Short answer: From 1 December 2026 a UAE business in one of the priced sectors that plays recorded music in public needs an annual licence from one of two Ministry approved societies, from AED 1,500 for a cafe of up to 50 seats to a cap of AED 50,000 for a large mall. That licence is written for venues and broadcasters. Nothing the Ministry has published says whether the music inside your brand video, reel or paid ad is covered, so clear those separately with whoever owns the track.
This guide is for marketing managers, agency leads and founders who make video and social content in the UAE, not only for restaurant operators. Almost everything written so far addresses venues, which leaves the question nobody has answered: does this licence cover the music in our films, reels, ads and in store screens. Below is what the Ministry published, what it costs, and where the published text stops. Checked on 12 October 2026, and where the answer is not settled we say so and name who to ask.
What starts on 1 December 2026, and who has to pay?
The Ministry of Economy and Tourism announced its Collective Management in Music Guide on 11 August 2026, adopted by Ministerial Resolution No. 136 of 2026. The page, last updated 8 October 2026, says fees are collected starting December 2026 and licences run one year, renewable. Reed Smith identifies the guide as version 1.1 effective 1 December 2026, and DLA Piper gives the same date.
Priced sectors: restaurants and cafes, shopping malls, fitness centres, hotels and floating hotels, airlines, radio, television, and concerts held in the UAE. Exempt: educational and academic institutions, government entities, national occasions, and non commercial personal celebrations, with power to add more by resolution. Ten per cent of collections funds a Cultural Support Fund for Music, run by the Ministry with the Ministry of Culture.
Two bodies collect: the Emirates Music Rights Association, licensed in April 2025, and Music Nation, licensed in June 2025, both under Federal Decree-Law No. 38 of 2021 on Copyright and Neighbouring Rights. Article 32 lets rights holders assign economic rights to professional associations; Article 34 says such a body may practise only after a Ministry permit.
Ignoring it is not a parking ticket. For using a protected work without the written permission of the author or neighbouring rights holder, Article 39 sets imprisonment of no less than two months and a fine of AED 10,000 to AED 100,000, or either penalty alone, rising on a repeat offence to no less than six months and AED 100,000 to AED 500,000. Reed Smith adds that the Ministry can apply administrative sanctions or revoke permits under Article 15 of Cabinet Resolution No. 47 of 2022.
What will it cost my venue?
| Sector | Measured by | Annual fee in AED | Cap in AED |
|---|---|---|---|
| Restaurants and cafes | Seats | 1,500 to 50 seats, 2,700 for 51 to 100, 4,800 for 101 to 200, then 20 per extra seat | 6,000 |
| The same with a DJ | Seats | 2,500 to 50 seats, 3,500 for 51 to 100, 6,500 for 101 to 200, then 20 per extra seat | 8,000 |
| Shops and retail | Floor area | 1,700 to 300 sqm, 3,400 for 301 to 700 sqm, then 60 per extra 25 sqm | 20,000 |
| Large shopping malls | Floor area | 625 for the first 100 sqm, then 50 per extra 25 sqm | 50,000 |
| Gyms and fitness centres | Floor area | 1,700 to 300 sqm, then 5 per extra sqm | 6,000 |
| Hotels, one and two star | Rooms | 50 per room to 50 rooms, 5,000 for 51 to 100, 8,000 above | No stated maximum |
| Hotels, three star | Rooms | 120 per room to 50 rooms, 12,000 for 51 to 100, 18,000 above | No stated maximum |
| Hotels, four and five star | Rooms | 150 per room to 50 rooms, 15,000 for 51 to 100, 18,000 for 101 to 200, 25,000 above | 25,000 |
| Radio stations | Annual income | 1 per cent, or 3 per cent for a music and song channel | minimum 1,700 |
| Television channels | Annual income | 1 per cent, or 0.25 per cent for a news channel | minimum 1,700 |
| Airlines, premium cabin | Seats | 5,000 to 50 seats, 10,000 for 51 to 300, 30,000 for 301 to 500, then 75 per extra seat | 45,000 |
Every figure is the annual licence fee from Annex 1 of the guide, version 1.1, as reported by Emirates 247 on 15 August 2026 and summarised by Reed Smith on 24 August 2026. Gulf News reported on 11 August 2026 that the Ministry's launch release gave the fee categories and not the amounts, so read the table as press reporting of the guide. No source we read says whether VAT is added, so ask the society for a tax invoice first.
Does a Spotify or Apple Music subscription cover my business?
No, for two separate reasons.
The first is the contract you already signed. Spotify's end user agreement, last updated 4 September 2026, grants “personal, non-commercial use” of the service and its content. Apple's Media Services terms, last updated 14 September 2026, allow use “only for personal, noncommercial purposes” and say the agreement “does not transfer any commercial or promotional use rights to you”. Epidemic Sound, which sells a commercial alternative, states on its in store music page that a personal streaming service is not allowed in a business under the standard consumer licence.
