Regulation, approvals and advertising compliance

This chapter sets out the rules that govern who may perform cosmetic procedures, how clinics may advertise them, and how patient data may be used, emirate by emirate and at federal level. The UAE has no single cosmetic advertising regime: a Dubai clinic works under DHA standards that ban words such as "the best" and "100%", a Sharjah clinic needs prior MOHAP approval before the Sharjah Health Authority will license an advertisement, and every clinic's creators and paid content sit under a 2025 federal media law with fines of up to AED 1,000,000 for serious breaches.

In brief

DHA's non-surgical cosmetic standard v2 took effect on 22 August 2022 and was updated to v2.1 by circular on 24 December 2024; only licensed physicians may inject toxin and fillers, and both are banned under 18 (DHA).

DHA circulars on v2.1 restrict invasive skin-opening procedures for tightening, lifting or dissolving fat to plastic surgeons, and allow PRP on the face and hair only (DHA, 2025; Dubai Health Authority, 2025).

DoH Abu Dhabi's own non-surgical standard, effective January 2025, limits GPs to the face, bars aestheticians from injecting and excludes under-18s except laser hair removal from 16 (Department of Health Abu Dhabi; DoH Abu Dhabi).

MOHAP's social media advertising licence costs AED 100 to apply plus AED 1,000 a month or AED 3,000 a year, per language, platform and content, under Cabinet Resolution 82 of 2025.

Resolution 82 of 2025 sets MOHAP fines of AED 8,000 per language for an unlicensed ad that also breaches the rules, and AED 4,000 per ad for promoting a facility through influencers without a licence (UAE Legislation portal).

Sharjah clinics need two approvals: MOHAP first, then a Sharjah Health Authority medical advertisement licence processed in 8 working days.

DoH Abu Dhabi requires each facility to nominate two trained representatives who log advertising materials for approval on the Health Media and Advertising System (Circular 26/2023) (DoH Abu Dhabi).

The UAE Media Council's Advertiser Permit became mandatory from 1 February 2026 for anyone creating advertising content, paid or unpaid, with personal accounts promoting their own business exempt (Gulf News).

Federal Law No. 2 of 2019 keeps health data in the UAE unless an exemption applies, fines localisation breaches AED 500,000 to 700,000, and bars non-health use of patient information without written consent.

Who regulates what

Local and federal authorities share responsibility for licensing and advertising. Federal media rules also apply. Clinics in Dubai Healthcare City fall under DHCR, not DHA, and clinics in Ajman, Umm Al Quwain, Fujairah and Ras Al Khaimah under MOHAP licensing and fees.

Older sources describe a centralised model in which MOHAP approved each healthcare advertisement, including those of DHA and Abu Dhabi facilities. That model predates the current DHA and DoH systems (Al Tamimi & Company; Gulf News, 2018).

Dubai: DHA clinical standards

Non-surgical cosmetic procedures: versions

The DHA Standards for Non-Surgical Cosmetic Procedures v2 (DHA/HRS/HPSD/ST-05) were issued on 22 June 2022, took effect on 22 August 2022 and carry a revision date of 22 June 2027; DHA updated them to v2.1 by circular CIR-2024-00000250 on 24 December 2024 (DHA). Reminders followed on 12 March and 4 June 2025 (DHA). The ONS draft recorded v2.1 as issued on 18 December 2024 and effective on 18 February 2025, which conflicts with the circular date; both are shown (Dubai Health Authority). A January 2026 law firm summary still describes v2 as governing (LY Lawyers). The full v2.1 text was not available to the research team, so the injector, supervision and laser rules below are cited as "v2 (2022), since updated to v2.1" (DHA).

Provisions relevant to marketing

The draft's verified provisions are retained, with their marketing implications.

