As the UAE prepares to welcome the world in 2020 as the first country in the Middle East, Africa and South Asia to host Expo, the country continues to be a beacon for technology and innovation. As a country that has achieved global recognition for its transformation and diversification, the UAE shows no sign of standing still.

On 25 September 2019, the UAE launched its first astronaut programme, sending Hazaa Al Mansouri into space. The UAE plans to send an unmanned spacecraft to Mars 2021 as part of the Hope Mars Mission. If successful, that would be the Arab world's first mission to Mars.

Smart Dubai 2021 aims to move to a 100 per cent digital future within four years leading to the Dubai government issuing its last paper transaction by 2021. Government planning extends to the year 2071 across a programme that includes the following objectives: (1) fortifying the country's reputation; (2) diversifying imports and exports by relying less on oil; (3) investing in education focusing on advanced technology; (4) building Emirati values and ethics for the future generations; (5) raising productivity of the national economy; and (5) enhancing society's cohesion. Technological change sits at the heart of this agenda.

While the UAE's regulatory schemes continue to develop, the government is also actively addressing the natural tension between regulation and innovation. The country has been keen to incorporate best of breed learnings from successful innovation hubs such as Silicon Valley. The Dubai Future Accelerators initiative, for example, brings together top international companies and entrepreneurs to address seven key '21st century opportunities'. This includes the application of cutting-edge technologies such as AI and robotics, genomics, 3D printing, distributed ledgers, biomimicry and biotechnology, as well as new business models and ways of working. In March 2019, Abu Dhabi government launched Hub71, a 1 billion dirham mega hub that aims to bring together start-ups, innovators and global and regional leaders in technology and venture capital, such as Microsoft and Mubadala.

At a regulatory level, we expect significant changes in the near future in areas such as data privacy and healthcare. We understand that the Telecommunications Regulatory Authority (TRA) is looking at implementing a federal level data privacy law, as part of the UAE National Cybersecurity Strategy, which, if enacted, will have a significant impact on companies that collect, process, host and transmit data within the UAE.


i The regulators

Formed in 1971, the United Arab Emirates is a constitutional federation of seven emirates, each with their own laws and each subject to federal laws. Free zones within emirates may issue their own laws, applicable within the relevant free zone, but are subject to the Federal Penal Code. The free zones are often referred to as offshore while the rest of the UAE is referred to as onshore.

The regulatory framework for the TMT sector in the UAE is divided into two sub-sectors: telecommunications and technology, and media, although convergence has led to a degree of overlap. In addition, as other sectors continue to digitally transform their everyday operations, there might be sector-specific considerations and legislations relating to technology outside the TMT sector in the UAE, such as in healthcare, banking or litigation.2 These sector-specific considerations are not covered as part of this chapter.

Telecommunications and technology

The principal regulator of the telecommunications and technology sector is the TRA, which was established under the law regarding the Organisation of the Telecommunications Sector (the Telecoms Law).3

The TRA has two stated focuses: regulating the telecommunications sector and enabling government entities in the field of smart transformation.4

It is responsible under the Telecoms Law for a range of functions, including ensuring telecommunications services provided throughout the UAE sufficiently satisfy public demands and enhancing the level of service provided by the telecommunications sector.5

In addition to the Telecoms Law, the TRA is also bound to act in accordance with the Executive Order,6 the Licensing Framework Resolution7 and the National Agenda.8


The National Media Council (NMC) is the federal authority tasked with supervising media activities in the UAE. It is mandated to:

  1. develop the UAE's media policy;
  2. draft media legislation and ensure its execution;
  3. coordinate media policy between the emirates; and
  4. issue operating licences to media companies.9

Federal Law No. 1510 (the Media Law) regulates printing and publishing licensing activities in the UAE and applies to traditional media content such as newspapers, magazines and television broadcasting. A 2010 Chairman's Resolution extended the application of the Media Law to all audio, visual, print and digital media institutions in the UAE.11

In March 2018, the NMC established a new system to govern electronic and digital media activities in the UAE. Under Cabinet Decision No. (23) of 2017 Concerning Media Content (the EM Regulations), any individual or company carrying on electronic media activities12 in the UAE must obtain a licence from the NMC. The websites of licensed traditional media (i.e., television, radio, newspapers and magazines) already fall under the provisions of the EM Regulations and, as such, are not required to secure new licences.