The second is the UAE licence. A supply contract, however correct, is a contract with a supplier, not the licence the guide requires for playing music to the public. Those are two bills, and from 1 December 2026 a venue in a priced sector needs the second one whatever is coming out of the speakers.
Does this licence cover the music in my videos, reels and ads?
Here is the distinction in plain words. Playing a finished track to people in a room, or sending it out over a channel, is public performance, which Article 1 of the copyright law defines as communicating the work to the public by any means, including playing musical works live or recorded. Putting a track into a film, an ad or a reel is a different act: you copy the recording and fix it against pictures. Article 7 lists reproduction, broadcasting, performance, communication to the public and modification as separate uses the author must authorise. The trade word for the second one is synchronisation, and it is negotiated per project, territory and term, not bought as an annual venue licence.
What is settled is that the Annex 1 tariffs are keyed to seats, floor area, hotel rooms, broadcaster income and aircraft seats. They price venues and broadcasters. Reed Smith's summary does not mention advertising, online or social media use at all, and neither DLA Piper's note nor the Pinsent Masons report of 1 September 2026 addresses them.
Three things are not settled, and we will not pretend otherwise.
- EMRA's own licensing page is broader than the tariff table. It lists Reproduction of Music as one of four categories alongside Radio, TV and Online, and says the licence covers music in recorded audio or audiovisual content and music used online and on digital platforms. No published tariff corresponds to that.
- MusicVybe, a vendor selling its own subscription, claims the societies cover only public performance of the composition and the sound recording, not reproduction, master or publishing rights. EMRA's own page claims more, so treat that as a sales position until a society confirms it.
- Whether one licence is enough is disputed. Baker McKenzie wrote on 19 August 2025 that neither society holds a statutory monopoly and each is exclusive only to the repertoire voluntarily assigned by its members, so a mixed playlist may need both. DLA Piper, updated in September 2026, says businesses need only one licence. DLA Piper is newer, and nothing in the Ministry text settles it.
So ask in writing and keep the reply. Send three questions to EMRA through its licensing form, to Music Nation, and to the Ministry, which Gulf News reports is where complaints go. Does your licence cover synchronising a track into a corporate film, a social reel and a paid ad, and under which category and tariff. Does it cover playback of our own brand video on in store screens. Does your repertoire include the tracks on our list, or do we need the other society too. Until that is answered, clear the music for anything with pictures with the library or composer who owns it, which is how our video production work has always handled it.
What does royalty free actually give me, and where does it fail?
Royalty free means you pay once, or by subscription, instead of per play. It does not mean the track is free of every other claim, and the licences differ sharply on exactly the points a UAE business now has to care about.
| What you are using | Brand video and reels | Paid ads | Venue or in store playback | UAE society fee covered |
|---|---|---|---|---|
| Personal Spotify or Apple Music | No | No | No | No |
| Meta Sound Collection | Meta surfaces only | Meta surfaces only | No | No |
| Artlist Pro licence | Yes, inside a project | Online yes, out of home needs the business licence | The project yes, the music alone no | No, section 9 says you pay the society |
| Epidemic Sound Pro plan | Yes | Online yes, television ads and cinema no | Separate in store plan through a partner | Claimed, but no territory named |
| An EMRA or Music Nation licence | Not tariffed, ask them | Not tariffed, ask them | Yes, this is the use it prices | Yes, this is the fee |
Rows come from each company's current terms: Spotify's of 4 September 2026 and Apple's of 14 September 2026; Meta's Music Guidelines, effective 26 March 2024; the Artlist Pro or Business License effective 15 February 2026, which is not the Social License on the same page, effective 4 January 2026, that covers only your own channels and bars paid media and client work; Epidemic Sound's in store page and its Pro plan page; and EMRA's licensing page.
Artlist says the hard part itself. Section 9 of the Pro License promises public performance and broadcast rights, then states that the licence does not cover royalties to performance rights organisations and other collecting societies, and that if you or your client broadcast or publicly perform the project you may receive payment requests and will have to pay them. In a country with two new societies, that clause points at you. The same licence forbids a track on its own, so a static image or looping animation with Artlist music behind it is out, which kills the cheapest in store screen loop. Companies over 50 employees, and any out of home placement, need the business licence.
Epidemic Sound sits the other way round. Its in store page says the licence covers public performance rights, helps you avoid public performance fees, and leaves no royalties owed to a local collecting society. It names no territory and sells in store through a partner, so get the UAE written into the contract. Its Pro plan covers digital ads and client work but excludes cinema, television shows and television ads, and pushes companies above USD 10 million of revenue to Enterprise.
