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The New Rules of Technology
This edition of Law Update looks at how technology is changing the legal questions businesses are facing across the region. From AI and deepfakes to cyber incidents, cloud services, data protection and digital assets, our lawyers examine where the risks are emerging and how regulators are responding.
The edition also brings together recent legislative developments and significant court decisions from across the UAE and Saudi Arabia, with a closer look at what they mean in practice for businesses operating in the region.
Dubai has announced two tourism initiatives aimed at encouraging repeat visits and simplifying the visitor journey: the Dubai Access Club and tourist visa applications through the official Visit Dubai platform. For tourism businesses and investors, the developments point to potential opportunities in visitor engagement, commercial partnerships and digital travel services. The immediate legal and commercial implications will depend on the implementation details.
Announced on 1 November 2026 by His Highness Sheikh Hamdan bin Mohammed bin Rashid Al Maktoum, Crown Prince of Dubai and Chairman of The Executive Council of Dubai, the initiatives support the Dubai Economic Agenda, D33, and its ambition to position Dubai among the world’s top three destinations for business and leisure.
Existing visa application channels, including government platforms, authorised travel agencies and airlines, will remain available. The announcement therefore signals an additional digital route for visitors, rather than a replacement for existing channels.
The practical implications will depend on how the initiatives are implemented, particularly the Dubai Access Club’s participation model and the integration of visa applications into Visit Dubai. Businesses should consider the following areas.
His Highness Sheikh Hamdan highlighted tourism’s role in Dubai’s economy and the importance of technology, innovation and partnerships between the public and private sectors in attracting investment and creating opportunities. The initiatives signal continued government support for the visitor economy, with the Dubai Access Club placing particular emphasis on repeat visitors.
For investors in hotels, serviced accommodation, attractions, leisure businesses and travel technology, the relevant question is how these initiatives could affect an asset’s demand profile, distribution costs and customer relationships. The announcements may support an investment thesis, but do not, by themselves, establish higher occupancy, visitor spending or investment returns.
In acquisitions and joint ventures, due diligence should examine any participation in tourism programmes led by government, including:
Where an investment involves government participation, the parties should establish whether a framework for partnerships between the public and private sectors or another procurement or contracting regime applies. Participation in a tourism initiative led by government should not, without further analysis, be treated as a formal public and private sector partnership. The investment structure and the asset’s location, including whether it is onshore or in a free zone, will also inform the regulatory assessment.
The announcement leaves important implementation questions open. GDRFA Dubai has indicated that further details of the visa service will follow, while businesses considering potential participation in the Dubai Access Club will need clarity on:
At this stage, businesses can usefully assess their commercial objectives and readiness to participate, while reserving contractual commitments until the operating model and relevant terms are clear.
Al Tamimi’s Corporate and Hospitality & Leisure teams advise hotel owners and operators, developers, investors, tourism businesses and entities connected with government across the UAE and the wider region.
We can assist businesses in assessing potential participation in tourism programmes, negotiating partnership arrangements and agreements with businesses providing programme benefits, and addressing related licensing, data protection and customer requirements. We also advise on hospitality and tourism investments, acquisitions and joint ventures, as well as the development, financing and operation of hotels, resorts and leisure projects.
For further information, please contact Fady Ghanem (F.Ghanem@tamimi.com), Ian Arnott (I.Arnott@tamimi.com) Sabeeha Moolla (S.Moolla@tamimi.com).
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