Driverless In The UAE, Two Years On: From Roads To Waterways And Beyond

What to Know

• Abu Dhabi issued the MENA region’s first driverless vehicle operating permits in November 2025.
• UAE’s federal traffic law now sets nationwide rules for self-driving vehicle inspection, licensing and testing.
• Ras Al Khaimah passed its own autonomous vehicle law in January 2026, requiring continuous digital monitoring.

When we last reported on autonomous vehicle (AV) regulation in the United Arab Emirates, the centrepiece was Dubai’s Law No. 9 of 2023 On Regulating the Operation of Autonomous Vehicles in the Emirate of Dubai (the Dubai AV Law). That Emirate-level instrument established the licensing architecture, vested wide discretionary powers in Dubai’s Roads and Transport Authority (the RTA) and set a financial penalty for non-compliance, but left the operational detail to be filled in.

Since then, the UAE’s AV regulatory framework has advanced materially and now sits across three layers: (i) a new federal traffic instrument; (ii) a maturing Dubai regime with binding executive regulations; and (iii) a permit-and-oversight regime in Abu Dhabi and a dedicated Emirate-level AV law in Ras Al Khaimah. In parallel, autonomous-mobility regulation is being extended beyond road vehicles into marine and logistics applications. This alert summarises the developments that in-house teams at automotive OEMs, technology providers, fleet operators and infrastructure investors need to be aware of and identifies the compliance touchpoints that are becoming decisive for market entry.

Federal Decree-Law No. 14 of 2024 On Traffic Regulation

On 30 September 2024, the President issued Federal Decree-Law No. 14 of 2024 On Traffic Regulation (the Federal Traffic Law) repealing Federal Law No. 21 of 1995 concerning Traffic and reshaping the federal traffic framework to accommodate self-driving vehicles, electric vehicles and personal mobility devices.

For AV stakeholders, four features of the Federal Traffic Law are material:

• Express federal recognition of self-driving vehicles: The conditions and procedures for inspecting, registering, licensing and renewing self-driving vehicles, and the mechanisms for testing modern vehicle technologies, are to be set by Cabinet decision on the proposal of the Minister of Interior. This is the first federal law to make express provision for self-driving vehicles and establishes that a federal Cabinet instrument will govern AV inspection, registration, licensing and testing, sitting above (and, in due course, intersecting with) the Emirate-level regimes;
• Establishment of the Federal Traffic Council: The Council’s formation, powers and working procedures are to be set by Cabinet decision on the Minister’s proposal. It is likely to be a key inter-Emirate coordinating body, and its early work programme will bear watching for AV stakeholders;
• A general enabling clause for modern technology: Modern technology may be used to achieve traffic safety and to issue violations against vehicles and persons, and each Emirate’s licensing authority must develop the electronic and smart programmes and applications through which licences and permits are submitted. This underpins the digital, data-driven monitoring approach that AV operators will encounter in practice; and
• Executive Regulations still to come: The Cabinet must issue Executive Regulations within six months of the law’s entry into force, on the Minister’s proposal, with prior resolutions remaining in force so far as not inconsistent. Those Executive Regulations, together with the accompanying Cabinet decision, are the two federal instruments that OEMs and technology providers should monitor most closely: they will fix the federal parameters for AV inspection, registration, licensing and testing with which the Emirate regimes must interoperate.

Dubai: Executive Regulations Under the Dubai AV Law

In November 2025, Dubai’s RTA adopted Administrative Resolution No. 939 of 2025 Issuing the Implementing Bylaw of the Dubai AV Law (the Executive Regulations).

