UAE Music Licensing Shift: How Businesses Can Prepare Before December 2026

The UAE is moving from a legislative framework for collective management of music rights to a more operational licensing and tariff regime. The UAE Ministry of Economy and Tourism (Ministry) recently issued Version 1.1 of the Collective Management Guide for Music (Guide), which is due to be implemented from 1 December 2026. The Guide provides further detail on how the collective management regime is intended to operate, including tariffs applicable to a range of commercial users of music.

WHAT IS A COLLECTIVE MANAGEMENT ORGANIZATION?

Copyright and neighboring rights in music can involve multiple categories of rights holders, including songwriters, composers, performers, music publishers and producers of sound recordings. Obtaining licenses separately from every relevant rights holder may be impractical for commercial users, while individual rights holders may also find it difficult to license and administer every use of their music directly.

Collective management organizations (CMOs) provide a mechanism through which those rights can be administered collectively, including by licensing uses of protected music, collecting remuneration and distributing it to relevant rights holders. For a business, the practical effect is a more structured route for clearing music rights, with licenses and remuneration administered through the relevant CMO in respect of the rights it represents.

THE UAE FRAMEWORK

The Federal Decree-Law No. 38 of 2021 concerning Copyright and Neighboring Rights (Copyright Law) and Cabinet Resolution No. 47 of 2022 concerning its Executive Regulations (Copyright Regulations) already provide the legislative basis for collective management and establish the framework under which entities may be licensed to carry out collective management activities in the UAE.

The UAE collective management framework is now being put into practice, with Emirates Arts and Music Rights Association and Music Nation operating as CMOs in the UAE.

WHAT DOES THE GUIDE MEAN FOR BUSINESSES?

For commercial users, the key point is straightforward: using protected music in a business environment may give rise to licensing and payment requirements under this framework. The Guide identifies a broad range of commercial users, including restaurants and cafés, retail stores and commercial complexes, shopping centers, gyms and health clubs, hotels, certain aviation services, radio stations, and television channels.

The scope is not limited to businesses whose primary activity is music or entertainment. For example, the Guide expressly notes background music and live performances in restaurants and cafés, as well as music played in retail environments for customers and visitors. Accordingly, music used simply as part of the customer experience may be sufficient to bring a business within the licensing framework.

HOW WILL TARIFFS BE CALCULATED?

There is no single fee for every commercial user. The Ministry’s tariff matrix applies different methodologies according to the relevant sector and the nature and scale of the use.

Restaurants and cafés are generally assessed by seating capacity, with different tariffs for establishments with DJ services or similar entertainment. Retail stores, commercial complexes, shopping centers, and fitness facilities are generally assessed by floor area, while hotel tariffs depend on the hotel’s classification and number of rooms. The Guide also establishes maximum annual collection limits for several categories.

Hospitality and mixed-use businesses should pay particular attention to how separate uses are categorized. The hotel tariff applies to music used within hotel rooms; restaurants, halls, commercial stores and entertainment facilities within a hotel are excluded from that tariff and may fall under their own category-specific tariffs. A single property may therefore involve more than one license or tariff analysis.

ARE THERE EXEMPTIONS?

The Guide identifies certain exemptions from the collection regime, including educational and academic institutions, government entities, uses connected with national occasions, and personal celebrations or events of a non-commercial nature. The Ministry may also exempt additional uses or categories by decision.

EXISTING CONTRACTS REMAIN IMPORTANT

The tariff schedule states that existing contracts and obligations arising from them will continue in accordance with their terms, provided that they do not conflict with applicable UAE laws.

Businesses should therefore review both existing music licenses and commercial contracts that may allocate responsibility for licenses or intellectual property costs, such as hotel management agreements, leases, franchise agreements, venue and event contracts, and entertainment agreements.

For businesses with complex operating structures, the question may therefore be not only whether a fee is payable, but also which entity is responsible for obtaining the license and bearing the cost.

HOW CAN BUSINESSES PREPARE?

Businesses should first understand whether and where, how, and by whom music is being used across their operations. In practice, this should include the following:

1. Map music use: Identify where and how music is used across venues, customer areas, hotel rooms, events, digital or broadcast channels, and other operations.
2. Match each use to the relevant tariff category: Multi-site and mixed-use businesses should avoid assuming that one license or one tariff covers all uses.
3. Review licenses and contracts: Check existing music licensing arrangements and determine which group company, operator, tenant, franchisee, manager, or event counterparty is responsible for obtaining licenses and paying related costs.
4. Confirm coverage and budget for implementation: Assess the licenses likely to be required, the rights and repertoire covered, applicable tariff caps, and any potential duplication before fees begin to be collected in December 2026.

This assessment may be relatively straightforward for a single venue, but more complex for hotel groups, mall operators, franchise networks, and mixed-use developments where different uses of music may fall within different tariff categories or involve different contracting entities.

A targeted review ahead of 1 December 2026 can help businesses identify the applicable categories, understand their potential exposure, and avoid compliance gaps and unnecessary duplication of licensing costs.

Associate Shamma Biny Sied contributed to this LawFlash.