Who may do what

Hair transplant, liposuction and day surgery

DHA's Standards for Hair Transplant Services (ST-02, Issue 3) took effect on 11 September 2023 (Dubai Health Authority). Plastic surgeons may be licensed to perform hair transplants; dermatologists, general surgeons and GPs need ABHRS or FISHRS certification, two or more years of recent experience and a DHA assessment, and a physician may perform one procedure at a time (DHA). The service may be offered in hospitals, day surgical centres and outpatient facilities with a procedure room after DHA permission, and its advertising must follow DHA medical advertisement standards (DHA).

DHA's Standards for Liposuction Services (DHA/HRS/HPSD/ST-07, Issue 1, issued 4 July 2019) allow only DHA-licensed specialist or consultant plastic surgeons to perform liposuction, and only in a general hospital, specialty hospital or day surgical centre; the revision date of 4 July 2024 has passed and no newer version was found (DHA). The maximum aspirate is 5,000 ml per procedure, or 2,000 ml when liposuction is combined with other procedures, and the procedure is contraindicated at a BMI of 40 or more (Caucasian) or 37.5 or more (Asian) (DHA).

DHA's Standards for Standalone Day Surgery Centres v4 took effect on 1 November 2023, with plastic surgery a permitted speciality (DHA). Class CM deep sedation is limited to 2 hours and Class C general anaesthesia to 3 hours, general anaesthesia may not start after 5pm, and there is no overnight stay (DHA). Centres must be accredited within two years of licensure (DHA).

Facility licence fees in Dubai are reported inconsistently. A vendor guide citing DHA gives a new facility licence fee of AED 1,000 for most clinics and AED 2,000 for day surgery, and annual activation of AED 5,000 to 40,000 (Pabau). Another directory reports one-year activation fees of AED 2,500 to 20,000 and inspection fees of AED 1,000 to 3,000, which conflicts with the first (Zavis Intelligence).

For marketersEvery service page and ad should name a practitioner whose licence and privileges cover that procedure in that branch. A campaign for body PRP, nurse-led injectables or invasive fat dissolving by a non-surgeon would advertise something the DHA rules do not permit (DHA; DHA, 2025).

Dubai: DHA advertising rules

The social media standard

DHA's Standards for Medical Advertisement Content on Social Media v1.1 (DHA/HRS/HPSD/ST-21) were issued on 3 August 2022 and took effect on 3 October 2022 (DHA). A 2026 DHA circular links to the standard (Dubai Health Authority). The clauses most relevant to cosmetic clinics are summarised below.

DHA has tightened enforcement since 2025 (Dubai Health Authority; The National, 2026). Circular CIR-2025-00000149 of 23 August 2025, "Regulations of Health Advertisement Content on Social Media", went to all DHA facilities; its attachment could not be read. Gulf News reported in September 2026 that DHA rules require doctors practising in Dubai and abroad to keep a separate Dubai account and require written approval to use DHA or government logos (Gulf News). The National reported that a DHA circular of August 2026 warned that non-compliance "could result in disciplinary action" and barred edited before-and-after images; no fine amounts were published (The National).

A 2019 law firm summary adds that testimonial consent should be limited to the requested subject and period, and that disclosing private patient information without permission could be a criminal offence (Clyde & Co via Mondaq).

Dubai Healthcare City and cosmetic products

Clinics in Dubai Healthcare City follow the DHCR Advertisement Policy of 13 December 2016: all medical ads need DHCR approval, outdoor, printed and electronic ads also need MOHAP approval, approval is valid for six months, and the policy bans superlatives, refund offers, ads aimed at under-18s and patient images without written consent. Cosmetic products, as distinct from clinic services, need a Dubai Municipality advertising permit through the Montaji system, reported at AED 100 a month (up to AED 1,200 a year) plus an AED 20 fee, valid 1 to 12 months, with medical benefit claims rejected (Artixio).

No public data. No DHA fee, validity period or Sheryan service page for medical advertisement approval was found; a vendor guide cites DHA manual section 19.1.7 as requiring prior approval, unconfirmed from a primary source (Pabau). A future edition should obtain the DHA service card and the attachment to circular CIR-2025-00000149.

