Short answer: A UAE online store must publish its trade licence and address, show every price including delivery and payment fees before checkout, issue a detailed invoice, run a staffed complaints channel with a tracking mechanism, and accept returns in the cases the law lists. Federal Decree-Law 14 of 2023 sets those duties, and Cabinet Resolution 200 of 2025, in force since 13 December 2025, prices each breach from AED 500 up to AED 100,000, almost always after a written warning and 15 days to fix, with closure of 20, 30, 40 or up to 90 days further up the scale, and permanent closure of the establishment at the very top.
This guide is for anyone selling to UAE customers from a website, an app, a marketplace listing or an Instagram account: the owner, the marketing manager who commissions the site, and the developer who builds the checkout. It covers what the law tells you to show and do, and what each breach now costs, as of October 2026. The duties have been in force since September 2023. The price list arrived only in December 2025, which is why most UAE stores have never been measured against it.
Does this apply to me if I sell from a free zone, from Instagram, or from abroad?
Almost certainly yes. Article 2 of Federal Decree-Law 14 of 2023 on Trading by Modern Technological Means, in force since 16 September 2023, applies to anyone carrying on a commercial activity through modern technological means "inside the State or those received from outside it", and to the logistics services and payment gateways attached to it. Shipping into the UAE from a warehouse abroad is inside the scope.
The definition in Article 1 covers websites, platforms and smart applications, and names e-commerce, digital commerce and social commerce in the same breath. A shop taking orders in Instagram direct messages is a digital merchant exactly as a Shopify store is.
Free zones are caught in two cases under Article 2(1)(c): where the goods or services are provided or sold outside the geographic scope of the free zone, and where the free zone has no legislation of its own regulating trading by modern technological means. Financial free zones are caught on the same two tests. Government procurement, non-commercial platforms and Central Bank supervised money and institutions sit outside the decree law entirely.
Licensing is a separate question. The federal portal's e-commerce page, updated on 28 September 2026, says mainland sellers need a commercial licence covering the e-commerce activity from their emirate's Department of Economic Development, that every such licence also needs approval from the Telecommunications and Digital Government Regulatory Authority, and that a free zone company selling on the mainland may need a local distributor.
What must every product page and checkout show?
Two rulebooks apply at once and they ask for different things.
Article 5(5) of the decree law tells the merchant to set the terms, conditions and details of the various stages of the sale, "including determining the prices of goods and services, and the fees and prices for logistics services and digital payment services", and to publish them on the website or app. Article 6(1) gives the customer the matching right: delivery to the announced specifications, on the time, value and logistics costs set out in the digital contract or the announced terms. Article 5(7) bans misleading methods and incorrect data.
Article 6(9) is the clause most UAE stores fail. The merchant's licence from the competent authority, their address, contact numbers, details of their physical address and their website all have to be publicly available. A contact form and a Gmail address in the footer does not meet it.
Then the consumer protection side. Article 40 of Cabinet Resolution 66 of 2023, the executive regulation of the consumer protection law and in force since 14 October 2023, lists what a listing must show clearly and legibly for each commodity: the name, trade name, address and trademark of the producer and of the importer; the name, type, nature, ingredients and quantity; a detailed statement of ingredients and specifications in the original language plus Arabic; the country of origin after the phrase "Made in"; the production date and shelf life; the risks of misuse; the terms of return and replacement; and the terms of handling, storage and use. The penalties table attached to that resolution puts AED 100,000 on failing to show them, and Article 40(3) makes the supplier responsible for a third party's goods sold through its platform.
Arabic is a duty, not a nicety. Article 26 of Federal Law 15 of 2020 on Consumer Protection requires data, advertisements and contracts related to the consumer to be in Arabic, with other languages allowed in addition. How far that reaches into your copy is the subject of our guide to Arabic or English marketing in the UAE.
What counts as a valid invoice?
Article 5(8) of the decree law requires "a detailed non-paper invoice", and row 3 of the schedule annexed to Cabinet Resolution 200 of 2025 widens that to "a detailed invoice, whether in paper or non-paper form". Neither text says what detailed means. The consumer protection regulation does.
Article 6(1) of Cabinet Resolution 66 of 2023 lists eleven particulars every invoice must carry, at no extra cost to the customer: the supplier's name, address and contact information; the invoice date; a description of the good or service; the unit of sale and the quantity or number of units sold; the condition of the good if it is used; the price in local currency; the warranty period; the date of delivery or of providing the service; the serial number of the goods and their parts where the nature of the good calls for it; the commercial registration number; and the tax number if there is one. Article 8(3) of Law 15 of 2020 says the same in shorter form, and Article 8(4) adds that the invoice shall be in Arabic, with any other language the supplier chooses alongside it.
