Why 70% of companies in the UAE's advertising, healthcare, education, and online services sectors are unknowingly violating licensing requirements

About a third of all companies in the UAE violate their trade license requirements by engaging in activities other than those specified, considering trade codes merely a formality. While such disregard might go unnoticed in some countries, in the UAE it is illegal.

The consequences can be varied: account blocking, free zone audits, fines from the Media Council (the government body overseeing all advertising and media activities in the UAE, including online) or the KHDA (Knowledge and Human Development Authority in Dubai), blocking of advertising accounts in Meta and Google, and others. For example, more than 55% of AML blockings of corporate accounts at Emirates NBD, a well-known local bank, were due to discrepancies between the company's license and transactions. Therefore, your actual business activities must strictly correspond with the documents. International law firm Antwort Law will discuss such situations in more detail in this article.

Few entrepreneurs typically undergo a full system compliance audit before starting operations, so it's important to note that your company's activities may be regulated by several independent agencies:

DED / Freezone Authority oversees licenses and trade codes.

• Media Council, as mentioned above, regulates everything related to advertising.
• MOHAP / DHA regulates medicine, wellness, and consulting.
• KHDA deals with education, training, and coaching.
• Banks check the compliance of their activities with licenses and ongoing transactions.

Based on our experience, we'll list the most common mistakes local companies make, especially in the fields of advertising, medicine, education, and online services.

Mistake №1: Selecting the wrong activity code – often just a guess. For example, IT services are selected, but the company is actually engaged in other regulated activities, such as marketing, advertising, training, medical advice, agency work, or traffic arbitrage. For these activities, the responsible authorities have the right to issue fines:

• DED (Dubai): up to AED 100,000 for unlicensed activity
• Media Council: up to AED 500,000 for illegal advertising
• Freezones: AED 5,000–50,000 + requirement to change the license
• CBUAE (banks): account blocking for mismatch between license and transactions

Mistake №2

Working in the advertising industry without a Media Council permit. In 2023, the Media Council fined more than 3,500 companies for lack of permits alone. Remember that any advertising activity requires an Advertising Permit/license from the Media Council. This includes:

• Advertising management
• Working with bloggers
• Targeting and arbitration
• SMM
• Production and content
• Agency model
• Advertising contracts.

Mistake №3

Violations in medicine and wellness: Many businesses do not consider themselves to be "medical," even though they are, according to UAE law. For example, if a company uses the terms "treatment," "diagnosis," "therapy," "program," or "healing," its activities fall under MOHAP/DHA, as well as:

• Wellness consultations,
• nutrition,
• nutrition recommendations,
• psychological consultations,
• child development,
• online coaching,
• fitness methods.

Mistake №4

Education and training (including online) without permission from the KHDA, the body that regulates:

• online courses,
• trainings,
• educational programs,
• coaching,
• academies and schools.

Mistake №5

Online sales of services require the necessary licenses. This means that if a company:

• sells consultations,
• acts as an intermediary,
• resells services,
• charges a commission,
• works as a promotional agent,

then it will need:

• brokerage activity code,
• commercial mediation,
• management services,
• e-commerce permit,
• or a separate agency license.

Free zones strictly monitor compliance with licenses, but it's worth noting that the rules vary across free zones. For example, the IFZA free zone regularly conducts compliance audits, DMCC has the most stringent auditing and most often requires license adjustments, Meydan requires confirmation of activity upon renewal, and so on.

Antwort Law conducts an in-depth licensing audit, including:

• Analysis of the current license (we compare actual activity and your trade codes)
• Checking all hidden regulatory requirements (such as Media Council → KHDA → MOHAP → DHA → DED → Freezone Authority)
• License adjustments (adding correct codes, removing unnecessary ones)
• Obtaining additional permits (Advertising Permit, Educational Permit, Healthcare Approvals)
• Complete rewriting of bank documents (to ensure the license complies with transactions)
• Compliance support (we prepare Activity Explanation, AML package, and bank documents)

We recommend conducting an audit in advance for the following reasons:

• The first request from the bank can arrive at any time,
• Media Council and KHDA fines arrive unexpectedly,
• Meta and Google require license confirmation,
• Freezones will not renew the license if it is not compliant,
• the bank may permanently close an account for license violations.

We make your business legal, safe, and sustainable. Contact us at Antwort Law and we will check your company today.

Diana Gulevskaya

Head of Office in UAE
Antwort Law