MENA legal, regulatory and commercial intelligence
LegalEyes Monthly Brief, September 2026
Full desk. Ten markets. Six topics. All functions.
Run LE-2026-09 · Compiled 30 August 2026 · Every item below has passed the verification gate
The Position In One Paragraph
Two deadlines dominate this cycle and both are closer than they look. In Saudi Arabia the six month grace period on fifty of the sixty nine fully localised administrative support professions lapses in the first week of October, which is shorter than a Saudi national recruitment cycle. In the United Arab Emirates the deadline to appoint an accredited electronic invoicing service provider falls on 30 October, and provider selection, contracting and testing rarely complete inside eight weeks. Two further items are already in breach rather than approaching: the Qatari governance code transition expired on 17 August, and Bahrain has abolished participation partnerships, so any group still holding one should treat it as a remediation item.
This cycle carries 6 items requiring action now, 11 requiring action within the current planning cycle, and 11 to monitor. 20 further claims were tested and withheld because no official government source or top tier media report confirmed them to the standard this desk applies. Those are listed at the end, because what a briefing declines to tell you is as much a part of its value as what it does.
Act now
The obligation has already bitten, or the time remaining is shorter than the time it realistically takes to comply. These require a named owner today.
Bahrain · Business Partnerships by participation have been abolished and groups still holding one are exposed
Instrument. Decree-Law No. 38 of 2025 amending the Commercial Companies Law of 2001, referred to the Shura Council for review in April 2026.
Who it catches. Existing participation partnerships (Sharikat Al-Mohasa), which the decree-law abolishes. Affected partners should confirm the conversion period and permitted target forms against the gazetted text. The law also extends liability to de facto managers and permits single shareholder closed joint stock companies.
Date. Conversion period believed to have expired. Confirm against the Official Gazette.
Why it is rated red. Any group with a Bahraini participation partnership in its structure chart should treat this as a remediation item, not a diary item.
What the market gets wrong. The conversion window is being described as still open. Entities that have not regularised their position should treat themselves as exposed. The issue date and the length of the conversion period were not confirmed by an official source, so neither is stated here.
Verification. PASS WITH CAVEAT, top tier media (Gulf Daily News), abolition and liability changes confirmed; issue date and conversion period not confirmed. Source: https://www.gdnonline.com/Details/1393058
United Arab Emirates · Marketing Advertiser permit enforcement is live and commissioning organisations must check every advertiser holds a valid permit
Instrument. Federal Decree-Law No. 55 of 2023 regulating media and its implementing Cabinet Resolution, permit deadline extended to 31 January 2026, enforcement from 1 February 2026.
Who it catches. Anyone posting promotional content on social media whether paid, unpaid or in exchange for product, together with the marketing agencies, public relations firms, brands and in house teams commissioning it. Visiting creators require a three month renewable permit, applied for through a licensed local agency.
Date. Enforcement live since 1 February 2026.
Why it is rated red. Permit number capture should be a condition precedent in every influencer contract and purchase order from the next campaign onwards.
What the market gets wrong. The permit is treated as the influencer’s problem. Organisations are expected to verify that any advertiser they work with holds a valid permit. Operating without one attracts AED 10,000 rising to AED 40,000 on repeat, and content standard breaches reach AED 1 million.
Verification. PASS WITH CAVEAT, top tier media (Gulf News), implementing Cabinet Resolution number not confirmed. Sources: https://gulfnews.com/uae/new-uae-law-advertiser-permit-now-mandatory-for-influencers-and-creators-for-social-media-1.500427938 and https://gulfnews.com/uae/uaes-content-creator-licence-deadline-has-been-extended-1.500317517
Qatar · Business Corporate governance code transition period expired on 17 August 2026 with no confirmed extension
Instrument. Qatar Financial Markets Authority Board Decision No. 5 of 2025, published in Official Gazette issue 21 of 17 August 2025.
Who it catches. All companies listed on the Qatar Stock Exchange, main market and venture market alike. Boards require a minimum of three independent directors regardless of board size, with tighter independence and experience criteria.
Date. Expired 17 August 2026.
Why it is rated red. Boards not yet compliant are in breach as at today. Confirm the position with the authority as a priority.
