UAE Competition Law: Filing Fees Announced

What to Know

• The UAE issued Cabinet Decision No. 105 of 2026, setting official fees for competition law filings.
• The fees decision takes effect on 29 July 2026, a day before the implementing regulation.
• Merger clearance fees are 0.02% of participants’ annual sales, capped at AED 150,000.

Background

In our recent updates, we summarised the key changes introduced by Federal Decree-Law No. 36 of 2023 on the Regulation of Competition (the New Law), the notification thresholds established by Cabinet Decision No. 3 of 2025 (the Threshold Decision) under the New Law and the detailed procedural framework introduced by Cabinet Decision No. 59 of 2026 on the Implementing Regulation of the New Law (the Implementing Regulation). We also covered the temporary exemption for cooperation on essential goods and services introduced by Ministerial Decision No. 96 of 2026.

The UAE Federal Cabinet has now issued Cabinet Decision No. 105 of 2026 on Fees Prescribed for the Implementation of the New Law (the Fees Decision), establishing for the first time the official fees payable in respect of competition filings and requests made under the New Law. The Fees Decision was signed on 12 June 2026 and published in Official Gazette No. 826 on 29 June 2026. It comes into force thirty (30) days after publication, i.e. on 29 July 2026.

Prescribed Fees

The Fees Decision prescribes the following fees:

Observations

The publication of the Fees Decision fills an important operational gap in the UAE’s competition law framework. As noted in our update on the Implementing Regulation, the documentary requirements for Economic Concentration applications include proof of payment of the applicable filing fee; the quantum of which is now confirmed. Several aspects of the fee schedule merit attention:

• Economic Concentration fee: the filing fee for merger clearance requests is calculated as a percentage of the total annual sales of all establishments participating in the concentration (0.02 percent), subject to a cap of AED 150,000. This turnover-based approach means that the fee scales with the size of the transaction parties but is capped at a level that is unlikely to present a material cost barrier even for large transactions. Deal teams should factor this fee into their transaction budgets alongside the other costs of the filing process, including the required audited financial statements for the last three (3) fiscal years and the comprehensive economic report described in our earlier update on the Implementing Regulation;

• Exemption request fees: a flat fee of AED 5,000 applies uniformly to exemption requests under Articles 5 (restrictive agreements), 6 (dominant position), 7 (economic dependency) and 8 (price reduction) of the New Law. The uniformity and relatively modest level of the fee should encourage Undertakings to seek the certainty of a formal exemption decision where there is any doubt as to whether an arrangement requires one;

• Objection fee: the fee for objecting to an Economic Concentration is AED 1,500. As noted in our update on the Implementing Regulation, any Interested Party may file a reasoned objection to an Economic Concentration within fifteen (15) working days of the MOE publishing basic information on its website. The low level of the objection fee may lower the threshold for third-party challenges, and deal teams should factor this into their transaction timetables; and

• Grievance fee: the fee of AED 500 for filing a grievance against decisions issued under the New Law is refundable if the grievance is accepted. The refundability of this fee offers a degree of comfort to parties considering a challenge to a Ministerial decision.

Timing

The Fees Decision comes into force on 29 July 2026, one day before the Implementing
Regulation takes effect on 30 July 2026. From that date, the full procedural framework (including the requirement to submit proof of payment of the filing fee with Economic Concentration applications) will be operational. Businesses contemplating transactions, exemption applications or other filings under the New Law should ensure that they have budgeted for the applicable fees and are prepared to comply with the full documentary requirements from 30 July 2026.

If you would like to discuss how any of these developments may affect your business or proposed transactions, we would be delighted to assist.