United Arab Emirates: Health Insurance Regulations and Technology in the Middle East

Last Updated: 17 October 2016
Article by Simon Isgar

Dubai Health Authority's Smart developments to guarantee a satisfied City

In this publication, we address how Dubai is leading the way in the application of technology to its healthcare insurance system and how the health insurance law is developing around these initiatives.  In addition, we provide a general update on the proposed training requirements for those involved with selling health insurance in Dubai.

Since 2013, the Dubai Health Authority ("DHA"), the healthcare regulator for the Emirate of Dubai, has regularly updated  the processes involved in,  and significantly developed the laws and regulations for, the provision of healthcare in Dubai.  These changes are in line with "The Smart Dubai Initiative", formally undertaken in March 2014, which aims to establish Dubai as the "smartest" city by 2017.  The vision of the initiative "is to make Dubai the happiest city on Earth" and its mission is "to create happiness, by embracing technology innovation".

Mandatory Health Insurance Coverage

The DHA aims to provide an accessible, effective and integrated healthcare system, to protect public health and improve the quality of life within Dubai.  The DHA's mission is to ensure access to health services, maintain and improve the quality of those services, improve the health status of nationals, residents and visitors and oversee a dynamic, efficient and innovative health sector.

To further that aim, in 2013, Dubai issued Health Insurance Law (No. 11 of 2013) (the "Law") concerning health insurance in the Emirate of Dubai.  The Law stipulates that it is mandatory for every person on a Dubai residence visa to be provided with a basic health insurance policy, which is compliant with the DHA rules, regulations and guidelines.  The deadline for full compliance was 30 June 2016.

It also establishes various obligations on Employers, Sponsors, Beneficiaries, Medical Claims Administration Companies, Health Services Providers, Insurance Brokers and Insurance Companies.  For example, Insurers must provide their members with policies containing the minimum benefits set out in the Basic Medical Insurance Package Benefits Schedule. 

It was anticipated that the Law would be followed by the issue of a General Circular and Executive Regulations, which would detail any penalties and fines in respect of breaches and the enforcement of the same.  General Circular No. 5 of 2014 (GC 05/2014) in respect of the DHA's approach to enforcement of fines and penalties was published on 18 November 2014. 

After the publication of GC 05/2014, the DHA initially took a supportive approach to non-compliance, in order to encourage stakeholders to comply.  However, on 4 April 2016, Executive Council Resolution No (7) of 2016 (the "Resolution") was published in issue 398 of the Dubai Gazette and it is clear from the Resolution, that the DHA will now look to take punitive actions against those stakeholders that violate any of the regulatory obligations associated with the Law in order to protect residents of Dubai and uphold their rights.  The Resolution was effective from the date of publication.  It deals with the aspects of enforcement and provides further clarity on what fines health insurers in the Dubai market might be vulnerable to and completes another stage in the implementation of the mandatory health insurance scheme for residents of Dubai.

Two tables are Annexed to the Resolution.  Table No. (1) outlines relevant fees payable for the provision of health insurance services, including fees for obtaining and renewing permits for insurance firms, insurance brokers, claim management companies, hospitals, polyclinics and specialised clinics, pharmacies, laboratories, radiology and analysis centres and other related companies.

Table No. (2), lists 56 violations with a specified fine for each.  The Resolution stipulates that offenders who repeat an offence within one year of the date of the first fine will be charged double the fine up to a maximum of AED 500,000.  In addition to levying fines, the DHA and Dubai Healthcare City Authority ("DHCA") have the power to take other actions, including the issuance of warnings, suspension from providing health insurance related services in Dubai for up to two years, and revoking licenses.  A stakeholder that has its license revoked is required to publish two notifications in a local Arabic and English language newspaper.  Failure to do so can result in the company incurring a fine of up to AED 150,000.  The Resolution further stipulates that an "employer or sponsor not engaging the persons they are required to engage in health insurance or engaging them below basic coverage at the time set by the government in this concern" will be fined "AED 500 per delay month, and a part of month shall be a month".

Grace Period for Violations

The DHA announced in June 2016, that the original 30 June 2016 deadline for compliance with the Law was delayed until the "end of the year" for the category of "non-employees" and those they sponsor as dependents.  The category of "Non-employees" includes individual sponsors, their dependents and their employees such as maids and cooks. 

The DHA have also confirmed they will be organising workshops and roadshows, where insurance companies who have been shortlisted to provide the basic insurance package will be invited to meet the public to ease the mandatory health insurance process further.

The announcement provides extra time for sponsors and employers in Dubai to comply with the Law.  However, the DHA continues to urge everyone to abide by the Law as soon as possible, as it aims to protect not only the dependents, but also the sponsors, from against incurring high medical costs due to illness. 