What the market gets wrong. The transition is commonly dated from the 4 August issuance rather than the 17 August gazette publication. The chairman has an express power to extend for further similar periods, but we could not confirm whether it has been exercised, so do not assume an extension.
Verification. PASS, official source (Qatar Financial Markets Authority). Source: https://www.qfma.org.qa/English/Legislation/Legal_decisions/Documents/Governance%20Code%20for%20Listed%20Companies.pdf
United Arab Emirates · Finance Corporate tax return and payment fall due for the financial year ended 31 December 2025
Instrument. Federal Decree-Law No. 47 of 2022, Article 53.
Who it catches. All registered Taxable Persons, including Exempt Persons required to register and claimants of Small Business Relief, who must still file a simplified return. No revenue floor applies to the filing obligation.
Date. 30 September 2026.
Why it is rated red. Thirty one days remain. Return preparation and board sign off typically consume three to four weeks.
What the market gets wrong. Small Business Relief is treated as a filing exemption. It is not. The nine month clock also runs from the period end, so companies with a non December year end have a different date.
Verification. PASS, official source (Federal Tax Authority). Source: https://tax.gov.ae/en/media.centre/news/fta.confirms.taxable.persons.eligible.for.the.small.business.relief.must.submit.simplified.corporate.tax.returns.within.prescribed.legal.deadline.aspx
Saudi Arabia · Hr Six month grace period on fifty of the sixty nine fully localised administrative support professions lapses in early October
Instrument. Ministry of Human Resources and Social Development decision on administrative support professions, effective 5 April 2026.
Who it catches. Private sector establishments with at least one worker in the covered professions. There is no headcount floor and no small enterprise carve out. Covered roles include secretarial, translation, data entry and general administration under the Unified Saudi Occupational Classification.
Date. Approximately 5 October 2026.
Why it is rated red. Thirty six days remain against a Saudi national recruitment cycle that rarely completes inside eight weeks. This is the most urgent human resources item in the region.
What the market gets wrong. This is being diarised as an upcoming change. Nineteen professions took effect on 5 April 2026 and are already live. The exposure now is the fifty professions whose grace period expires in early October.
Verification. PASS, official source (Saudi Press Agency). Source: https://www.spa.gov.sa/en/N2553750
United Arab Emirates · Finance Deadline to appoint an accredited service provider for electronic invoicing extended to 30 October 2026
Instrument. Ministerial Decision No. 244 of 2025, as amended by the Ministry of Finance announcement of 10 May 2026.
Who it catches. Businesses with annual revenue of AED 50 million or more, being Phase 1 of the business to business and business to government electronic invoicing mandate. Business to consumer transactions remain outside scope until the Minister determines otherwise.
Date. 30 October 2026.
Why it is rated red. Sixty one days remain. Provider selection, contracting and integration testing rarely complete inside eight weeks.
What the market gets wrong. Reports that the 1 January 2027 go live moved. It did not. Only the service provider appointment date moved. Phase 2 is also defined by revenue below AED 50 million rather than by a date tranche.
Verification. PASS WITH CAVEAT, official source (Ministry of Finance). Source: https://mof.gov.ae/en/news/ministry-of-finance-announces-targeted-amendments-to-einvoicing-system-decisions/
Act within this planning cycle
Action is required inside the current cycle and can still be completed without disruption. These belong on the next management meeting agenda.
Saudi Arabia · Marketing Individual social media advertising licence is mandatory for any commercial advertisement featuring an influencer
Instrument. Mawthooq licence issued by the General Authority for Media Regulation, in force since 1 October 2022.
Who it catches. Individuals producing advertising content on social media. Applicants must be eighteen or over, Saudi national or resident, and must register every advertising account. Foreign investors must hold at least fifty per cent ownership in a licensed Saudi advertising or marketing firm, so non resident influencers targeting Saudi audiences route through an approved local entity.
Date. In force.
Why it is rated amber. Processing runs to roughly fifteen days, so campaign planning must allow for it.
What the market gets wrong. The licence is frequently called Tarkhees. It is Mawthooq. Tarkhees is the authority’s general licensing portal. The government fee is SAR 15,000 for a three year term and breach exposure is stated at up to SAR 500,000.
