As of 31 March 2025, the UAE has updated its competition law framework under Federal Decree-Law No. 36 of 2023 with key implementing provisions brought into effect by Cabinet Decision No. 3/2025. Pre-merger notification is mandatory for transactions that meet specified thresholds. This applies to mergers, acquisitions, and joint ventures.
A filing is required if either of the following thresholds are met:
- Turnover Threshold: Where the total annual sales of the parties in the “Relevant Market” in the UAE exceeds AED 300 million during the latest fiscal year (approximately USD 81.6 million); or
- Market Share Threshold: Where the total market share of the parties exceeds 40% of the total sales in the “Relevant Market” in the UAE during the last fiscal year.
The updated regime brings the UAE closer to international antitrust norms. Transactions will be reviewed for potential anti-competitive effects before they are allowed to complete.
This development requires greater diligence and lead-time for deal execution. Businesses operating in concentrated markets or engaging in cross-border M&A should factor merger control analysis into their planning.
This development requires greater diligence and lead-time for deal execution. Businesses operating in concentrated markets or engaging in cross-border M&A should factor merger control analysis into their planning.
Get in Touch
For more information on how any of these developments may affect your organisation or your clients, please contact Suneer Kumar, Head of Corporate Practice on suneer@alsuwaidi.ae and Vida Grace Serrano, Corporate Senior Associate on Vida@alsuwaidi.ae.
Alsuwaidi & Company’s corporate team advises on a wide range of matters including regulatory compliance, investment structuring, M&A, employment, and tax strategy. We support multinational and regional businesses across sectors with practical, commercially grounded legal guidance.