The Executive Regulations:

• Define six AV categories: (i) light autonomous vehicles for passengers or freight (up to 13 seats); (ii) heavy autonomous freight vehicles; (iii) light public autonomous buses (14-26 passengers); (iv) heavy public autonomous buses (26+ passengers); (v) light and heavy equipment (wheeled or non-wheeled); and (vi) self-driving motorcycles;
• Set eight licensing/renewal conditions and seven technical and operational approval criteria: including: (i) a manufacturer’s certificate confirming successful road trials in the country of origin or another approved jurisdiction; (ii) evidence of conformity with relevant UAE or Gulf standards; and (iii) operational tests conducted in Dubai demonstrating safety under local climatic conditions, with trial data shared with the RTA and any identified issues addressed to the RTA’s satisfaction;
• Impose 14 obligations on operators and agents: (i) vehicles may only be operated within designated lanes and zones; (ii) operators must regain control of the vehicle without delay in the event of a malfunction or loss of control; (iii) an adult must be present when children under 16 are on board; and (iv) operators must maintain an integrated electronic system capturing vehicle movements, service and maintenance history, repairs, faults and accidents. Records may not be altered or deleted without prior RTA approval. Timely and secure software updates are mandatory. Agents may not activate autonomous systems without prior RTA approval and must immediately disable them if a public-safety issue arises;
• Set three security and safety standards: (i) a system for communication with the operator in emergencies (including any malfunction of the vehicle); (ii) a system for alerting the operator to respond to passenger emergencies; and (iii) adherence to any additional requirements set out in the RTA-approved operational and technical manual for the vehicle; and
• Impose infrastructure conditions: covering: (i) traffic safety measures; (ii) electronic systems capable of communicating with vehicles; and (iii) compatibility with signage, road markings, signals and charging stations, with a requirement that infrastructure accommodate future technological developments.

These Executive Regulations sit under the Dubai AV Law, which continues to apply across Dubai (including its free zones and the Dubai International Financial Centre) and, as previously reported, embeds a strict operator civil liability regime, with recourse against the actual wrongdoer, and the AED 500–AED 50,000 administrative fine band. Dubai’s regime has shifted from a principles plus RTA discretion model to an evidence-based compliance framework in which safety dossiers, local operational testing and continuously maintained electronic records are the compliance currency.

Abu Dhabi: A Permit-and-Oversight Regime With Real-time Digital Monitoring

Abu Dhabi has taken a structurally different approach. Rather than legislating a standalone AV statute, it has built a permit-and-oversight regime administered by the Integrated Transport Centre (Abu Dhabi Mobility), under the supervision of the Smart and Autonomous Systems Council (SASC) and in coordination with the UAE Regulations Lab at the General Secretariat of the Cabinet.

In November 2025, Abu Dhabi Mobility issued the first two operating permits for the commercial operation of fully driverless, Level 4 autonomous vehicles, the first such permits in the MENA region. Two features of the regime are especially relevant for OEMs and technology providers. First, permits are granted only after completion of all safety and operational readiness requirements and of rigorous performance, sensor and traffic-response testing in Abu Dhabi. Second, Abu Dhabi Mobility monitors vehicle movements and operations in real time through a dedicated digital platform that logs incidents and violations, enabling live oversight against permit conditions.

For OEMs and technology providers, this means Abu Dhabi expects continuous, connected compliance rather than periodic reporting: telemetry, incident logs and violation data flow directly to the regulator.

Ras Al Khaimah: A New Emirate-level AV Law

In January 2026, Ras Al Khaimah issued Law No. 1 of 2026 on the operation of autonomous vehicles, designating the Ras Al Khaimah Transport Authority (RAKTA) as competent regulator. The law provides for continuous digital monitoring, periodic reporting, data governance and cybersecurity oversight, and defines the responsibilities of AV operators and users. It codifies specific public-safety features, including automatic transition to a safe mode where autonomous operation cannot continue, connectivity with secure control centres, and transparent operational and incident records. It also embeds accessibility and community-awareness obligations.

RAKTA is empowered to issue implementing decisions; the technical standards and monitoring protocols under those decisions will determine the practical timetable for scaling AV activity in the Emirate.