Verification. PASS, official source (Saudi government service catalogue). Source: https://www.vco.sa/en/government/detail/259
United Arab Emirates · Hr New Wage Protection System resolution raises the compliance threshold to eighty five per cent and removes the grace period
Instrument. Ministerial Resolution No. 340 of 2026, replacing the previous Wage Protection System rules.
Who it catches. All private sector establishments licensed with the Ministry of Human Resources and Emiratisation.
Date. In force 1 June 2026.
Why it is rated amber. Payroll calendar and treasury funding cycles need to be re baselined.
What the market gets wrong. The old fifteen day payment window mental model persists. Wages for the preceding month are now due on the first day of each month with no grace period, and enforcement escalates to suspension of new work permits from day five.
Verification. PASS WITH CAVEAT, top tier media (Gulf News), repeal of the 2022 resolution not confirmed. Source: https://gulfnews.com/uae/government/uae-sets-monthly-salary-deadline-for-private-sector-from-june-1-1.500544328
Qatar · Finance Global minimum tax registration opened on 2 August 2026 with a three month window and no published calendar date
Instrument. Law No. 22 of 2024 amending Income Tax Law No. 24 of 2018, with Council of Ministers Resolution No. 2 of 2026.
Who it catches. Multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding fiscal years with a constituent entity or joint venture in Qatar. Registration is at group level through a designated local entity.
Date. Protective date 31 October 2026.
Why it is rated amber. First filing for the 2025 fiscal year is due 30 June 2027.
What the market gets wrong. A deadline of 30 November 2026 is circulating widely. It traces to a secondary publication whose own text computes 2 November and then tabulates 30 November anyway. The tax authority has published no calendar date at all, only a three month window from 2 August, which ends on 1 or 2 November depending on how the months are counted. Work to 31 October.
Verification. PASS WITH CAVEAT, official source (General Tax Authority) for the regime; no calendar date published. Source: https://gta.gov.qa/en/media-center/news/general-tax-authority-announces-the-start-of-registration-for-the-global-an
Saudi Arabia · Hr Sports centres and gyms move to fifteen per cent localisation from 18 November 2026
Instrument. Ministry of Human Resources and Social Development decision with the Ministry of Sport, in force 08/06/1448 corresponding to 18 November 2026.
Who it catches. Private sector sports centres and gyms with four or more employees in the twelve covered roles, including sports coach, professional football coach and professional aquatic sports coach.
Date. 18 November 2026.
Why it is rated amber. Eighty days. Sufficient if recruitment begins this month.
What the market gets wrong. The four employee floor is routinely dropped from summaries, which over captures small operators.
Verification. PASS, official source (Ministry of Human Resources and Social Development). Source: https://www.hrsd.gov.sa/en/media-center/news
United Arab Emirates · Finance Domestic minimum top up tax registration opens with a transitional deadline of 30 November 2026
Instrument. Cabinet Decision No. 142 of 2024, with registration timelines under Federal Tax Authority Decision No. 12 of 2026 issued 16 July 2026.
Who it catches. Constituent entities of multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding fiscal years, for financial years starting on or after 1 January 2025.
Date. 30 November 2026.
Why it is rated amber. Ninety two days. Group structure mapping and designation of the filing entity should start now.
What the market gets wrong. The 30 November 2026 date is treated as a universal registration deadline. It is transitional, applying to entities whose fiscal year ended before 30 April 2026. The Cabinet Decision is also 142 of 2024, not a 2025 instrument.
Verification. PASS WITH CAVEAT, official source (Ministry of Finance) for scope; the transitional date rests on Federal Tax Authority Decision No. 12 of 2026. Source: https://mof.gov.ae/en/public-finance/tax/uae-domestic-minimum-top-up-tax/
United Arab Emirates · Hr Second half Emiratisation increment falls due, taking the cumulative target to ten per cent of skilled roles
Instrument. Cabinet Resolution No. 18 of 2022.
Who it catches. Private sector establishments with fifty or more employees. The quota applies to skilled roles only and only Emiratis registered with the General Pension and Social Security Authority and paid through the Wage Protection System count towards it.
Date. 31 December 2026.
Why it is rated amber. Recruitment, offer and onboarding of Emirati talent in skilled roles commonly runs to twelve weeks.
