The competition law had been on the books since 2023 but had gone more than thirty months without implementing rules: there was no procedure for filing a notification, no review timetable, no stated criteria. In that gap a good many transactions closed without anyone asking the question. The rules now exist, and anyone with a live sale or acquisition needs to add a step to the deal calendar.
What happened
Cabinet Decision No. 59 of 2026, issued on 20 April and in force since 30 July 2026, is the implementing regulation of Federal Decree-Law No. 36 of 2023 on competition. It fills a gap that lasted more than thirty months. The regulation sets out when a concentration — the purchase of a business, a merger, the acquisition of control — must be notified to the Ministry of Economy before completion, how the notification is filed, and the time the authority has to review it.
What changes in practice
The test for whether a filing is required used to rest on market share alone. There are now two thresholds and crossing either one is enough: combined annual turnover of the parties in the relevant UAE market exceeding AED 300 million in the preceding financial year, roughly USD 82 million, or a combined market share exceeding 40% of the relevant market. On timing, the Ministry has ten working days to confirm that the notification is complete, extendable by a further ten, within an overall maximum of thirty days. The regulation also broadens the factors used to assess dominance: not just market share, but technological superiority, financial resources, the robustness of the business model, geographic concentration and pricing conduct.
Who it applies to
Anyone buying or selling a business with activity in the UAE, and anyone acquiring control of a UAE company. The turnover threshold is high and takes most transactions between smaller companies out of scope: AED 300 million of turnover in the relevant market is a scale few owner-managed structures reach. The market share threshold is a different matter, because in a narrowly defined market — a services niche, a specific product — 40% is reached at far lower volumes.
The exposure
The obligation is to notify in advance: the filing goes in before closing, not after. A transaction completed without a required notification remains exposed to intervention by the authority after the fact, which is the worst moment to find out. The delicate point is not the turnover threshold, which can be counted, but the definition of the relevant market on which the share calculation depends: businesses operating in a niche tend to define their market broadly and conclude that 40% is far off, while the authority may define it more narrowly.
What to do now
Anyone with a live sale or acquisition should run two calculations before signing: the parties' combined turnover in the relevant UAE market in the last financial year, and their combined share of that same market. If either threshold is crossed, the notification belongs in the deal calendar together with the review period, which can run to thirty days for the completeness stage alone. Where there is doubt about how the relevant market is defined, resolve it first, because that is the variable that decides the answer.
Sources
Published 1 September 2026 on the basis of public sources and official United Arab Emirates instruments. This is not legal or tax advice. Verify your position with a qualified professional before acting.