Abu Dhabi: DoH

Non-surgical cosmetic standard

DoH's "Standard for Healthcare Professionals Performing Non-Surgical Cosmetic Procedures" (DOH/ST/HCWS/HCPP-Non-SCP/V1/2024) took effect in January 2025 and is due for revision in January 2027 (Department of Health Abu Dhabi). Toxin and fillers are permitted for dermatologists, plastic surgeons, oculoplastic surgeons and specialised physicians; GPs are limited to the face; aestheticians may not inject (DoH Abu Dhabi, 2025). Aestheticians may perform laser only under a licensed, privileged specialist or consultant physician, and nurses are not listed as a licensed category (DoH Abu Dhabi). Procedures are not permitted under 18, except laser hair removal from 16 with dermatologist referral, or in pregnancy (DoH Abu Dhabi). Practitioners need facility privileges plus DoH permission through TAMM, written consent before each procedure, and "honest and transparent" marketing; there is no before-and-after rule (DoH Abu Dhabi). A trade press claim of a 20-procedure logbook requirement was not found in the primary text (Zavis Intelligence).

Advertising approval

DoH Circular 26/2023 of 23 February 2023 requires every licensed facility to nominate two representatives for training on the Health Media and Advertising System, who then log advertising materials on DoH systems for approval; no fee is stated (DoH Abu Dhabi). TAMM lists the e-services "Log a Health Advertisement" and "Re-log a Health Advertisement", with no fee shown (DoH Abu Dhabi).

No public data. No DoH advertising fee, validity period, document list or processing time, and no DoH social media rules for professionals, were found. A future edition should read the TAMM service cards and the Abu Dhabi Healthcare Guidelines for Health Media and Advertising.

Data security and enforcement

Abu Dhabi's ADHICS V2 cyber security standard took effect in August 2024; it covers facilities and health web and app providers and bars storing healthcare data on personally owned devices (DoH Abu Dhabi). In 2025 DoH carried out 4,540 licensing audit rounds and 3,485 compliance audit rounds (up from 2,401 the previous year), issued 223 corrective actions and closed 7 healthcare facilities, none described as cosmetic-specific (Abu Dhabi Media Office).

MOHAP: federal rules and the northern emirates

Cabinet Resolution 82 of 2025

Cabinet Resolution No. 82 of 2025 on MOHAP fees and fines was issued on 16 June 2025, published in Official Gazette No. 802 on 26 June 2025 and took effect on 22 December 2025, 180 days after publication; the UAE legislation portal lists it as active. It defines a health advertisement as content promoting a facility, service, information or practitioner, excluding health education (UAE Legislation portal, 2025). MOHAP's monitoring page, accessed in October 2026, still shows the older 2007 schedule, so the page lags the resolution.

A social media advertisement licence costs AED 100 to apply plus AED 1,000 a month or AED 3,000 a year, per language, platform and content, and website advertisements cost the same (UAE Legislation portal, 2025). Printed, audio or audiovisual advertisements cost AED 11,000 a year for a specialty clinic, AED 9,000 for a general clinic and AED 12,000 for a hospital, per language and product (UAE Legislation portal).

An annual MOHAP licence for one social media ad costs AED 3,000, against AED 11,000 for a specialty clinic's printed or broadcast ad

Annual licence fee by advertisement type, AED, excluding the AED 100 application fee, UAE federal (MOHAP), Cabinet Resolution 82 of 2025; charged per language and per platform, content or product

View chart data

Label	Annual fee (AED)
Social media (per language, platform, content)	3000
Website (per language, content)	3000
Print/audio/AV: general clinic	9000
Print/audio/AV: specialty clinic or centre	11000
Print/audio/AV: hospital	12000

Article 4 of the resolution sets fines from AED 200 for a missing licence number to AED 8,000 per language for an unlicensed advertisement that also breaches the conditions; promoting a facility through influencers without a licence costs AED 4,000 per advertisement (UAE Legislation portal, 2025).