What the market gets wrong. The half year increment is one per cent, not two. The 2026 contribution is AED 9,000 per month per unfilled position, being AED 108,000 annualised, and not the AED 10,000 figure in circulation.
Verification. PASS WITH CAVEAT, official source (Emirates News Agency reporting the ministry). Source: https://www.wam.ae/en/article/hszrh04t-companies-violating-emiratisation-targets-will
Egypt · Sustainability Carbon disclosure deadline for non bank financial institutions extended to 31 December 2026
Instrument. Financial Regulatory Authority Board Decision No. 36 of 2026, gazetted 17 February 2026, as amended by Board Decision No. 115 of 2026, gazetted 17 June 2026.
Who it catches. Companies in non banking financial activities whose issued capital or net equity exceeds EGP 100 million. Note the test is capital or net equity, either limb. Compliance is a condition of continued licensing.
Date. 31 December 2026.
Why it is rated amber. Reporting is limited at this stage to Scope 1 and Scope 2, must be verified by a body registered with the authority, and twenty per cent of emissions must be offset within ninety days of filing through the regulated voluntary carbon market.
What the market gets wrong. The 30 June 2026 deadline is still being quoted. It was superseded three months ago by Decision No. 115 of 2026. The ninety day offset clock now runs from the new filing date.
Verification. PASS, official source (Official Gazette text published by the Financial Regulatory Authority). Source: https://fra.gov.eg/wp-content/uploads/2026/06/alamiria_2026_115.pdf
United Arab Emirates · Business Capital markets regulator reconstituted and entities must regularise their position by 1 January 2027
Instrument. Federal Decree-Law No. 32 of 2025 and Federal Decree-Law No. 33 of 2025, both effective 1 January 2026.
Who it catches. All entities and persons within the capital markets perimeter, including free zone and offshore entities conducting cross border offerings or marketing directed at onshore clients in the United Arab Emirates.
Date. 1 January 2027.
Why it is rated amber. Perimeter analysis for free zone entities marketing onshore should be run this quarter.
What the market gets wrong. This is treated as a rebrand of the Securities and Commodities Authority. The material change is the express extraterritorial reach over firms marketing to onshore clients from a financial free zone or from outside the country. The regularisation deadline is also extendable at the board’s discretion.
Verification. PASS, official source (Capital Market Authority). Source: https://www.uaecma.gov.ae/en/new-cma-law
Saudi Arabia · Legal Data protection enforcement is active with forty eight violation decisions issued
Instrument. Personal Data Protection Law, Royal Decree M/19 of 2021 as amended by Royal Decree M/148 of 2023, fully enforceable since 14 September 2024.
Who it catches. Controllers and processors. Registration on the National Data Governance Platform is mandatory for public entities, controllers whose primary activity involves processing personal data, controllers processing sensitive data, and individuals processing beyond personal or family use. The law provides for administrative fines, which increase for repeat violations.
Date. Enforcement ongoing.
Why it is rated amber. Recurring violation types are processing without lawful basis, marketing without consent and inadequate technical measures.
What the market gets wrong. Vendors sell registration as universal. It is not. A controller that is not a public entity, does not process data as its core business and does not handle sensitive data has no registration obligation. Conversely sensitive data is defined broadly enough to catch most healthcare, human resources, fintech and insurance operators.
Verification. PASS WITH CAVEAT, official source (Saudi Press Agency reporting the Saudi Data and AI Authority), forty eight decisions and violation types confirmed; fine levels and registration scope to be confirmed against the authority’s published rules. Source: https://spa.gov.sa/en/N2489505
Qatar · Hr Non compete periods double to two years but only take effect with ministry approval
Instrument. Law No. 9 of 2026 amending Labour Law No. 14 of 2004.
Who it catches. Private sector employers. Enterprises employing one hundred or more workers must establish joint committees, and further changes to the scope of restraint clauses are reported but await the implementing decisions.
Date. Dates unconfirmed.
Why it is rated amber. Template employment contracts should be updated but restraint clauses should not be relied upon until the approval process is published.
What the market gets wrong. The two year non compete is being treated as self executing. It is conditional on Ministry of Labour approval for which no process has yet been published. The Qatar News Agency reported the law’s issue on 25 June 2026, but no gazette or effective date has been published and none should be quoted.
