Overview Of Qatar's New Law Regulation Of Travel Offices And Air Freight Offices

Overview of Qatar's New Law Regulation of Travel Offices and Air Freight Offices
Law No. 3 of 2025 has introduced a significant regulatory framework for Travel and Air Freight Offices (Law), and repeals law No. 26 of 2006, law No. 6 of 2010, as well as any provisions that conflict with its provisions.

Key Definitions

1. Travel offices are defined as entities engaged in (i) booking and selling flight tickets, (ii) providing services related to travel and the air transportation of baggage, (iii) as well as any other activities determined by a decision of the Director of the Qatar Civil Aviation Authority (Authority).
2. Air Freight offices are defined as entities engaged in providing services related to (i) the air transportation of goods and baggage, (ii) the transport of hazardous materials by air (subject to special approval), in addition to any other activities specified by a decision of the Director of the Authority.
   (Articles 2 of the Law)
3. Hazardous materials are defined as any goods or substances that may endanger the health, safety, property, or the environment. The classification and handling of such materials shall be in accordance with the instructions issued by the International Civil Aviation Organization (Article 1 of the Law)

Key Highlights

1. Pursuant to Article 3 of the Law, no Travel or Air Freight Office may operate in the State of Qatar without first obtaining a license from the competent department at the Authority. To be eligible for such a license, the Travel and/or Air Freight Office must satisfy the following requirements:
   1. The applicant must be a company duly registered in accordance with the provisions of the Commercial Companies Law of the State of Qatar, with its stated activities as travel and/or Air Freight activities.
   2. Secure an appropriate premises suitable for conducting the licensed activities (in accordance with Article 12 of the Law, following approval from the relevant department and the acquisition of any necessary licenses from other authorities, the entity may conduct its activities online without the requirement for a physical premises, provided that such activities are carried out through a website established within the State of Qatar);
   3. Employ a sufficient number of qualified staff with relevant experience in the field;
   4. Provide a bank guarantee in favor of the Authority for the performance of the licensed activities, with the amount and terms of issuance to be determined by a decision of the Director;
   5. Maintain insurance coverage against fire for their warehouses;
   6. Comply with any additional requirements that may be imposed by the Authority.
2. The aforementioned documents must be submitted together with the application form to the competent department at the Authority. The department shall issue a decision regarding the application within thirty (30) days from the date of submission. In the event of a rejection or failure to respond within the prescribed period—which shall be deemed a rejection—the applicant may file an objection with the Director within thirty (30) days from the date of notification of the decision or the lapse of the response period. The Director shall issue a final decision within thirty (30) days from the date of submission of the objection.
3. According to Articles 5 and 7 of the Law, the license shall be issued once all requirements have been fulfilled and the prescribed fees have been paid. The license is valid for a period of one (1) year and may be renewed for an equivalent or different period. A renewal request must be submitted at least thirty (30) days prior to the license's expiration date.
4. Travel and Air Freight Offices may not establish branches within the State of Qatar without obtaining prior approval from the competent department at the Authority and paying the applicable fees, subject to compliance with any conditions specified by a decision issued by the Director.
5. Pursuant to Article 13 and 14 of the Law, the Travel and Air Freight Offices shall comply with the below:
   1. For Travel Offices:
      1. Adhere to international regulations for the booking and sale of travel tickets and related services.
      2. Refrain from making fraudulent bookings or failing to comply with ticket pricing conditions.
      3. Avoid engaging in any activities that are in violation of the terms of the license.
      4. Comply with any obligations established by a decision of the Director.
   2. For Air Freight Offices:
      1. Comply with international regulations for issuing and redemption shipping waybills, as well as pricing for shipping services.
         Inform customers of the air shipping rates.
      2. Avoid engaging in any activities that are in violation of the terms of the license.
      3. Comply with any obligations established by a decision of the Director.
6. According to Article 15 of the Law, no Air Freight Office shall handle hazardous materials without first obtaining a license from the relevant department at the Authority. The office must also comply with the following requirements:
   1. Train at least two employees to handle hazardous materials, with training accredited by the International Air Transport Association.
   2. Ensure that their warehouses comply with international standards and the requirements of the relevant authorities.

Enforcement and Penalties (Articles 22, 23, 25, 26 and 28 of the Law)

1. In the event of non-compliance with the provisions of the Law, the Authority may take the following actions:
   1. Issue a formal notice to the applicant;
   2. Suspend the license for a period of up to three (3) months; in the case of repeated violations, the suspension period may be doubled;
   3. Order the temporary closure of the office for a period not exceeding fifteen (15) days to remedy the violation; if the issue is not resolved within that period, the closure may remain in effect.
2. The license may be revoked in any of the following cases:
   1. If the legal entity/office is dissolved or terminated;
   2. If the license was obtained based on fraudulent information or falsified documents;
   3. If the office engages in activities not authorized under its license;
   4. If any of the conditions listed in Point 1 (Key Highlights) are no longer fulfilled;
   5. If the office fails to commence its activities within six (6) months from the date of license issuance;
   6. If no renewal request is submitted within the prescribed renewal period;
   7. If the license is assigned to another (Such assignment requires the approval of the Authority and may only be granted if the assignee meets all applicable licensing requirements.)
3. The Authority may impose a fine of up to QAR 200,000 on any Air Freight Office for failure to comply with the provisions related to dealing with hazardous materials.
4. A fine of up to QAR 50,000 may be imposed for violations of other applicable laws or regulations.
5. Additionally, the responsible manager of the entity/office may also be subject to such penalties if it is determined that the violations occurred as a result of their failure to fulfill managerial duties.

The new law eliminates the previous requirement mandating a minimum 51% ownership by a Qatari or GCC national. This change now allows for full foreign ownership of the two specified activities. This marks a significant shift in Qatar's investment landscape and warrants emphasis in the alert, as it is likely to attract interest from both existing and prospective investors seeking to establish or restructure their operations in the country.

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