MOHAP fines run from AED 200 for a wrong licence number to AED 8,000 per language for an unlicensed, non-compliant ad

Administrative fine per violation, AED, UAE federal (MOHAP), Cabinet Resolution 82 of 2025, Article 4

View chart data

Label	Fine (AED)
Unlicensed ad that also breaches conditions (per language)	8000
Compliant but unlicensed ad	6000
Breaching licence conditions	4000
Promotion via others or influencers without licence (per ad)	4000
Ad past its validity	2000
Missing or incorrect licence number (per ad)	200

MOHAP's monitoring page, accessed in October 2026, still lists the older schedule of AED 4,000 per language and product for an unlicensed health advertisement, AED 8,000 for one breaching Cabinet Resolution 7 of 2007 and AED 2,000 for altering a licensed advertisement. Advertisers get a warning and up to 3 working days to license or remove an ad, and the fine doubles if removal takes more than 5 working days; any ad reaching the UAE or carrying UAE contact details is in scope (MOHAP).

Licence services and conditions

The social media licence takes 1 to 3 working days (MOHAP). Each institution may have one account; opening more than one freezes all of them, and the licence does not exempt the holder from other authorities' requirements (MOHAP). Directory advertisements cost AED 100 plus AED 1,000, and the design must show licence start and end dates (MOHAP).

The underlying regulation is cited as Cabinet Resolution No. 7 of 2007 by Al Tamimi (2013), which says it bans ads targeting minors, guaranteeing effectiveness or claiming no side effects, and as Resolution No. 4 of 2007 by the National Media Council guide; the sources conflict.

MOHAP facility licence fees under the resolution are AED 6,000 a year for a specialised clinic and AED 20,000 for a one-day surgery centre, plus application, approval and blueprint fees (UAE Legislation portal, 2025).

Sharjah: two approvals

The Sharjah Health Authority's "Request for a medical advertisement license" is open to SHA-licensed facilities and practitioners, requires prior MOHAP approval plus the advertisement materials, and takes 8 working days; fees depend on advertisement type and format, with no amount stated, and any change needs a new application. SHA's facility licence takes 8 working days and is valid for one year (Sharjah Health Authority). Sharjah Healthcare City, a free zone, lists its own "License Application for Health Advertisement" covering channels, websites, SMS and social media.

No public data. No SHA advertising fee amount, no SHA cosmetic or aesthetic clinic standard, and no MOHAP or Emirates Health Services cosmetic standard for the northern emirates was found. A future edition should obtain the SHA fee schedule and ask MOHAP whether a non-surgical cosmetic standard applies to facilities it licenses.

Federal media law and the Advertiser Permit

The Federal Media Law (Decree-Law No. 55 of 2023) took effect on 29 May 2025 with 20 content standards, none specific to health claims (Gulf News). Its rules, as reported, set fines of up to AED 1m, doubling to AED 2m for repeats, and ban unauthorised content in regulated sectors, naming health advertisements (Khaleej Times). Gulf News (24 January 2026) reported fines of up to AED 1,000,000 for serious breaches such as religious offences or inciting violence, AED 5,000 to 10,000 for disseminating false information and AED 10,000 to 40,000 for operating without a licence (Gulf News). A law firm reading of Cabinet Resolution No. 42 of 2025 gives AED 10,000, which can be doubled, for an ad breaching advertising conditions and AED 20,000 to 50,000 for social media advertising without a licence (Bird & Bird).

Reported media-law fines for advertising breaches range from AED 5,000 to AED 150,000, before the AED 1m ceiling for serious breaches

Reported fine range per violation, AED, UAE federal media law and Cabinet Resolution 42 of 2025, as reported 2025 to 2026; the AED 1,000,000 ceiling (AED 2,000,000 for repeats) is not drawn

View chart data

Label	Fine range low (AED)	Fine range high (AED)
Disseminating false information (first, repeat)	5000	10000
Operating without a licence (first, repeat)	10000	40000
Social media advertising without a licence	20000	50000
Publishing false or harmful content	5000	150000

