Book an appointment with us, or search the directory to find the right lawyer for you directly through the app.
Find out moreReal estate, construction, and hospitality are at the forefront of transformation across the Middle East – reshaping cities, driving investment, and demanding increasingly sophisticated legal frameworks.
In the June edition of Law Update, we take a closer look at the legal shifts influencing the sector – from Dubai’s new Real Estate Investment Funds Law and major reforms in Qatar, to Bahrain’s push toward digitalisation in property and timeshare regulation. We also explore practical issues around strata, zoning, joint ventures, and hotel management agreements that are critical to navigating today’s market.
As the landscape becomes more complex, understanding the legal dynamics behind these developments is key to making informed, strategic decisions.
2025 is set to be a game-changer for the MENA region, with legal and regulatory shifts from 2024 continuing to reshape its economic landscape. Saudi Arabia, the UAE, Egypt, Iraq, Qatar, and Bahrain are all implementing groundbreaking reforms in sustainable financing, investment laws, labor regulations, and dispute resolution. As the region positions itself for deeper global integration, businesses must adapt to a rapidly evolving legal environment.
Our Eyes on 2025 publication provides essential insights and practical guidance on the key legal updates shaping the year ahead—equipping you with the knowledge to stay ahead in this dynamic market.
The Ministry of Commerce and Industry (MoCI), through its Commercial Registration and Licensing Department, has released a regulatory guide governing the licensing and operation of cloud kitchens in the State of Qatar.
This initiative aligns with the country’s broader strategic objectives to (i) advance digital transformation, (ii) enhance food safety standards, and (iii) create a more efficient and business-friendly regulatory environment within the food services sector.
The guide introduces a structured and transparent framework that facilitates the establishment of cloud kitchen facilities while ensuring full compliance with applicable technical, health, and commercial regulatory requirements. It aims to streamline procedures, reduce bureaucratic inefficiencies, accelerate the licensing process, and enhance the overall competitiveness of the sector in support of national economic digitalisation efforts.
This regulatory framework targets a wide range of stakeholders, including (i) entrepreneurs and investors in the food and beverage industry, (ii) food delivery and logistics service providers, as well as (ii) existing restaurant operators seeking to expand their reach without establishing additional physical outlets.
Notably, cloud kitchen activities are fully open to foreign investment, presenting an attractive opportunity for international entrepreneurs and companies to enter Qatar’s rapidly evolving digital food sector.
Cloud Kitchens
Cloud kitchens, also known as ghost or virtual kitchens, are food production facilities that operate exclusively through digital ordering and delivery platforms, without offering dine-in services or direct on-site customer interaction. As an innovative and cost-efficient, cloud kitchens enable food service providers to significantly reduce overheads costs and expand market reach by leveraging digital technologies and third-party delivery networks.
These kitchens support a range of business and operational models, including but not limited to:
To operate a cloud kitchen in the State of Qatar, the investor must first establish a legal entity and obtain the necessary licenses and regulatory approvals from the MoCI and other relevant authorities.
The licensing process includes the following key steps:
Company Incorporation and Commercial Registration
The investor is required to incorporate a company with the MoCI and obtain a commercial registration. The registered business activities should be classified under:
Regulatory Approvals and Supporting Documents
As part of the incorporation process, other regulatory approvals are required from relevant authorities:
Trade License
Following the commercial registration, the investor must apply for a trade license, which necessitates securing a valid lease agreement for the business premises.
Establishment Card (also known as Computer Card)
The investor must secure an establishment card from the Ministry of Interior, which serves as a prerequisite for hiring employees under the business entity.
Tax Registration
Registration with the General Tax Authority is mandatory and must be completed within 60 days from the issuance of the commercial registration.
Cloud kitchens shall be subject to periodic inspections to ensure compliance with all applicable laws, regulations, and standards. In the event of any violations, the MoCI, along with other competent authorities including the Ministry of Municipality and the Ministry of Interior, shall have the authority to impose penalties.
Such penalties may include, but are not limited to, (i) temporary suspension of the license until the violation is remedied, (i) permanent revocation of the license in cases of repeated non-compliance or where there is an imminent risk to public health and safety, and (iii) monetary fines, or administrative closure of the facility.
Operators are required to report any health or technical emergencies that may impact food safety and to fully cooperate with regulatory authorities during inspections and investigations.
(I) Kitchen-as-a-Service: This model involves leasing out fully equipped kitchen spaces to independent food businesses, restaurants, or culinary entrepreneurs. The kitchen operator provides the infrastructure, basic utilities, and compliance support, while the tenants manage their own menus, staff, branding, and delivery operations. The tenants will be required to issue the licenses related to serving food.
This model is commonly adopted by startups or businesses entering a new market, as it offers a cost-effective solution without the need to invest in a full-scale restaurant or complete kitchen setup.
(ii) Aggregator Model: is a cloud kitchen facility that is owned and operated by a food delivery platform or aggregator, where multiple restaurant brands are hosted to operate delivery-only services. The aggregator provides not only the kitchen infrastructure but also logistics, technology integration, data insights, and marketing support.
How it works:
This model is particularly attractive to established restaurant brands seeking rapid market entry or geographic expansion, digital-first food brands that prefer to outsource operations entirely, and international chains aiming to enter new regions without setting up a physical presence. However, this Model presents significant risks and disadvantages, such as (i) lower profit margins due to revenue-sharing or commission structures, (ii) limited control over food quality and customer service, and (iii) a potential risk of brand dilution if the aggregator fails to maintain consistent standards.
The newly issued guidelines establish a comprehensive and structured regulatory framework for the licensing and operation of cloud kitchens in the State of Qatar. This initiative reflects the government’s commitment to fostering innovation and digital transformation, while maintaining strict adherence to food safety, public health, and operational standards.
By facilitating the reduction of overhead costs and promoting scalable, technology-driven operational models, the framework creates new opportunities for growth across the food services sector. Whether operating under segmented, unified multi-brand, or other cloud kitchen models, businesses now benefit from a clear and compliant pathway to market entry and sustainable expansion.
However, businesses operating in this sector must remain vigilant in ensuring full compliance with all regulatory requirements. Regular inspections, licensing obligations, and strict enforcement measures underscore the importance of maintaining operational integrity. Failure to comply may result in significant penalties, including fines, suspension, or revocation of the license.
How can we help?
For personalised guidance and to explore how we can assist you, please do not hesitate to contact the key contacts.
To learn more about our services and get the latest legal insights from across the Middle East and North Africa region, click on the link below.