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UAE Competition Law Filing Fees (2026): Who Files, How Much, and By When

As of late July 2026, the UAE has a working merger-control regime with real, published filing fees. If your transaction crosses certain thresholds, notifying the Ministry of Economy (MoEc) before you close is now mandatory — and getting it wrong is expensive. This guide covers who must file, what it costs, the deadline, and the penalties, with sources.

What changed, and when?

The UAE Competition Law (Federal Decree-Law No. 36 of 2023) is now operational, completed by Cabinet Decision No. 59 of 2026 (the Executive Regulations) and Cabinet Decision No. 105 of 2026 (the filing fees). The jurisdictional thresholds sit in Cabinet Decision No. 3 of 2025.

  • The fees take effect 29 July 2026.
  • The Executive Regulations take effect 30 July 2026.
  • The fees decision was published in UAE Official Gazette No. 826 on 29 June 2026.

Do I have to file a merger (economic concentration) notification?

A pre-merger notification to the Ministry of Economy is mandatory when the transaction meets the turnover threshold set by Cabinet Decision No. 3 of 2025:

  • Combined UAE annual turnover of the parties in the relevant market is AED 300 million or more in the previous fiscal year.

If it's met, you must file at least 90 days before completing the transaction — and you cannot close during the review. The regime is suspensory: with the Ministry's review period (up to 90 days, extendable by 45) on top, plan for a six-month-plus clearance horizon.

What about the 40% figure? A 40%-or-more market share is a dominance presumption, not a merger-filing trigger. It means an undertaking is presumed dominant — relevant to abuse-of-dominance (conduct) rules, and rebuttable in both directions (dominance can be found below 40% too). On its own, it does not require a merger notification; the turnover test above is the filing trigger.

How much does a merger-clearance filing cost?

  • 0.02% of the total annual sales of all establishments participating in the concentration, capped at AED 150,000.

What does a competition exemption filing cost?

  • AED 5,000 for each exemption request (requests under Articles 5–8 of the Competition Law).

What about objections and grievances?

  • Objection to a concentration: AED 1,500.
  • Grievance against a decision: AED 500 — refundable if the grievance is accepted.

What are the penalties for not filing (or closing too early)?

  • Failure to notify a transaction that met a threshold: a fine of 2% to 10% of the previous fiscal year's annual revenue. Where that revenue cannot be calculated, the fine ranges from AED 500,000 to AED 5 million.
  • Gun-jumping (breaching the standstill obligation — closing before clearance): AED 50,000 to AED 500,000.

Does this actually apply to my business?

Most SMEs won't hit the AED 300M turnover threshold, so a merger notification often won't apply. But two things still catch smaller businesses regardless of size: a 40%+ share of a narrow relevant market brings you into scope of the abuse-of-dominance rules (a conduct issue, separate from merger filing), and exemption filings (the AED 5,000 ones under Articles 5–8) cover a broader set of agreements than full mergers. Check your specific arrangement — the dominance and restrictive-agreement rules bite independently of the turnover threshold.

How Dembri helps

Dembri works out whether these thresholds apply to your entity or deal and tracks the 90-day clock so a filing window doesn't lapse. It flags what applies and when; it doesn't file for you — that stays with you or your competition counsel.

Sources

  • Federal Decree-Law No. 36 of 2023 (UAE Competition Law)
  • Cabinet Decision No. 3 of 2025 (jurisdictional / notification thresholds)
  • Cabinet Decision No. 59 of 2026 (Executive Regulations; in force 30 July 2026)
  • Cabinet Decision No. 105 of 2026 (filing fees; UAE Official Gazette No. 826, 29 June 2026; in force 29 July 2026)

This guide reflects reputable practitioner analysis of the above instruments as of 27 July 2026. Confirm against the primary Official Gazette text before acting on a specific transaction.