The penalties here are the heaviest in this guide. The table attached to Cabinet Resolution 66 of 2023 puts AED 100,000 on failing to give that invoice and another AED 100,000 on an invoice not issued in Arabic. Article 29 of Law 15 of 2020 goes further on the contents: up to two years in prison, a fine of AED 10,000 to AED 2,000,000, or both, doubled on a repeat. Article 30 covers the Arabic clause at up to six months, a fine of AED 3,000 to AED 200,000, or both, also doubled on a repeat.
The decree law's own ladder is the milder one: a written warning, then AED 500 to 5,000, then AED 5,000 to 10,000, then AED 10,000 to 30,000 with the establishment closed for up to 90 days. Tax invoice content sits in the tax legislation, outside all of this.
What can a customer return, and what can you refuse?
Article 7(1) gives a right to return or exchange in five cases: the goods or services breach UAE legislation; they arrive defective, incomplete, damaged or contrary to the description the merchant gave; delivery is so late the customer cannot use them; they breach the digital contract or the announced terms; or the Minister issues a decision adding a case.
Article 7(2) takes the refund right away in four cases: the customer used the item, unless the use was to verify the absence of a defect; the period specified or followed in the relevant legislation has passed; the goods are food or consumer goods that expire within three weeks, or goods the Minister has listed; or they are books, films or programmes that can only be used, viewed or listened to once.
Two consequences follow. There is no blanket cooling off period here: changing your mind is not among the five grounds, and the only time limit mentioned is "the period specified or followed in the relevant legislations", which in practice means the window you publish. And your returns page has to carry that window and the exclusions in advance, because a refusal you never announced is a refusal against your own announced terms.
Article 8 obliges the customer not to abuse the right of return. That is a defence, not a policy. Obstructing a lawful return is row 6 of the penalty schedule and reaches AED 10,000 to 20,000 plus 20 days of closure on a fourth breach.
What complaint route do you have to offer?
A permanent one, staffed, with a reference the customer can follow. Article 6(7) requires phone numbers and means of communication for complaints that are "permanently available without interruption along with qualified staff", a mechanism to track complaints, a clear address, and periodic updating in an easily accessible way. Article 6(6) is the right to complain about the purchase or any party to it, and Article 6(8) requires contact numbers for the merchant itself.
Read the wording carefully, because it is commonly misquoted: the tracking mechanism the law demands is for complaints, not for orders. Order tracking is good service. Complaint tracking is the legal duty.
Article 6(5) adds something few UAE stores have built: a rating box, provided transparently to everyone, that lets the customer rate the merchant, the goods, the services, the payment gateways and the logistics.
Where the customer goes next is not your choice. The Ministry of Economy and Tourism runs a consumer complaints service on 8001222 and through its app, asking for the defendant's details, a summary and the purchase invoice, and quoting an average of 8 working days. It takes complaints from every emirate except Abu Dhabi, Dubai and Ajman, where the emirate's economic department handles them.
One clause catches badly drafted terms pages. Under Article 9(2)(b), a digital contract worth less than AED 50,000 may not include a condition referring disputes to arbitration, so a boilerplate arbitration clause copied from a foreign template is void for most of what you sell.
What are the fines, and how do the warning and the appeal work?
The price list is Cabinet Resolution 200 of 2025, issued on 27 November 2025, published in Official Gazette issue 813 on 12 December 2025 and in force since 13 December 2025. Some law firm commentary dates it 28 November 2025; the signed text on the federal legislation portal says 27 November. It lists 11 types of violation, each with four steps.
Ten of the eleven start with a written warning giving the merchant no more than 15 days from the date the warning is sent to fix the problem. Only one starts with a fine straight away: the row on providing a secure technical environment for verifying digital identity and the contracting parties. Here are the breaches a shop owner is most likely to commit, every figure in AED.
| What you got wrong | First time | Second | Third | Fourth |
|---|---|---|---|---|
| Unsafe identity or consent flow | 2,000 to 10,000 | 10,000 to 20,000 | 20,000 to 40,000, shut 20 days | 40,000 to 100,000, shut for good |
| Terms, timing, value or delivery cost not as declared | Warning, 15 days | 1,000 to 5,000 | 5,000 to 20,000, shut 20 days | 20,000 to 100,000, shut 40 days |
| No detailed invoice | Warning, 15 days | 500 to 5,000 | 5,000 to 10,000 | 10,000 to 30,000, shut up to 90 days |
| Blocking a lawful return or exchange | Warning, 15 days | 500 to 5,000 | 5,000 to 10,000, shut 20 days | 10,000 to 20,000, shut 20 days |
| No complaints mechanism | Warning, 15 days | 2,000 to 5,000 | 5,000 to 10,000 | 10,000 to 20,000, shut 20 days |
| Undeclared digital payment fee | Warning, 15 days | 500 to 5,000 | 5,000 to 10,000 | 10,000 to 20,000, shut 20 days |
| Undeclared logistics fee | Warning, 15 days | 500 to 2,000 | 2,000 to 5,000 | 5,000 to 10,000 |
Every figure above comes from rows 1 to 7 of the schedule annexed to Cabinet Resolution 200 of 2025, as the federal legislation portal publishes it in English. The Ministry of Economy and Tourism publishes the signed Arabic original on its consumer protection legislations page, as a scan with no text in it. The portal's own note says the English is unofficial and the Arabic prevails where the two differ, so quote the Arabic to a regulator.
