By Alex Hepworth
The UAE’s competition law framework is now complete following the publication of Cabinet Decision No. 59 of 2026, the Implementing Regulation to Federal Decree-Law No. 36 of 2023 on the Regulation of Competition.
While much of the attention has focused on the regulatory implications, the changes are also likely to have an impact on the legal market. As competition law becomes a more prominent part of transaction planning, compliance and risk management, demand for specialist legal expertise is expected to grow.
The Implementing Regulation introduces a more detailed framework for assessing market power, reviewing transactions and enforcing competition rules. Together, these changes move the UAE closer to the approach adopted in more established competition jurisdictions such as the UK and EU.
One of the most significant developments is the expansion of how dominance is assessed. While the familiar 40% market share threshold remains relevant, it is no longer the sole factor considered by the Ministry of Economy. Financial strength, technological advantages, barriers to entry, customer relationships and the ability to operate independently of competitors can now all form part of the assessment. Businesses with market shares below 40% may still be found to hold a dominant position, while those above that threshold cannot assume dominance automatically exists.
The Regulation also provides greater clarity around pricing practices and introduces a fully operational merger control regime. Businesses involved in qualifying transactions must submit detailed filings, provide economic analysis and obtain approval before completion. With review periods potentially extending beyond three months, competition clearance is likely to become a standard consideration in UAE transaction planning.
The Ministry of Economy has also been granted broader investigative powers, including the ability to request information, inspect premises and review electronic records. A formal settlement process has been introduced for certain competition infringements, creating a clearer enforcement framework than previously existed.
The changes will affect far more than a small group of competition specialists. Issues such as pricing, distribution arrangements, acquisitions and compliance are likely to become more prominent considerations for organisations operating in the UAE.
That is expected to create work across multiple legal disciplines, from corporate and regulatory advisory through to investigations, compliance and disputes.
The most immediate impact is likely to be an increase in merger control and competition advisory work. Mandatory filings, transaction risk assessments and regulatory strategy advice are expected to become a routine part of many deals involving UAE operations. Organisations will also require guidance on market power assessments, distribution models, pricing structures and competition compliance programmes.
The changes are also expected to generate more investigations and disputes work. As enforcement activity develops, organisations facing information requests, regulatory reviews or competition complaints will require specialist legal support. The preservation of civil liability following settlements may also create opportunities for follow on litigation and competition related disputes.
Another area to watch is the growing importance of economic analysis. The new framework places greater emphasis on market definition, competitive effects and consumer impact. In more mature competition markets, this has led to closer collaboration between lawyers and economists. The UAE market may follow a similar path, creating opportunities for economic advisory professionals alongside legal practitioners.
The recruitment implications are likely to emerge gradually rather than through a sudden surge in hiring. However, firms with limited competition capability may need to strengthen their teams as demand develops. Competition lawyers, regulatory specialists, investigations practitioners and commercial disputes lawyers are all likely to benefit from the broader range of work generated by the new regime.
Mid-level associates may be particularly well positioned. Competition matters often involve significant project management, regulatory analysis and stakeholder coordination, creating demand for lawyers with the experience to manage complex workstreams. Competition economists and other specialist advisory professionals may also become more visible in the UAE market as firms expand their offerings.
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The new regulations are expected to create demand for competition, regulatory, investigations and disputes talent across the UAE legal market. To discuss hiring plans, team growth or career opportunities in the region, please contact:
Alex Hepworth
Middle East Legal Recruitment alex.hepworth@wearebuchanan.com