In addition to the federal laws referenced above, some free zones in the UAE also regulate broadcasters and publishers operating within the parameters of their jurisdictions.13

ii Regulated activities

Telecommunications and technology

Under the Telecoms Law, any sale, provision or operation of a telecommunication service requires a licence.14

Telecommunication services are defined as transmitting, broadcasting, switching or receiving by means of a telecommunications network. This includes, for example, wired and wireless telecommunications; voice, music and other audio material; and visual images.

The provision of internet services to subscribers also requires a licence,15 as clarified in Article 66 of the Executive Order.

There are two types of licences:16 individual licences for services that require substantial regulatory supervision or usage of scarce resources (e.g., spectrum); and class licences17 where there is no need to use scarce resources of spectrum and numbers or less regulatory supervision is required.18 Both licences are issued for 10-year periods.

There are currently two licensed providers of public telecommunications services in the UAE: Etisalat and du.

The telecommunications sector is currently excluded from the scope of the most recently enacted competition law in the UAE.19


Under the Media Law, certain activities require a licence, including operating a printing press or publishing house; circulating, selling or distributing printed material; and the publication of newspapers.20

Applications must be filed online via the NMC's website, and the fees payable depend on the type of licence sought.

As noted previously, any individual or company carrying on electronic media activities is required to obtain a licence from the NMC.21

Restrictions apply under the Media Law and the EM Regulations in respect of the types of individuals and entities that can apply for a licence.

Internet of things

The UAE has an ambitious internet of things (IoT) strategy. Through projects such as the 'Dubai Internet of Things Strategy', the UAE seeks to build the world's most advanced IoT ecosystem. As part of this, the TRA has published policy and regulatory procedures regulating the internet of things (IoT Policies).22 These IOT Policies give the TRA regulatory powers in relation to IoT services in the UAE and set forth certain principles with respect to the associated data. The IoT Policies apply broadly and will be relevant to individuals, companies, public authorities and other legal entities concerned with IoT in the UAE (including foreign IoT providers that provide IoT services remotely into the UAE). An overview of the principal requirements includes the need to register with the TRA and to obtain a registration certificate. To obtain a registration certificate a UAE presence or appointed UAE representative is required by the TRA. In addition, there are various data-focused requirements such as data storage requirements and purpose limitation requirements. In the absence of any additional grace periods IoT suppliers need to be compliant with the IoT Policies at the time of writing.

Future technology

The UAE government has issued new legislation under which a temporary licence can be granted for projects that use modern technologies (including the use of artificial intelligence) which are not currently governed by legislation in the UAE.23 This temporary licence may be granted as a temporary measure while appropriate legislation regulating the project or technology is prepared.

iii Ownership and market access restrictions

General foreign ownership restrictions

Currently, foreign companies can only operate onshore in the UAE by partnering with a UAE national or wholly owned UAE entity, with the UAE national or entity having 51 per cent ownership.24 Companies established in the free zones are exempt from this restriction, and may have 100 per cent foreign ownership.25 A limited liberalisation of the onshore position was introduced in September 2018 allowing foreign ownership of some companies operating in 13 sectors.26

Telecommunications and technology

Licence holders under the Telecoms Law (individual and class) must be a company established under the Commercial Companies Law27 whose shareholding accords with a resolution of the TRA Board.28

TRA Resolution No. 8 of 2009 restricts the foreign ownership of global mobile personal communications service licensees or public access mobile radio service licensees to 49 per cent.29

At the time of writing, there are no public constraints on aggregate holdings of spectrum and licences but, in the future, as the number of new entrants increase, there may be changes to help the TRA manage competing claims for spectrum.