Verification. PASS WITH CAVEAT, official source (Qatar News Agency) and top tier media (The Peninsula), probation and sector provisions not confirmed. Sources: https://qna.org.qa/en/News-Area/News/2026-6/25/qatar-introduces-major-labor-law-reforms-to-boost-market-efficiency-and-investment-climate and http://thepeninsulaqatar.com/article/12/07/2026/labour-law-amendments-introduce-professional-licensing-flexible-work-and-revised-non-compete-rules
Oman · Hr Every commercial registration must employ at least one Omani, with regularisation triggered by renewal
Instrument. Ministry of Labour directive of 5 May 2025 developed with the Ministry of Commerce, Industry and Investment Promotion.
Who it catches. Establishments that have passed one year since establishment. Firms with ten or more staff have three months from notification to submit an operational hiring plan, firms with fewer than ten employees have six months, and Omani entrepreneurs up to one year, with a three month grace period from official notification.
Date. Rolling on renewal.
Why it is rated amber. Non compliance triggers automatic freezing of new licences through the ministry’s digital system, which is a commercial stoppage rather than a fine.
What the market gets wrong. The fee change is reported as purely punitive. The same instrument gives a thirty per cent discount on expatriate work permit fees to employers meeting their Omanisation rates and doubles charges for those that do not.
Verification. PASS WITH CAVEAT, top tier media (Muscat Daily). Source: https://www.muscatdaily.com/2025/10/26/ministry-of-labour-revises-expat-work-permit-system/
Monitor
Confirmed and relevant, but no action is required this cycle. Carried for the record and for the quarterly board pack.
United Arab Emirates · Marketing Telemarketing rules carry the sharpest penalties of any marketing regulation in the country
Instrument. Cabinet Decision No. 56 of 2024 and Cabinet Decision No. 57 of 2024, effective 27 August 2024.
Who it catches. All companies licensed in the United Arab Emirates including free zone entities. Individual telemarketing without licensing is prohibited.
Date. In force 27 August 2024.
Why it is rated green. Calls are permitted only between nine in the morning and six in the evening on business days.
What the market gets wrong. Marketing teams look to the data protection law for outbound risk. The enforceable exposure is here. Calling a number on the Do Not Call Registry attracts AED 50,000 to AED 150,000, and unauthorised telemarketing AED 75,000 to AED 150,000.
Verification. PASS, official source (Ministry of Economy and Tourism legislation list). Source: https://www.moet.gov.ae/en/consumer-protection-legislations
United Arab Emirates · Legal Merger control filing obligation now bites at AED 300 million of relevant market turnover with a ninety day standstill
Instrument. Federal Decree-Law No. 36 of 2023 and Cabinet Decision No. 3 of 2025, with Executive Regulations issued as Cabinet Decision No. 59 of 2026.
Who it catches. Parties to any economic concentration where combined annual sales in the relevant market in the United Arab Emirates exceed AED 300 million in the last fiscal year, or combined share exceeds forty per cent of the relevant market.
Date. In force sixty days after gazette publication of Cabinet Decision No. 3 of 2025, issued 20 January 2025.
Why it is rated green. Filing is required at least ninety days before completion, and the ninety day review, extendable by forty five days, is a standstill, so it must be built into every deal timetable.
What the market gets wrong. The AED 300 million test is widely published as combined United Arab Emirates turnover. It is relevant market turnover in the United Arab Emirates, which materially changes which deals are caught.
Verification. PASS WITH CAVEAT, official source (Ministry of Economy and Tourism), in force date derived from the sixty day rule. Sources: https://www.moet.gov.ae/en/regulation-of-competition-legislations
United Arab Emirates · Legal New anti money laundering decree law and its executive regulations are both now in force
Instrument. Federal Decree-Law No. 10 of 2025, Official Gazette No. 808 of 30 September 2025, in force 14 October 2025, with executive regulations at Cabinet Resolution No. 134 of 2025 in force 14 December 2025.
Who it catches. Financial institutions, designated non financial businesses and professions, and virtual asset service providers. Fines for legal entities run from AED 5 million to AED 100 million, with personal criminal liability for managers.
Date. In force 14 December 2025.
Why it is rated green. Policies drafted against the 2018 law need refreshing against the proliferation financing provisions.
