permit in the company’s own name, since this is not legally possible, but rather to engage an individual permit holder, or to confirm whether a separate media licence applies to the company’s own trade licence.
Practical Implications
Businesses that rely on influencers or content creators to publish advertising content on social media in the UAE should keep the following in mind:
The Advertiser Permit regime draws a clear line between individuals and companies. Only a natural person, operating through a sole establishment or an equivalent single-individual-shareholder licence, can hold the permit.
Companies, regardless of their ownership structure or the Emirate in which they are established, cannot apply for it directly.
Businesses that advertise on social media in the UAE, whether directly or through influencers and content creators, are encouraged to review their current arrangements against these requirements and to consider whether a separate media licence applies to their own operations.