Article 2 of the Media Law (and subsequent resolutions issued by the NMC) provide that the owner of a media service must be a UAE national. This means that a media entity with foreign ownership must either partner with a UAE national or wholly owned UAE entity to set up an onshore entity or, as noted above, set up in a free zone that permits 100 per cent foreign ownership.

iv Transfers of control and assignments

Licence transfers require the written approval of the TRA.30

There is also an express obligation to obtain the prior written consent of the TRA in the event of a merger or acquisition, transaction, contract, reorganisation, sale or other corporate venture that results in the change of control of a licensee.31


i Internet and internet protocol regulation

The Telecoms Law makes no regulatory distinction between internet and IP services and other telecommunications services. Such services fall within the definition of a regulated activity and thereby require a licence from the TRA. That said, certain specific policies cover the provision of internet and IP services in the UAE.

For example, it is TRA policy that the provision of VOIP services requires a licence.32 There are two exceptions: where the network is operated for the benefit of users within the same company or group; or where the network is operated for an educational purpose, research purposes or for the benefit of UAE government entities. Otherwise, the provision of consumer IP services is not permitted in the UAE, and access to a number of these services such as Skype consumer and Facetime are blocked.33

ii Universal service

As noted previously, the TRA is tasked with ensuring that telecommunication services provided in the UAE are sufficient to satisfy the public demands of those who wish to make use of such services.34 It also has the authority to create conditions on universal service in the UAE.35 To this end and, in addition to certain financial obligations for universal service funding in each telecoms licence, the TRA has issued a regulatory policy on the promotion of universal telecommunications services in the UAE (USO Policy).

Under the USO Policy, the TRA will designate one or more licensees as having an obligation to provide universal services in the UAE (a universal service provider (USP)). A USP must ensure that consumers in permanent accommodation have access to a service capable of delivering basic voice, TV services and high-speed data packages of at least 10Mbps. A USP may subcontract its USO to other licensees who are able to provide the services more efficiently provided that it obtains approval from the TRA.

At this stage, there are no official government subsidies for the construction of broadband infrastructure and innovative communications technologies. However, the government is heavily invested in telecommunication companies who in turn invest in deploying new broadband infrastructure. This differs from other countries and regions (including the European Union) where public funding is made directly available for broadband deployment.

iii Restrictions on the provision of service

Pricing regulation

The TRA has in place a regulatory policy on pricing36 that prohibits a licensee from pricing in a way that is anticompetitive, and that could restrict, distort or prevent competition in the short term or in the long term; or restricts, distorts or prevents the growth and development of the telecommunication sector of the UAE,37 the exception being in the case of a public emergency.

The TRA recently published a new regulatory policy and procedure on price control,38 which provides that each licensee must request prior approval before implementing any change in price,39 including where there is a price promotion.


Licensees are required pursuant to the terms of their licence to permit interconnection with each other's networks.40

There are regulations on interconnection pricing41 and corresponding fee schedules42 that either du or Etisalat may43 be required to comply with.

Net neutrality and monitoring

There is no net neutrality obligation in the UAE, and in the absence of one, licensees technically have the freedom to block or favour certain content over other content. Content is typically blocked on the grounds of public or political policy or as a result of TRA policies (i.e., the prohibition on VOIP services discussed above).44

The network operators monitor content accessed through their network in order to assist with the enforcement of laws in the UAE.

Unsolicited communications

Under Article 5 of the Unsolicited Electronic Communications Regulations,45 telecommunication licensees must establish practical measures to minimise the transmission of spam having a UAE link across their telecommunications networks. If they become aware of such spam, they are under an obligation to take all practical measures to end its transmission or breach the regulations.46

For those entities which are not telecommunications licensees, there is no express obligation under the privacy laws in onshore UAE to obtain consent for marketing communications, although in practice it is recommended to do so to align with best practice in other jurisdictions such as Europe. For those operating in free zones such as the Dubai International Financial Centre (DIFC)47 and Abu Dhabi Global Markets (ADGM),48 an individual must be notified and given the right to object to its data being used for direct marketing purposes.

iv Security

Protection of national interest and law enforcement

National standards for content exist under the Media Law and NMC resolutions, including prohibitions on material that is harmful to the UAE's interests or criticises the government or rulers of the UAE. These are discussed in further detail in Section V.

