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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.
Federal Law No. 3 OF 2022 Regulating Commercial Agencies (the “Commercial Agencies Law”), which came into effect on 15th June 2023 (the “Effective Date”), ushered in a period of change surrounding the termination and de-registration of registered commercial agencies in the UAE.
Pursuant to Article 9(1)(a) and (b) of the Commercial Agencies Law, a commercial agency, that has been registered with the UAE Ministry of Economy, will terminate (a) upon expiry and non-renewal of the term of the commercial agency agreement or (b) if either party elects to terminate the commercial agency agreement based on agreed terms of the underlying agency agreement.
However, the enforceability of Article 9(1)(a) and (b) of the Commercial Agencies Law, regarding the expiry/non-renewal and unilateral termination of commercial agency agreements, was expressly suspended, under Article 30 of the same law, for a period of two (2) years (the “Suspension Period”) in respect of registered commercial agencies that meet certain relevant criteria (each an “Affected Agency”).
Since the Effective Date fell on 15th June 2023, the Suspension Period expired on 15th June 2025.
In practical terms and as from 15th June 2025, parties under an Affected Agency will be able to freely deal with one another, under the provisions of Article 9(1)(a) and (b) of the Commercial Agencies Law, with the effect that each such Affected Agency may be terminated based on expiry/non-renewal or unilateral termination in accordance with the terms of the underlying agency agreement.
Given the expiry of the Suspension Period, we encourage all clients that are involved in registered commercial agencies in the UAE to evaluate their positions, promptly, in order to: (a) verify whether their agency can be classified as an Affected Agency and (b) assess their relative positions under such agencies with particular regard to Article 9(1)(a) and (b) of the Commercial Agencies Law.
Why This Matters
How can we help?
Our team of experienced commercial and disputes lawyers are ready to assist you in:
• Assessing Registered Agencies: We can assist in assessing whether any particular registered agency can be classified as an Affected Agency.
• Strategic Advisory: We can provide strategic advice and tactical guidance on the impact of the expiry of the Suspension Period on: (a) any Affected Agency and (b) the relative positions of the parties, in respect to each other, under such an agency.
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.