Three details change how the ladder bites. Under Article 3(3) the Ministry may skip the gradation where the violation is serious. Under Article 3(4) carrying on after the warning period expires, or after the window for paying a fine lapses, is a fresh violation with a fresh penalty, which is how a store travels from step two to step four in a season. Under Article 3(5), where your emirate's authority supervises, it sets the penalty and keeps the fine.
The appeal route is tight. The Ministry notifies you of the penalty decision within 15 days of issuing it (Article 4(1)). You then have 30 days from that notification to file a reasoned grievance with all supporting documents, and nothing is admissible after that (Article 4(2)). It is decided within 30 days, silence counts as a rejection (Article 4(3)), and the decision is final (Article 4(4)). Fines fall due 30 days after notification under Article 3(6).
Article 2(3) carves acts already priced in the consumer protection executive regulation's penalties annex out of this schedule, so the two tables are meant to divide the ground rather than stack. Article 2(2) still preserves penalties under any other legislation, and the invoice duty sits in both annexes, so take advice before you assume only the milder ladder reaches you. Either way you are reading two penalty tables, and the other one runs to AED 100,000 for a single listing failure.
Which pages does your site need, and what must your checkout stop doing?
Build these before you turn on ads. A legal page with the licence number, the licensing authority, the full physical address and a working phone number, as Article 6(9) requires. Terms and conditions describing every stage of the order, with prices, delivery fees and payment fees named in full under Article 5(5). A returns page stating your window, the five grounds and the four exclusions. A complaints page with a phone number, an address and a reference the customer can quote. A rating control under Article 6(5). Product pages carrying the Article 40 particulars. And a written business continuity plan under Article 5(10), which is an operations document rather than a page.
Then the subtractions. Your checkout must stop adding any logistics or payment fee that was not declared in the digital contract or the terms, which Articles 14(3) and 15(3) forbid outright and the schedule fines separately. Card surcharges go further than that: Article 5(3) of Cabinet Resolution 66 of 2023 tells the supplier not to add any further amount to the value of a good when a credit card is used, declared or not. It must stop showing a total that only becomes true on the last step. It must verify identity, capacity and the offer and acceptance before it takes money, because that is the one row with no warning stage. And it must stop carrying an arbitration clause on orders under AED 50,000.
None of this is expensive to build correctly the first time, and all of it is expensive to retrofit. See what shapes a build budget in what a website costs in Dubai, and what our web design team puts into an e-commerce build. An agency quoting a store without mentioning any of the above is telling you something useful when you are choosing a marketing agency in Dubai.
This is general information, not legal advice. Laws and official guidance change, so read the texts linked here before acting, or book a consultation for a second pair of eyes on your checkout.
Frequently asked questions
Do I need a UAE licence to sell on Instagram?
Yes, if you are selling to customers in the UAE. The decree law's definition of trading by modern technological means puts social commerce alongside websites and apps, so an Instagram shop carries the same duties as a Shopify store. The federal portal says mainland sellers need a commercial licence covering the e-commerce activity from their emirate's Department of Economic Development, plus approval from the telecoms regulator.
Does UAE law give online shoppers a 14 day cooling off period?
Not in this decree law. Article 7 lists five grounds for returning or exchanging and buyer's remorse is not one of them. The only time limit it mentions is "the period specified or followed in the relevant legislations", which in practice means the window you publish. Publish one, state the exclusions beside it, and honour it.
Can I refuse a return on a sale item or an opened product?
Opened is often yes, discounted is usually no. Article 7(2) removes the refund right once the customer has used the item, unless the use was only to verify the absence of a defect, and for food that expires within three weeks and for books, films or programmes that can only be used once. Being on sale is not on that list, so a blanket "no returns on sale items" line has nothing in the decree law behind it.
My company is in a free zone. Does any of this reach me?
In the two situations named in Article 2(1)(c): when you provide or sell outside the geographic scope of your free zone, which covers almost every delivery to a mainland address, and when your free zone has no legislation of its own regulating trading by modern technological means. Ask your free zone authority which applies to your licence.
Does my online store have to be in Arabic?
The consumer facing parts, yes. Article 26 of the consumer protection law requires data, advertisements and contracts related to the consumer to be in Arabic, with other languages permitted in addition, and Article 25(1) asks e-commerce suppliers for adequate information in Arabic about the product and the terms of contract, payment and warranty. Our guide on Arabic or English marketing in the UAE covers how far that reaches into campaign copy.