The telecommunication providers are required to assist the government with criminal enforcement. Article 8.2 of Etisalat's licence requires that it complies with directions of the TRA or other competent authority that may be issued from time to time on public interest, safety or national security. It must also maintain call logs for its subscribers and install such equipment as the TRA needs to allow access to its network and the retrieval and storage of data for reasons of public interest, safety and national security. Likewise, satellite licensees must permit access to their premises for inspection by the TRA and otherwise comply with the directions of the TRA with regard to public interest, safety and national security.

Telecommunication licensees are required to register any mobile consumer who purchases a mobile sim card and mobile services, including obtaining and verifying their identification details and storing such information in a database.

The UAE legislature has taken steps to protect national interests under the Cyber Crimes Law,49 as described in Section IV.

Personal data and privacy protection

There is no general data protection law in onshore UAE and no single national data protection regulator. An individual's right to privacy is enshrined in the UAE Constitution50 and the UAE Penal Code. It is, however, worth mentioning that the TRA is looking at implementing a data privacy law, as part of the UAE National Cybersecurity Strategy. A draft of the law has yet to be made public. Likewise, the DIFC has amended its Data Protection Regulations to bring them more in line with GDPR and international best practices,51 and we understand that it is expected to issue a new data privacy law before the end of the year.

For example, under the Penal Code it is an offence to disclose the secret52 of another without their consent. A company must obtain consent from individuals before collecting personal details of individuals, whether that is a consumer or an employee.

When obtaining consent electronically, companies must ensure that individuals granting consent to the use of their personal information must signify consent through some form of positive act. Collecting an individual's personal information without first obtaining consent has the potential to carry criminal liability.

More comprehensive data protection laws apply to companies incorporated in a free zone with its own data protection laws, such as the DIFC and ADGM.53

Companies using tracking technologies such as cookies should be aware of the Cyber Crimes Law. Article 2, for example, creates an offence for anyone who gains access to, inter alia, a website, computer network or electronic information system without consent. The Cyber Crimes Law also carries criminal liability.

Protection of children online

To deal with an increase in crimes against children online, the UAE has established various child protection initiatives. A UAE based non-profit organisation called e-safe aims to create a safer online experience and to protect children from all types of exploitation.54

In 2016, a child protection law55 was issued by the government. The law obliges telecommunication companies to notify the competent authorities or concerned entities of any child pornography being circulated on the internet.56

Cybersecurity in the UAE

The Cyber Crimes Law was designed to prevent crimes online and promote a safer digital environment.57

Offences include gaining access to an individual's electronic system without permission,58 invading an individual's privacy using electronic means and using a false internet protocol address for the purposes of concealing a criminal activity. Punishment for breach of the law can lead to imprisonment and fines.

The UAE established the UAE Computer Emergency Response Team to improve information security standards and practices and to protect IT infrastructure in the UAE.


i Development

In common with other jurisdictions, the UAE operates a licensed spectrum regime, and the TRA has in place a spectrum allocation regulation59 and a spectrum fees regulation.60

ii Flexible spectrum use

The UAE has implemented, and is in the process of implementing, a number of strategies with respect to spectrum licensing:

  1. digital dividends, which will occur when spectrum is freed up as operators switch from analogue to digital transmissions;61
  2. LTE standards, which may utilise spectrum more efficiently than certain alternative technologies;62
  3. spectrum sharing: the TRA Regulations on Spectrum Allocation and Cordless Telephony allow for spectrum sharing, and place a special emphasis on reviews and audits of such proposed sharing to ensure there is no mutual harmful interference; and
  4. mobile monitoring stations: the TRA has purchased a mobile monitoring station with the objective of monitoring frequencies and better managing spectrum.63

iii Broadband and next-generation mobile spectrum use

Like many other jurisdictions, the demand for broadband services has increased in the UAE.