What the market gets wrong. Commentary still describes the executive regulations as awaited. They were issued as Cabinet Resolution No. 134 of 2025 and took effect on 14 December 2025. The instrument is also a Decree-Law, not a Federal Law.
Verification. PASS, official source (UAE Legislation portal). Source: https://uaelegislation.gov.ae/en/legislations/3857
Qatar · Sustainability Mandatory sustainability reporting under IFRS S1 and S2 commenced on 1 January 2026
Instrument. Qatar Financial Centre Regulatory Authority GENE Corporate Sustainability Reporting and Minor and Technical Amendments Rules 2025, reference RM/2025-1.
Who it catches. All Category A authorised firms mandatorily, being the larger banks and insurers, plus other authorised firms designated by the regulator using size, assets under management, client base and voluntary reporting criteria.
Date. Financial years beginning on or after 1 January 2026.
Why it is rated green. Data collection for the first mandatory period is already running.
What the market gets wrong. Branches of foreign groups assume they must report separately. Group level reports under standards recognised as highly aligned are generally acceptable, with exceptions for entities filing separate branch level financial statements.
Verification. PASS, official source (Qatar Financial Centre Regulatory Authority). Source: https://www.qfcra.com/news/notification-qfc-regulatory-authority-issues-the-gene-corporate-sustainability-reporting-and-minor-and-technical-amendments-rules-2025/
United Arab Emirates · Sustainability Climate change law is in force with no emissions threshold, but implementing decisions remain unissued
Instrument. Federal Decree-Law No. 11 of 2024, Official Gazette No. 782, in force 30 May 2025.
Who it catches. All public and private legal persons and individual enterprises whose operations generate greenhouse gas emissions, mainland and free zone alike. There is no minimum emissions threshold in the federal law. Penalties run from AED 50,000 to AED 2 million, doubling for repeat violation.
Date. Reporting date stated as 30 May 2026.
Why it is rated green. Emissions inventory work is worth starting regardless, because the lead time on assured Scope 1 and 2 data is six months or more.
What the market gets wrong. This is being sold as an operative filing deadline. It is not. No official source yet sets out how filings will be made or verified. Build the inventory, and confirm the filing mechanics with the ministry before diarising a submission.
Verification. PASS WITH CAVEAT, official source (UAE Legislation portal) and top tier media (Khaleej Times), filing mechanics not confirmed. Sources: https://uaelegislation.gov.ae/en/legislations/2558 and https://www.khaleejtimes.com/business/uae-firms-rush-to-meet-climate-law-deadline-as-ai-drives-compliance
Oman · Legal Capital market institutions have until late January 2027 to regularise under the new securities executive regulations
Instrument. Executive Regulations of the Securities Law, published in the Official Gazette of 26 July 2026, in force the following day.
Who it catches. Capital market institutions and entities operating in the securities sector, which must regularise within six months. Licensed banks conducting securities activities have up to three years to transfer those activities into an independent entity, with custody, trust services and underwriting excluded.
Date. Approximately 27 January 2027.
Why it is rated green. Investment banking becomes a regulated activity and a regulatory sandbox is introduced.
What the market gets wrong. Banks are assumed to face the same six month clock. They have a separate three year carve out. The decision number could not be confirmed and should not be cited.
Verification. PASS WITH CAVEAT, top tier media (Muscat Daily). Source: https://www.muscatdaily.com/2026/07/26/fsa-issues-executive-regulation-for-securities/
Saudi Arabia · Finance Electronic invoicing wave twenty five pulls in taxpayers above SAR 187,500 of revenue with integration due 1 February 2027
Instrument. Zakat, Tax and Customs Authority wave twenty five criteria, announced 24 July 2026.
Who it catches. Value added tax registered taxpayers whose value added tax subject revenues exceeded SAR 187,500 in any one of 2022, 2023, 2024 or 2025. The authority notifies targeted taxpayers directly at least six months before the integration date.
Date. 1 February 2027.
Why it is rated green. No wave twenty six had been announced as at 30 August 2026.
What the market gets wrong. The threshold is read as current year turnover. It is any one of the four years, so a business now below SAR 187,500 is still caught if it exceeded the threshold in any of them. The threshold has halved against previous waves, which brings a very large small business population into scope.
