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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.
The Minister of Commerce and Industry has issued Decision No. 25 of 2026, establishing the conditions and limitations governing the conduct of commercial activities through websites where such activities do not require a physical storefront (“Decision”).
Under the Decision, a license to conduct e-commerce activities may be obtained, provided that the prescribed requirements are satisfied.
The specific commercial activities permitted to be carried out through e-commerce will be determined based on a list proposed by the competent department of the Ministry of Commerce and Industry (“MoCI”), subject to the approval of the relevant authorities responsible for regulating the nature of such activities and the Minister’s final approval. The approved list will be published on the MoCI’s official website.
For the purposes of the Decision, a “website” is defined broadly as any system or technology that relies on technological tools to facilitate communications or transactions between parties, including electronic means and social media platforms.
In this context, “e-commerce” refers to the sale and purchase of goods or the provision of services through such websites, and “commercial activity” means any activity that may be conducted through websites in accordance with an e-commerce license.
The commercial activities may not be conducted online unless an e-commerce license is first obtained from the competent department of the MoCI and the applicable fees are duly paid.
To obtain an e-commerce license, applicants must comply with the following conditions:
Where a business intends to conduct commercial activities through multiple websites, a separate license must be obtained for each website. In addition, the MoCI must grant approval to any changes to the e-commerce license.
The Decision emphasises that consumer protection requirements apply equally to online commercial activities. Once approval is granted, license holders must:
The Decision does not apply to transactions conducted through websites involving the sale of products or services for personal use, provided that such transactions do not involve commercial quantities.
The Decision appears to apply primarily to entities registered with the MoCI, as it requires applicants to hold a commercial registration issued by the MoCI. Accordingly, businesses established under alternative regulatory regimes (such as the Qatar Financial Centre or other free zones) may fall outside the direct scope of the Decision; however, this position should be assessed on a case-by-case basis depending on the nature of the activities conducted and the manner in which they are offered within the State of Qatar.
In light of the above, businesses operating through digital channels are encouraged to undertake a careful review of their current structures, licensing position, and operational model to determine the extent of their exposure under the Decision.
Al Tamimi & Company is well placed to assist with assessing the applicability of the Decision, advising on the appropriate licensing strategy, liaising with the relevant authorities, and supporting clients in obtaining the required approvals and ensuring ongoing compliance with the applicable regulatory framework.
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