To this end, and to encourage the deployment of the new 5G broadband technology, the TRA has created a steering committee with respect to the introduction and deployment of 5G technology. To manage UAE spectrum more efficiently in the provision of 5G services, the TRA supports the use of harmonised spectrum bands for 5G, and is considering the 40GHz for 5G technology beyond 2020.64

Both du and Etisalat launched their 5G network in the Middle East and North Africa region (MENA) region in June 2019. Users can enjoy 5G service access on select smartphones only. The three devices that currently grant users access to the 5G network are ZTE Axon 10, the ProHuawei Mate 20X 5G and OPPO RENO 10X 5G. Technology analysts estimate 5G connectivity will boost the GCC economy by US$269 billion over 10 years with cheaper, faster internet access and connecting devices through the IoT.65

To meet the growing demands for broadband services, the TRA has introduced exceptions to the blanket requirement for a spectrum authorisation for any use of spectrum in the UAE.66 For example, the provision of Wi-Fi services in public places (i.e., hotels, cafes) can be provided by any person without a formal spectrum authorisation from the TRA, provided certain conditions are met.67

iv Spectrum auctions and fees

There are currently no plans to auction spectrum in the UAE.


i Restrictions on the provision of service

Telecommunications and technology

The TRA implements an internet access management (IAM) policy in the UAE, in coordination with the NMC and Etisalat and du, the licensed ISPs.68 The policy must be taken into consideration by the ISPs to ensure the security of the internet and to protect end users from harmful websites that are contrary to the UAE's religious and ethical values. Restricted content under the IAM policy includes pornography, nudity, vice and offences against the UAE. The TRA also monitors online advertising in its enforcement of the IAM policy and has discretion to block online content if found contrary to the policy and other local legislation.69


The Media Law sets national standards for media content. Restrictions include prohibitions on material that is harmful to Islam or harms the UAE's interests; material criticising the government or rulers of the emirates or the UAE; and publishing news, photographs or comments that invade the privacy of individuals and families or destroy reputations.

A 2010 Chairman's Resolution extended the Media Law (including the content restrictions thereunder) to all audio, visual, print and digital media institutions in the UAE.

The EM Regulations 2017 reinforce the existing restrictions for media content and their extension in scope to include digital activities. The Regulations also create a Website Censorship Committee70 tasked with ensuring websites comply with the principles and standards of media content set out in the legislation, and recommending websites to be blocked and keywords to be banned on the internet.

NMC Chairman's Decision No. 35 of 2013 regulates the content of advertising materials. Advertisements that are produced, placed or distributed within the UAE or imported into the UAE must abide by the national standards for media content and the Media Law.

Finally, the Penal Code includes specific provisions regarding defamatory content.71

In addition to the federal laws above, some free zones in the UAE also regulate broadcasters and publishers operating within the parameters of their jurisdictions. Examples include Dubai Media City, regulated by the Dubai Development Authority, and Two Four Fifty Four, the media free zone in Abu Dhabi.

ii Internet delivered video content

Online video subscriptions across the MENA region exceeded 1 million in 2017, up 48 per cent from the previous year.72 Subscriptions are forecast to grow at a compound annual growth rate of 34.4 per cent over six years, reaching 5 million in 2022.73

That growth is likely to be more pronounced in the UAE, a market with high internet and mobile penetration rates, government support for internet ubiquity and the presence of a significant youth population. Relative to the country's high gross national income per capita, broadband is also affordable for many users.74 In the UAE, consumers spend an average of 4.7 hours weekly on smartphones watching online videos, and 71 per cent of internet users watch films online.75

As in other jurisdictions, telecom operators in the UAE have suffered a decrease in revenues due to the emergence of OTT players in the market. That has led to a debate around the cost of network infrastructure rollout, OTTs' contribution towards such costs, and whether network operators and OTTs operate on a level regulatory playing field.


On 6 February 2019, the President of the UAE issued Federal Law No. 2 of 2019 (the Health Data Law),76 which regulates the use of information and communications technology (ICT) in the healthcare sector. The law was introduced to increase the use of ICT in health fields, while ensuring the safety and security of health data and information. Some of the notable provisions of the law include Article 13, which imposes a data localisation requirement for the storage and transfer of health information and impacts the use of non-UAE based cloud service providers in the healthcare sector.