Verification. PASS, official source (Zakat, Tax and Customs Authority). Source: https://zatca.gov.sa/en/MediaCenter/News/Pages/Wave25-E-invoicing.aspx
Kuwait · Finance Domestic minimum top up tax applies to calendar year 2025 groups and the first return date is still to be confirmed
Instrument. Decree-Law No. 157 of 2024 with executive regulations at Ministerial Resolution No. 55 of 2025.
Who it catches. Multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding fiscal years operating in Kuwait through entities or permanent establishments. Minimum effective rate fifteen per cent.
Date. To be confirmed against Ministry of Finance guidance.
Why it is rated green. Tax periods begin on 1 January, so groups with calendar year ends are already in scope. Confirm the first return date directly with the Ministry of Finance.
What the market gets wrong. Filing dates are circulating without an official source. Advance payment arrangements should also be confirmed directly with the Ministry of Finance.
Verification. PASS WITH CAVEAT, top tier media (Zawya), filing date and advance payment position not confirmed. Source: https://www.zawya.com/en/economy/policy/kuwait-rolls-out-mne-top-up-tax-mbinjl6w
Saudi Arabia · Business Minimum local content percentages become a condition of benefiting from the mandatory list in government procurement
Instrument. Local Content and Government Procurement Authority decision announced 17 February 2026.
Who it catches. Suppliers seeking to benefit from the mandatory list of national products in government procurement. Phase one covers 233 products from 1 August 2026, including ceramic and porcelain tiles. Phase two from 1 August 2027 adds split air conditioning units, water pumps, water valves, copper wires and various medical devices and supplies.
Date. Phase one live, phase two 1 August 2027.
Why it is rated green. Per product percentages sit on the authority’s own site and were not independently retrievable, so verify the specific percentage before bidding.
What the market gets wrong. Described as a general private sector local content quota. It is a condition of benefiting from the mandatory list in public procurement, which is a narrower but commercially decisive distinction for anyone bidding into government work.
Verification. PASS, official source (Saudi Press Agency). Source: https://www.spa.gov.sa/en/N2514218
Oman · Finance Personal income tax commences on 1 January 2028, not 2027
Instrument. Personal Income Tax Law issued by Royal Decree No. 56/2025.
Who it catches. Individuals whose annual taxable income exceeds OMR 42,000, taxed at five per cent, with deductions and exemptions for education, healthcare, housing, zakat and donations. About ninety nine per cent of the population is unaffected.
Date. 1 January 2028.
Why it is rated green. Watch for the executive regulations, due within one year of gazette publication.
What the market gets wrong. Widely reported as starting in 2027. It is 2028. It is a first for the Gulf Cooperation Council states but applies only above OMR 42,000, which excludes the large majority of earners.
Verification. PASS, official source (Oman Tax Authority). Sources: https://tms.taxoman.gov.om/portal/w/issuance-of-personal-income-tax-pit-law and https://gulfnews.com/business/tax-news/oman-to-impose-first-personal-income-tax-for-high-earners-effective-january-2028-1.500172741
United Arab Emirates · Legal Personal data protection executive regulations remain unissued almost five years after the law
Instrument. Federal Decree-Law No. 45 of 2021, in force 2 January 2022, executive regulations still outstanding.
Who it catches. All controllers and processors on the mainland. The Dubai International Financial Centre and Abu Dhabi Global Market are expressly excluded and operate standalone regimes, so data flows between the mainland and those free zones should be assessed under the cross border transfer rules.
Date. No commencement trigger.
Why it is rated green. The live enforcement risk on outbound marketing in the United Arab Emirates is the telemarketing regime, not the data protection law.
What the market gets wrong. At least one circulating source asserts the executive regulations have been issued with a 1 January 2027 compliance date. No such regulations appear on the official UAE Legislation portal. Anyone briefing a client that mainland compliance has a hard deadline is wrong.
Verification. PASS WITH CAVEAT, official source (UAE Legislation portal and UAE Government portal), absence of executive regulations inferred from no publication on the official portal. Sources: https://uaelegislation.gov.ae/en/legislations/1972 and https://u.ae/en/about-the-uae/digital-uae/data/data-protection-laws
What we did not publish, and why
Every item below is circulating in the market as though it were settled, or rests only on commentary this desk does not cite. Each was tested against the verification standard and failed. They are recorded here so that a subscriber who hears one of these claims from another source knows why this desk has not repeated it, and what would have to happen before it could be.