Advertiser Permit

The UAE Media Council's Advertiser Permit was launched on 30 July 2025 and became mandatory from 1 February 2026 for anyone creating advertising content, paid or unpaid; personal accounts promoting their own business are exempt, and organisations must check that the advertisers they use hold permits (Khaleej Times; Gulf News). It is free for citizens and residents for the first three years and applicants must be 18 or over; reports differ on whether it is valid for one year, renewable, or three years (Gulf News; Communicate Online, Jan 2026). Missing the 31 January 2026 deadline exposed creators to fines of up to AED 10,000 (Communicate Online). By October 2025 more than 3,000 permits had been issued, and the Council was preparing rules requiring health content creators to have the necessary qualifications (Gulf News). The NMA permit service covers paid and unpaid advertising by individuals (National Media Authority).

The older National Media Council guide, which predates the 2025 law, required paid content to carry "#ad" or "#paid_ad" near the start. Instagram's own policy requires the paid partnership label on organic branded content.

For marketersBefore a creator posts for a clinic, check three things: the creator's Advertiser Permit, the facility's health advertisement approval for that content (DHA Medical Director, DoH, MOHAP or SHA as applicable), and the disclosure label. One does not substitute for another (Gulf News; MOHAP).

Products, medicines and prescriptions

Product alerts reach clinics through the Emirates Drug Establishment (EDE) and local regulators. In June 2026 the EDE ordered an immediate halt to a counterfeit Botox Cosmetic 100 Units batch, C7048C4, which DHA forwarded by circular (Khaleej Times; DHA). DHA circular CIR-2026-00000137 of 12 August 2026 forwarded EDE update No. 35/2026 to Awareness Circular 34/2026, warning of a falsified product presented as BOTOX 500 Units (DHA). DoH Circular 2025/10 warned of counterfeit Ozempic and Mounjaro and stated that both are prescription-only (DoH Abu Dhabi). Pharmacies must verify prescriptions for Wegovy, Ozempic and Mounjaro (Gulf News, Jan 2026). MOHAP halted cosmetic services nationwide during COVID-19 in January 2021 (Gulf News, Jan 2021).

Medical liability

The Federal Decree-Law on Medical Liability (No. 4 of 2016) requires written consent for surgery, mandatory civil liability insurance for practitioners with premiums paid by the facility, and sets penalties for gross medical error of up to one year and/or AED 200,000; it has no cosmetic-specific article (UAE Legislation portal). A January 2026 academic study finds legal ambiguity over whether UAE cosmetic surgeons owe an obligation of means or of result, cites a 2025 Federal Supreme Court decision on cosmetic surgeon liability and calls for specialised legislation (IJARAFMS).

Health data and patient privacy

Federal Law No. 2 of 2019 (executive regulations: Cabinet Resolution 32 of 2020) bars storing, processing or transferring health data outside the UAE without approval and requires records to be kept for at least 25 years. Article 16 bars using patient information for non-health purposes without written consent (Latham & Watkins). Breaching localisation carries a fine of AED 500,000 to 700,000, and health authorities may add fines of AED 1,000 to 1,000,000 (Latham & Watkins). Resolution 51 of 2021 sets 10 exemption types, granted case by case by each emirate's health authority (Al Tamimi & Co; flows, via US International Trade Administration).

The PDPL (Federal Decree-Law 45 of 2021) does not apply to health data regulated by separate legislation, and Dubai Healthcare City licensees are also under DHCC Regulation No. 7 of 2013 (protection regime, via Pinsent Masons Out-Law). PDPL executive regulations had not been issued by the end of 2024 (Baker McKenzie Global Data and Cyber Handbook).

DHA policy PP-11 (10 August 2022) classes marketing as a secondary use of protected health information needing written consent and DHA permission, and treats full-face photographs as identifiers. It says such information "should not be transferred" outside the UAE except under the federal exemptions with DHA approval, requires data sharing agreements for third-party processors and bars sub-processors without written authorisation; messaging apps are not mentioned (Dubai Health Authority). The US International Trade Administration says DHA asset policies allow cross-border flows, which conflicts with this clause.