In March 2019, Uber announced plans to acquire the regional ride hailing app Careem for US$3.1 billion.77 While the acquisition, which is expected to close in 2020, was viewed as another success story for e-commerce startups in the UAE,78 it is still being challenged by the competition authority in Qatar.79

Also in March 2019, the Abu Dhabi government launched Hub71, a 1 billion dirham mega hub that aims to bring together start-ups, innovators and global and regional leaders in technology and venture capital, like Microsoft and Mubadala, with the aim of accelerating Abu Dhabi's economy and positioning the capital as a preferred destination for tech companies and start-ups.80

In April 2019, the UAE launched a national strategy for artificial intelligence (AI) with the aim of employing artificial intelligence in vital areas in the UAE to improve customer services and increase living standards.81

Tech giants Microsoft and AWS both announced the launch of data centres in the Middle East in a race to become the leading cloud service providers in the region. In June 2019, Microsoft announced the launch of two new data centres in the UAE.82 Amazon Web Services (AWS) closely followed suit in July by announcing the launch of a data centre in Bahrain.83


In 2019, the UAE continued to position itself as a regional hub for emerging technology and innovation, by introducing regulations governing the IoT, adopting a national strategy for AI and launching 5G.

In addition, the UAE is gearing up to host Expo 2020 between 20 October 2020 and 10 April 2021, under the slogan of 'Connecting minds: Creating a better tomorrow', which is likely to boost the economy and attract foreign investment in the country, particularly in the TMT sector.

We anticipate that the UAE's ambitious plans for smart cities, autonomous transportation and blockchain technology will continue to cement the country's position as a leader in this field.

Challenges still exist. The question regarding public and private data ownership is likely to be a source of future debate, particularly in light of the Dubai Data Law,84 which allows the government to require private sector entities to provide Dubai data85 for the purposes of making that information open data. The UAE may also consider revisiting its restrictions on VoIP services if it wants to stimulate the exchange of ideas and innovations across borders, and relax its localisation requirements for the storage of data to enable businesses to benefit from the agility and scalability that can only be achieved through the use of public cloud platforms.


1 David Bintliff is a partner, Lena El-Malak, Chris Eklund and Mayowa Olusola are associates, and Ayah Abdin is a trainee associate at Bird & Bird.

2 See, inter alia, Federal Law No. 2 of 2019 on the Use of the Information and Communication Technology in the Health Fields, or Ministerial Decision No. 260/2019 on the Procedural Guide Regulating Litigation Via Electronic Means and Telecommunications in Civil Matters.

3 Federal Decree Law No. 3 of 2003 as amended by Federal Law No. 1 of 2005 and Federal Law No. 5 of 2008 (the Telecoms Law).

4 https://www.tra.gov.ae/en/about-tra/about-tra-vision-mission-and-values.aspx.

5 Article 13, Telecoms Law.

6 The Decision of the Supreme Committee for the Supervision of the telecommunications Sector No. (3) of 2004 issuing the Executive Order of the Telecoms Law.

7 TRA Resolution No. (6) of 2008 regarding the Licensing Framework.

8 National Agenda 2021, available at www.vision2021.ae/en/national-agenda-2021.

9 UAE Federal Law No. 1 of 1972 on the competencies of ministries and powers of ministers, and concerning the establishment of the National Media Council as amended by Federal Decree Law No. 1 of 2006.

10 Federal Law No. 15 of 1980 concerning Printing and Publishing and its amendments (the Media Law). An amendment to the Media Law was proposed in 2009, but not signed into law.

11 Chairman of the NMC Resolution No. 20 of 2010 Concerning Media Content Standards.

12 All online activities including e-commerce, publishing and selling of print, video and audio material 'even if practiced on social media'.

13 For example, Dubai Media City, regulated by Dubai Creative Clusters Authority, and Two Four Fifty Four, the media free zone in Abu Dhabi.

14 Article 37, Telecoms Law.

15 Except in the case of internet service provided onboard aircraft, which can be provided without a licence above 10,000 feet. See Aeronautical Radio Systems Regulation issued by the TRA on 14 March 2018.

16 TRA Resolution No. (6) of 2008 regarding the Licensing Framework (the Licensing Framework Resolution).

17 Not to be confused with class licences granting a general authorisation to provide certain telecommunication services to a number of service providers providing the same class of service as used in the UK regulatory regime and other jurisdictions.