Beyond Road Vehicles: Autonomous Marine and Logistics

Autonomous-mobility regulation in the UAE is also spreading beyond road vehicles.

In Abu Dhabi, Administrative Decision No. 17 of 2026 (issued by the Department of Municipalities and Transport under SASC supervision) introduced the Manual Requirements and Controls for Testing Autonomous Marine Crafts. The decision establishes a dedicated regime for testing autonomous and remotely operated small marine vessels in Abu Dhabi waters, centred on a mandatory permitting system, obligations for permit applicants and vessel operators, procedures to ensure safe testing without disrupting existing maritime operations, and specific requirements as to insurance cover and cybersecurity. It builds on Administrative Decision No. 69 of 2025, which set broader rules on maritime safety, environmental protection and operational responsibilities in Abu Dhabi’s waterways.

In parallel, Dubai has issued frameworks for autonomous heavy vehicles and logistics routes, aligned with the Dubai Commercial and Logistics Land Transport Strategy 2030. Together with the autonomous marine developments, this shows that the UAE’s AV framework is being extended across modalities, and OEMs and technology providers with logistics, freight or marine platforms should not treat AV regulation as a passenger-car issue alone.

Practical Implications for OEMs and Technology Stakeholders

In our view, six compliance themes now cut across the UAE’s AV regime and warrant attention in every AV deployment plan:

• Federal–Emirate interoperability: The Cabinet decision and Executive Regulations anticipated by the Federal Traffic Law will fix the federal parameters for AV inspection, licensing and testing. Emirate-level licences and permits will need to sit consistently with those parameters. Structuring a deployment as Dubai-only or Abu Dhabi-only is no longer sufficient;
• Evidence-based safety dossiers: Dubai’s Executive Regulations, Abu Dhabi’s permit regime and RAK’s law all require documented testing, certifications and operational readiness. Foreign testing and certification alone is not sufficient for commercial operation in Dubai, with local operational testing being a mandatory step;
• Data localisation, retention and integrity: Operators must maintain integrated, secure electronic records of vehicle movements, maintenance, repairs, faults and incidents. In Dubai, those records may not be altered or deleted without prior RTA approval. In Abu Dhabi, telemetry flows to the regulator’s live-monitoring platform and in RAK, the law expressly requires transparent operational and incident records. Data governance and record-integrity controls should be designed in from the outset;
• Cybersecurity and secure software updates: Timely, secure software updates are mandatory in Dubai; cybersecurity is expressly required under both the RAK law and the Abu Dhabi marine-craft framework. Over-the-air update governance and incident-response protocols will need to be regulator-ready;
• Insurance and liability: The Federal Traffic Law bars insurance policies from restricting cover for civil liability arising from vehicle-caused death, injury or damage. The Dubai AV Law imposes strict operator liability with recourse against the actual wrongdoer. Insurance placements and contractual risk allocation between OEM, technology provider, fleet operator and platform partner need to reflect both layers; and
• Continuous compliance, not one-off licensing: Real-time monitoring, mandatory software updates, ongoing performance standards published on regulator websites and evolving executive regulations mean AV compliance in the UAE is a continuous operating discipline, not a one-off licensing exercise.

Looking Ahead

The direction of travel is unmistakable. The UAE is moving from a jurisdiction of aspirational smart-mobility policies to one with substantive, enforceable and increasingly harmonised regulatory frameworks. The Federal Traffic Law’s Executive Regulations and Cabinet decision on self-driving vehicles are the near-term instruments to watch, together with implementing decisions under the RAK law, further RTA manuals under the Dubai Executive Regulations, and the phased extension of AV regulation into logistics and marine applications.

Regulatory certainty at this level tends to be a competitive advantage for jurisdictions seeking to attract AV investment. OEMs, technology providers and infrastructure investors correspondingly need to engage early and structure deployments so that federal, Emirate and modality-specific requirements are met in an integrated way, not retrofitted post-launch.