Platform libraries are narrowest. Meta's Music Guidelines say use of music for commercial or non personal purposes is prohibited unless you hold the appropriate licences, that the recording must not be the primary purpose of the content, and that more music means more restriction. Its Sound Collection, the cleared pool business accounts are pointed to, clears music for Meta's own surfaces, so the same track does not travel to YouTube, your website, or an in store screen. Osborne Clarke put the general rule on 27 March 2026: platform libraries are mostly licensed for private use, commercial use should be read very broadly, and where a platform licence does not clearly cover a use, a separate licence has to be obtained. If your social media calendar runs on trending audio, that is the risk you carry.
Original score or a library track: what are you actually buying?
Price is the wrong first question. The first is what you own and what you can prove.
A library subscription buys a non exclusive right to use someone else's recording inside a project, within the limits above. Artlist's licence is explicitly non exclusive, so the track behind your brand film can also sit behind a competitor's, and both Artlist and Epidemic Sound stop at television advertising and cinema on their standard plans. That is the line most UAE brands cross the moment a campaign moves to a screen that is not a phone.
An original score buys the opposite: music written for one film, one chain of title, cleared for the uses named in the commission, with no platform match to clear and no term that expires mid campaign. It is also the only option that lets you own the asset, which matters once the music becomes a brand sound. Our own sound design and original music work starts at AED 2,500 a project as an indicative figure, and that page does not state VAT treatment, so read it as one data point near the floor rather than a benchmark. Budget music alongside the production, not after it, the way the numbers in our guide to video production costs in Dubai are laid out.
The rule: internal, short lived, phone first content takes a library track on the right plan. Paid media, television, out of home, cinema, an in store screen, or anything you still want in three years gets commissioned, or licensed per project in writing.
Can I use AI generated music, and who owns it?
Two questions, and only one has a clear answer.
Ownership first. Suno's terms of service, revised 10 August 2026 and effective 3 September 2026, say free and basic tier users may use outputs only for lawful, personal and non commercial purposes, while Pro and Premier subscribers receive an assignment of Suno's right, title and interest in the output. The same document then says Suno makes no representation or warranty that any copyright will vest in any output. Read that twice: you get whatever the company holds, and nobody promises a copyright exists in the result. For a brand asset you may need to defend, that is weak, and it is the position you are in with AI video too unless you direct it properly, which is the argument in our note on directing AI video.
Licensing second, and here we will not invent an answer. DLA Piper's note, published 20 July 2026 and updated in September 2026, states that completely AI generated music cannot be licensed under the framework, while music with sufficient human creative input remains eligible. We could not corroborate that in anything the Ministry has published, and its announcement does not mention AI. The law is narrower and still useful: Article 1 defines a work as an innovative production, an author as the person who creates the work, and innovation as the character that bestows originality and distinction upon the work. It is built around a creating person and says nothing about machine generation.
Either way, keep the prompt, model, date, session export and plan tier the way you would keep a composer's contract. If the music is load bearing for the brand, put a person in the loop and document what they contributed.
Frequently asked questions
I already pay a music supplier for my shops. Do I still need the UAE licence?
Probably yes, for a different thing. Your supplier contract clears the recordings. The guide prices a licence for playing music to the public in a priced sector from 1 December 2026, collected by EMRA or Music Nation. Epidemic Sound is the one supplier we read that claims its direct licence removes collecting society fees, and it names no territory, so get the UAE written in. Artlist states the opposite in section 9 of its Pro License.
Does the licence cover a reel posted from the company account?
No published tariff covers it and the Ministry text does not address social content. EMRA's licensing page says its licence extends to music online and on digital platforms and to music in recorded audio or audiovisual content, with no stated tariff. Ask EMRA and Music Nation in writing which category applies. Meta's Music Guidelines separately require an appropriate licence for commercial use of music on its platforms.
What is the penalty if we do nothing?
Article 39 of Federal Decree-Law No. 38 of 2021 sets imprisonment of no less than two months and a fine of AED 10,000 to AED 100,000, or either penalty on its own, for using a protected work without written permission. A repeat offence rises to no less than six months and AED 100,000 to AED 500,000. Reed Smith also notes the Ministry's power to sanction or revoke permits under Cabinet Resolution No. 47 of 2022.
Does one licence cover both societies' music?
The sources disagree and the disagreement is live. DLA Piper, updated in September 2026, says one licence is enough. Baker McKenzie wrote in August 2025 that each society is exclusive only to the repertoire its members assigned to it, which points towards needing both for a mixed playlist. Send both your track list and ask each in writing whether it holds those rights.
How soon should we deal with this?
Now, because the window is short. Fees start on 1 December 2026 and EMRA publishes a licensing application form on its own site, so send it and keep the dated reply. Nothing we read says applications are formally open, so ask EMRA and Music Nation directly. To settle the venue, the ads and the social calendar in one pass, our team can take it apart with you in a short consultation.