18 Article 4(2)(b) of the Licensing Framework Resolution.

19 Federal Law No. 4 of 2012 on the Regulation of Competition. However, a sector may be listed as exempt due to another law or regulation regulating competition in that sector; for example, the TRA has authority to regulate competition in the sector.

20 Articles 3, 17, 24, 49, 54, 66 and 67 of the Media Law.

21 Refer to the EM Regulations.

22 TRA Regulatory Policy – Internet of Things, issued on 22 March 2018 and TRA Regulatory Procedures – Internet of Things, issued on 6 March 2019.

23 Federal Decree-Law No. 24/2018 on Futuristic Projects; Cabinet Decision No. 14/2019 on the Regulation of Issuance of Temporary Licences for Futuristic Innovative Projects

24 Article 10, Federal Law No. 2 of 2015.

25 Article 5, Federal Law No. 2 of 2015.

26 Federal Decree-Law No.19 of 2018 on Foreign Direct Investment issued on 23 September 2018.

27 Federal Law No. 2 of 2015.

28 Articles 28 and 29 Telecoms Law; and Articles 2(1) and 3(1) NMC Resolution No. (7) of 2008.

29 Resolution No. 8 of 2009 Regarding the Approval of Acquisition Fees and Licensing Applications.

30 Under the Telecoms Law, the Executive Order and each licence. Note, the blanket prohibition on assigning spectrum authorisations under Article 5.5 of the Radiocommunications Policy.

31 Under each provider's licence, e.g., Article 3.4.2 of the Emirates Integrated (du) licence.

32 TRA Regulatory Policy on Voice over internet Protocol. Version 2.0 issued on 30 December 2009.

33 However, licence holders Etisalat and du have both recently introduced their own VOIP-based apps, BOTIM and C'ME as part of their unlimited voice and video call services. It is also important to note that Enterprise VoIP solutions, such as Microsoft's Teams are not blocked when used within a closed network.

34 Article 13 of the Telecoms Law.

35 ibid., Article 14.

36 Regulatory Policy on Price Control version 2.1 issued 23 September 2008.

37 Paragraph 3.1 of the 2008 Regulatory Policy on Pricing.

38 Regulatory Policy and Procedure, Price Control, Version 1.0 issued 28 June 2017.

39 ibid., Article 4.1.

40 Public Telecommunication Licences No.1 of 2006 and No. 2 of 2006 respectively.

41 Regulatory Policy on interconnect Pricing. Version 1.5 issued on 15 December 2010.

42 Available on the TRA website: https://www.tra.gov.ae/en/open-data/interconnection-prices.aspx.

43 Whether they are required to comply depends on whether they have market power (as defined in the TRA's Instructions on Cost Accounting, Accounting Separation and LRIC Modeling, Version 3.0 dated 14 July 2010).

44 In 2017, the principal reason why content was blocked was because it contradicted the ethics and morals of the UAE: https://www.tra.gov.ae/userfiles/assets/KK8LZjJGR1.pdf.

45 Version 1.0 issued 30 December 2009.

46 ibid., Article 5.2.

47 Article 9 of DIFC Law No.1 of 2007 (the Data Protection Law) as amended by DIFC Laws Amendment Law, DIFC Law No. 1 of 2018.

48 Section 2 of ADGM Data Protection Regulations 2015.

49 Federal Decree-Law No. 5/2012 on combating cybercrimes as amended. On 13 August 2018, HH Shaikh Khalifa Bin Zayed Al Nahyan approved Decision No. 2 of 2018 with regard to the amendment and replacement of Articles 26, 28 and 42 of the Cyber Crimes Law. Not published at the time of writing, we understand that this decision will increase the fines and penalties of imprisonment for establishing, managing, running a website or publishing information in favour of a terrorist group or that affects national security.

50 Article 31 of the Constitution confirms the right to privacy of communications.

51 DIFC, 'DIFC Announces Enactment of Amendment Law 2018 and Amendments to Data Protection Regulations', https://www.difc.ae/newsroom/news/difc-announces-enactment-amendment-law-2018-and-amendments-data-protection-regulations/. See also footnote 47.

52 Generally accepted to mean any personal information about an individual, including any photographs where an individual or their belongings are identifiable: Section 379.

