Law note · United Arab Emirates

Federal Decree-Law on the Protection of Personal Data, enforcement and supervision

cite Federal Decree-Law No. 45 of 2021, Arts. 25-26 stage IN FORCE in force since 2022-01-02 kind Enforcement supervision binds public and private bodies reviewed 2026-08-29

What it requires

  • An app processing the personal data of an individual in the onshore UAE must be prepared to answer to the Bureau's supervisory powers; administrative penalty amounts are set by a separate Council of Ministers decision rather than the Decree-Law itself.

When LexLint raises it

  • crawls_web
  • trains_models
  • generates_content
  • deploys_chatbot
  • automated_outreach
  • high_risk_decisions
  • processes_voice
  • processes_biometrics

What we found

The UAE Data Office ("the Bureau", established by Federal Decree-Law No. 44 of 2021) is the federal supervisory authority. A grievance against a Bureau decision goes to the Bureau itself first under Art. 25. Administrative penalty amounts are not set in the Decree-Law itself: Art. 26 requires a separate Council of Ministers decision, on the General Director's recommendation, to list violations and set administrative penalties.

No provision creating a private right of action for a Data Subject to sue a Controller directly was found in the articles read; this is recorded as not established rather than a confirmed absence, since the full Act was not read in its entirety.

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