Privacy design for marketing systems

The draft's privacy design principles are retained: collect only what the next step needs; keep medical history, photographs, diagnoses and clinical notes out of advertising tags and marketing exports; keep the enquiry form minimal; separate enquiry contact permission, marketing preferences and clinical consent; and review URLs, event names, chat transcripts and integrations for accidental disclosure before launch.

Google places "invasive medical procedures, including cosmetic surgery, surgical procedures, or injections" in its sensitive health category, and does not allow Customer Match, your data segments, audience expansion or lookalike segments for these promotions. This is an audience restriction, not a ban on cosmetic search ads. A generic event name does not make an upload safe if the surrounding data still reveals sensitive information.

ONS reading Because DHA policy says protected health information should not leave the UAE without an exemption, and the federal law fines localisation breaches heavily, overseas-hosted CRMs, WhatsApp Business exports and ad-platform customer lists built from patient data need legal review in every emirate before use. These privacy recommendations do not assert that any particular CRM, messaging app or hosting location is approved for a clinic.

VAT and consumer pricing

Elective cosmetic treatment is standard-rated for VAT at 5%, while preventive and basic healthcare from licensed providers is zero-rated (PwC Middle East; Gulf News). Treatment prescribed to treat or prevent a medical condition can be outside the standard rate (Gulf News). DHA allows fees and instalment plans in ads but rejects unmeetable time-limited discounts and prices without conditions (DHA).

No public data. Federal consumer protection rules on price display, promotions and refunds as they apply to clinics were not researched for this edition, and no Ministry of Economy or Dubai Economy enforcement case against a cosmetic clinic was found. A future edition should review the consumer protection law and its executive regulations for price display and promotion rules.

Platform policies in brief

Platform rules apply alongside UAE law; passing a platform review does not mean an ad meets DHA, DoH or MOHAP rules, and the reverse is also true. Chapter 16 covers the operational detail.

Enforcement cases

Published enforcement against cosmetic providers is mostly about unlicensed practice and counterfeit products, not advertising wording. Fine amounts are rarely reported; most press reports say only that cases were referred to the Public Prosecution.

Separate the agency's role from the clinic's

The agency can manage discovery, booking information and communication preferences; the clinical team decides assessment, suitability, treatment and informed consent. A person who completes a form has not been assessed or accepted for treatment. Approval for an organisation or creator does not cover every claim. Keep supporting evidence and the medical review with each advert or post, record the version of the applicable standard, and check creator permits separately from health-sector approval.

Campaign launch checklist by emirate

The checklist below is ONS judgement built from the rules cited in this chapter. It is not legal advice, and each clinic should confirm its current process with its regulator.

ONS reading Treat the strictest applicable rule as the default when a campaign runs across emirates. A UAE-wide ad for a Dubai clinic is still a Dubai clinic's ad under DHA rules, and MOHAP's monitoring page treats any ad that reaches the UAE or carries UAE contact details as within scope.

Clinic launch file

For each campaign, hold the facility licence, responsible practitioner and privileges, the advertisement approval reference and expiry, approved wording, claim evidence, written patient consents and creator permits. Keep a sign-off log with an owner for each approval, and re-check when the treatment, product, practitioner, price, branch or platform changes.

Gaps in the evidence

No public data. DHA and DoH advertisement approval fees, validity and documents, and SHA fee amounts, were not found. No DHA standard for IV therapy or general cosmetic surgery, and no SHA or MOHAP cosmetic standard, was found; the full DHA v2.1 text was not available for clause checking.

No public data. PDPL regulation status after December 2024 was not confirmed; no list of registered toxin and filler brands was found (Baker McKenzie Global Data and Cyber Handbook); Mordor's claim that EDE took over MOHAP services is unconfirmed. No fine amounts were published for 2023 to 2026 cosmetic enforcement cases, no Sharjah or northern emirates case was found, and the live Meta Health and Wellness wording could not be read.