53 Supra notes 41 and 42.

54 http://www.esafesociety.org/en/why-e-safe/.

55 Federal Law No. 3 of 2016 on child rights (Wadeema's Law).

56 ibid., Article 29.

57 Federal Decree-Law No.5 of 2012 on combatting IT crimes (the Cybercrimes Law), as amended by Federal Decree Law No. 2 of 2018 (the Amending Decree).

58 This would encompass the use of cookies and other tracking technologies without consent.

59 Spectrum Allocation and Assignment Regulations version 1.0 issued 30 December 2009.

60 Frequency Spectrum Fees version 3.0 issued 7 January 2016.

61 TRA Annual Report 2014, Telecommunications Sector.

62 TRA Annual Report 2013, Spectrum Affairs.

63 ibid., 57.

64 TRA press release: TRA Launches the 5G in the UAE, 23 December 2017.

65 Khaleej Times: https://www.khaleejtimes.com/technology/5g-to-create-19b-subscriptions-by-2024-11.

66 Article 2.4 of the Spectrum Allocation and Assignment Regulations version 1.0 issued 30 December 2009.

67 See Article 2.2 of the TRA Regulations on the Use of 2.4GHz and 5.8GHz bands for WLAN and RLAN: version 1.0, issued on 5 August 2009 (WLAN Regulations).

68 TRA Internet Access Management Regulatory Policy (Version 1.0) issued on 19 April 2017 (the IAM policy).

69 For statistics on blocked content, see www.tra.gov.ae/userfiles/assets/KK8LZjJGR1.pdf.

70 Comprising representatives from the Ministry of Interior, TRA and National Electronic Security Authority.

71 Article 372 deals with publicity that exposes the victim to public hatred or contempt and Article 373 deals with a false accusation that dishonours or discredits the victim in the public eye.

72 MENA Pay TV & Online Subscription Video Market Monitor, IHS Markit, 2018.

73 ibid.

74 International Telecommunications Union, Measuring the Information Society Report 2017 https://www.itu.int/en/ITU-D/Statistics/Documents/publications/misr2017/MISR2017_Volume1.pdf.

75 Growth in Pay TV and OTT Video Services Paving Way for Hybrid TV Viewing, Frost & Sullivan, 2017.

76 Federal Law No.2 of 2019 On the Use of the Information and Communication Technology (ICT) in Health Fields, issued on 06 February 2019.

77 Forbes: Uber Acquires Careem for $3.1 Billion as the Middle East Startup Pushes to Become a Super App, https://www.forbes.com/sites/michelleevans1/2019/03/26/meet-careem-ubers-3-1-billion-new-acquisition-in-the-middle-east/#39f7f00c1e3c.

78 Khaleej Times: Sheikh Mohammed reacts to Uber-Careem deal, https://www.khaleejtimes.com/nation/dubai/sheikh-mohammed-reacts-to-uber-careem-deal-12.

79 MenaBytes: Qatar blocks Uber's acquisition of Careem in the country, https://www.menabytes.com/qatar-blocks-uber-careem-deal/.

80 Gulf News: Abu Dhabi launches Hub71 that brings together start-ups, global powerhouses, including Microsoft, https://gulfnews.com/business/abu-dhabi-launches-hub71-that-brings-together-tech-start-ups-global-powerhouses-including-microsoft-1.1553408162860.

81 Gulf News: Cabinet clears 10 year artificial intelligence strategy, https://gulfnews.com/uae/cabinet-clears-

82 Microsoft: Microsoft Cloud datacenter regions now available in the UAE to help fuel Middle East's future economic ambitions, https://news.microsoft.com/en-xm/2019/06/19/microsoft-cloud-datacenter-regions-now-available-in-the-uae-to-help-fuel-the-middle-easts-future-economic-ambitions/.

83 AWS: Now Open – AWS Middle East (Bahrain), https://aws.amazon.com/blogs/aws/now-open-aws-middle-east-bahrain/.

84 Dubai Law No. 26 of 2015 on the Regulation of Data Dissemination and Exchange in the Emirate of Dubai.

85 Any data related to the Emirate of Dubai and available to data providers.