Book an appointment with us, or search the directory to find the right lawyer for you directly through the app.
Find out more
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.
On 14 June 2026 the United Arab Emirates announced the establishment of the new Artificial Intelligence and Data Authority, a federal body intended to unify oversight of artificial intelligence, data governance and digital government initiatives under a single national framework.
The establishment of the new Authority is particularly significant as it consolidates under a single federal mandate the functions previously carried out by three separate entities: the Office of Artificial Intelligence, Digital Economy and Remote Work Applications, the Digital Government Sector at the Telecommunications and Digital Government Regulatory Authority (TDRA), and the UAE Data Office. This centralisation reflects a clear shift toward a more coordinated and unified approach to AI, digital governance and data regulation in the UAE. The announcement demonstrates that the UAE is entering a more mature phase of governance around data, privacy and artificial intelligence.
The Authority’s role will include shaping national policy, legislation and strategy relating to artificial intelligence, data and digital government, while prioritising alignment between federal and local digital initiatives. A key aspect of its function will be the development of a unified digital government framework, including the increased use of AI-driven systems and data-led decision making across government services.
The Authority will also oversee the management and integration of government data platforms. In parallel, it will be responsible for establishing standards and guidance relating to the platforms as well as monitoring compliance across federal entities and supporting the development of national technical capabilities.
Importantly, the Authority’s remit reflects the UAE’s wider economic and strategic ambitions in the AI sector. PwC has previously estimated that AI could contribute approximately US$96 billion to the UAE economy by 2030, and the objectives of Dubai’s Economic Agenda (D33), which targets an annual contribution of AED 100 billion from digital transformation projects to Dubai’s economy underlining the increasing importance of a coordinated regulatory and governance framework. The creation of a single authority with oversight across AI, data and digital government therefore signals not only a regulatory development, but also a broader economic and policy commitment to positioning the UAE as a leading global hub for digital innovation and emerging technologies.
The practical significance of the Authority will, however, depend on the scope of its formal mandate, including whether it will have rulemaking, supervisory or enforcement powers, and how it will coordinate with existing federal, emirate-level, sectoral and free-zone regulators.
The UAE has already taken significant strategic steps with regards to AI through initiatives such as the UAE National Strategy for Artificial Intelligence 2031 and various sector-specific AI guidance documents. However, there is currently no standalone federal AI law regulating the development, deployment or use of AI systems. In practice, the current regulatory landscape for AI in the UAE is embedded within existing legislative and regulatory frameworks, including, among others, the Cybercrime Law, the Penal Code, the Civil Transactions Law and existing personal data protection regimes. This contrasts with developments in other jurisdictions, most notably the European Union, which has adopted a comprehensive risk-based legislative framework for AI through the EU AI Act and Saudi Arabia which has established the Saudi Data and Artificial Intelligence Authority which has played a central role in shaping the national approach to data and AI.
Globally, it remains that governments and regulators are still navigating how best to govern artificial intelligence and data use, particularly as the technology continues to evolve rapidly. Against that backdrop, this development signals the UAE’s intention to take meaningful steps toward a more structured framework for AI governance, accountability and data regulation, although the form of that framework remains to be seen.
In practice, the UAE could move in a number of directions. It may adopt a comprehensive AI law, issue sector-specific AI regulations, publish regulator-led guidance, introduce voluntary or mandatory governance standards, or develop a hybrid model combining elements of each all within the remit of the new Authority’s functions.
The principal federal legislation governing personal data protection in the UAE remains Federal Decree-Law No. 45 of 2021 Concerning the Protection of Personal Data (“UAE PDPL”). Although the UAE PDPL came into force on 2 January 2022, at the time of writing, Executive Regulations have not yet been issued. In practice, this has created a degree of uncertainty regarding implementation, enforcement mechanisms, regulatory expectations and practical compliance requirements. The establishment of the new AI and Data Authority suggests that the UAE is now moving toward a more consolidated and operational regulatory framework for data governance, although it remains to be seen whether, and when, this will be followed by the long-awaited Executive Regulations.
Given the multi-layered nature of the UAE regulatory environment, including the existing data protection regimes and enforcement frameworks within the Dubai International Financial Centre and Abu Dhabi Global Market, the move toward a more unified federal approach to AI and data governance will be a development to monitor as the broader regulatory framework continues to evolve.
The Authority’s focus on government data management and data sharing across federal entities may also have broader implications for public sector procurement, technology contracting and digital infrastructure projects. As government entities continue to adopt more integrated digital systems and AI-enabled services, there may be an increased emphasis on contractual frameworks dealing with data safeguards and enhanced cybersecurity. While the practical approach remains uncertain at this stage, the announcements suggest a move toward more coordinated government data practices.
The establishment of the Artificial Intelligence and Data Authority should be viewed as more than an administrative restructuring exercise. It is a strong indication that the UAE intends to accelerate the development of a comprehensive digital governance ecosystem.
It also reflects a broader policy trajectory in which data, AI and digital government are becoming increasingly interconnected. Data protection compliance, AI governance, cybersecurity, cloud adoption, digital identity, public-sector digitalisation and cross-border data flows are no longer separate issues. They are part of the same regulatory and commercial conversation about how the UAE positions itself as a trusted, competitive and innovation-friendly digital economy.
The direction of travel is clear, even if the detail remains uncertain. The UAE is continuing to align its digital economy ambitions with a more mature governance framework for data and AI. For businesses operating in the UAE and particularly those processing personal data, deploying AI-enabled systems or procuring AI tools from third-party vendors, this is an appropriate time to reassess data governance frameworks, review AI usage and internal AI governance policies, review vendor and third-party arrangements on digital services and monitor developments relating to the new authority’s mandates, guidance, enforcement priorities and interaction with existing regulators, and prepare for a more active and structured regulatory environment in the near future.