All stakeholders involved with health insurance in Dubai, including insurance companies, should make sure that they have completed a full legal and compliance audit of their legal obligations.  For example, some insurers may not be providing the correct level of health insurance coverage required by the Law, which requires that all Dubai residents must have a level of health insurance that meets or exceeds minimum benefits stipulated by DHA. These benefits form what is known as the Essential Benefits Plan ("EBP").

In addition, international private medical insurers that use primary fronting insurers as a partner to write their medical products locally in Dubai should ensure that they engage with those partners in order to avoid any violations and consequent reputational risks.   

Mandatory Insurance Exams

In order to ensure residents of Dubai are getting adequate and up to date advice in relation to health insurance, the DHA is introducing a new process, which is aimed solely at insurers and brokers selling health insurance.  For Insurers to provide medical insurance in Dubai, all employees involved in the selling and marketing of medical insurance, at any level, will have to sit mandatory insurance examinations.  The examinations will be part of the updated Permitted Health Insurance Representative's process and as this is currently being changed from its original plan, the deadline is currently uncertain, but it is believed that all employees will need to have completed and passed the examinations by August 2017.

While the content of the examinations is still in the process of being finalized, it is suggested that employees will be required to sit a one-off examination to be licensed and one for CPD each year, both of which will be multiple choice consisting of 75 questions.  An online system will be created by the DHA in order for employees to register for and sit the examinations.  The results will be provided to the employee on the same day.

These will be Level 4 qualifications, which is the same level as the Chartered Insurance Institute examinations in the United Kingdom.  There will be two categories of examinations, entry level and advanced level.

The syllabus is yet to be finalised and approved by the DHA.  It is anticipated that it will cover a variety of subjects, including:

  1. Basic Principles of Insurance and Regulations;
  2. Private Health Insurance Coverage (self-funded, exclusions, basic terms & conditions) (approximately 10% of syllabus);
  3. The Market for Health Insurance (approximately 25% of syllabus);
  4. Health Insurance Regulation in the United Arab Emirates;
  5. Main factors affecting Underwriting in Health Insurance (approximately 10% of syllabus);
  6. Claims Processing;
  7. Fraud, Waste and Abuse;
  8. Conduct of business and professional conduct.

Online Portal to purchase Health Insurance

As we state above, the mission of the Dubai Smart City Initiative is to create happiness by embracing technology innovation.

The DHA is already on board when it comes to embracing technology, as can be seen by its implementation of the online health insurance claims system - ipromes.eclaimslink.ae - in 2012.

On 13 July 2015, the DHA published General Circular 04/2015, which requested expressions of interest from licensed health insurers in "Project Full Sweep".  Since the implementation of the Law, there has been extra demand for health insurance in Dubai. Project Full Sweep will help the DHA expedite the process, by providing the public access to an online portal that will allow them to purchase health insurance easily from a selection of pre-underwritten products from DHA-approved insurers.  The products will cater to both individuals and groups, depending on the insurer. This model is similar to current health exchange models in the USA and Ireland.

The deadline for expressions of interest was 27 July 2015.  However, insurers are still expressing interest on a regular basis. The project is still in its development stages and the DHA is working on minor issues to ensure the portal is 100% "bug" free and ready for operation once it is live.  The portal will be accessible via the community marketplace at www.isahd.ae and will offer consumers the ability to purchase health insurance plans in the name of the employer sponsors (for employees) or individual sponsors (for spouses, dependents, domestic workers). Participating insurers are limited to a specific range of underwriting questions.  Satisfactory answers will allow the applicant to purchase immediate cover without further underwriting.  At this stage, the DHA envisages these questions being limited to age, gender, number of insured lives, occupation, height and weight and pre-existing conditions.  The insurer must have certain information available on or via the portal, including: (i) a rating engine, which will allow the applicant to view the cost of the insurance plan; (ii) full product details and policy documents (which must be legally compliant); (iii) an online payment facility; and (iv) a function enabling policy schedules and wordings to be downloaded or delivered by email.  The portal will automatically update the DHA Member Register, which contains insurance related details, collected from insurance companies, about the insured population in Dubai. 

All polices on the portal must meet the EBP requirements and the decision to include an insurer on the portal will be taken by the DHA, and will depend upon whether or not the product offered meets the objective of allowing the target audience to access affordable online health insurance cover in a simple and efficient manner.


There have been, and will continue to be, significant developments in health insurance laws and regulations in Dubai, reflecting and embracing the use of technology.  It is anticipated that this may serve as a model for other GCC countries.  All stakeholders in the sector should ensure they keep themselves updated with legal and technological developments, or they may find themselves shut out of a potentially lucrative, and growing, market. 

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

In association with
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement

Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of www.mondaq.com

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at enquiries@mondaq.com.

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.