Bahrain. Bahrain has introduced a ten per cent corporate income tax with effect from 1 January 2027.
Why it was withheld. The law has not been enacted. It was referred to the legislative authorities on 29 December 2025 and shared with the business community in closed consultation on 23 February 2026, but has not been officially released or gazetted. Every substantive term can still change and the intended effective date is itself at risk with roughly four months to run.
Status. Draft only. Do not publish as enacted. Monitor the Legislation and Legal Opinion Commission gazette and the National Bureau for Revenue.
Egypt. Merger control amendments raising thresholds to EGP 2.5 billion domestic and EGP 15 billion worldwide are in force.
Why it was withheld. Parliament approved the bill in late April 2026 but presidential ratification has not occurred and the amendments have not been published in the Official Gazette. They take effect three months after presidential approval, so there is currently no effective date. The threshold figures could not be confirmed from an official source.
Status. Not ratified. Advise clients that the current regime still governs. Monitor the Egyptian Competition Authority and the gazette.
Egypt. The executive regulations to Labour Law No. 14 of 2025 have been issued.
Why it was withheld. No consolidated executive regulation has been issued a year after the law took effect. Egypt appears to be implementing through rolling ministerial decrees instead, the most recent being the general rules for the work organisation bylaw launched on 29 August 2026 for establishments with ten or more workers.
Status. Not issued. Report the ministerial decrees individually as they appear. Do not describe the executive regulations as out.
Oman. Personal data protection grace period expired 5 February 2026 with a forty five day response window, seventy two hour breach notification and mandatory data protection officer.
Why it was withheld. None of these specifics could be verified against an official source or a top tier media report. There is also an unresolved arithmetic problem, in that the executive regulations were gazetted in February 2024, so a transition ending in February 2026 implies a two year period where a one year period would have ended in February 2025.
Status. Unverifiable. Do not publish any part of this item. Commission direct verification against the Ministry of Transport, Communications and Information Technology.
Jordan. Personal Data Protection Law No. 24 of 2023 is in enforcement with twenty four hour notification to individuals and penalties of up to three per cent of annual revenues.
Why it was withheld. Nothing in this item was verified against an official source or a top tier media report. The twenty four hour notification to individuals is unusual enough on its face to warrant direct verification against the Arabic text.
Status. Unverifiable. Do not publish. Verify against the Jordanian Official Gazette and the Ministry of Digital Economy and Entrepreneurship.
United Arab Emirates. The personal data protection executive regulations have been issued with a compliance date of 1 January 2027.
Why it was withheld. False. The executive regulations to Federal Decree-Law No. 45 of 2021 remain unissued as at August 2026. No such regulations appear on the official UAE Legislation portal.
Status. False. Publish the non event as the insight. The absence of a commencement trigger is itself the client relevant fact.
United Arab Emirates. A named federal decree law number establishing the National Media Authority.
Why it was withheld. Four sources report the establishment of the National Media Authority on 18 December 2025 as successor to the Media Council, the National Media Office and the state news agency, but none cites the instrument number or its effective date. The transitional treatment of existing advertiser permits is also unconfirmed.
Status. Number unverified. Report the change without the number. Flag the permit transition question to clients as an open risk.
Saudi Arabia. A standalone Saudi Advertising Law and its implementing regulation are in force.
Why it was withheld. The only public record located is a consultation draft of a consolidated media law merging the Audiovisual Media Law and the Printing and Publication Law. No standalone advertising law was confirmed in force.
Status. Possibly draft. Do not describe a Saudi Advertising Law as a live instrument. The verified instruments are the Audiovisual Media Law and its implementing regulation.
United Arab Emirates. Dubai Land Department Trakheesi advertising permit requirements, fees and fines.
Why it was withheld. The requirement that every property advertisement carries a valid permit number is well established in market practice, but the instrument, fee and fine could not be retrieved from an official source in this pass.
Status. Unverified. Priority verification item for the next cycle. High frequency and high enforcement for any client marketing property.
United Arab Emirates. Ministerial Decisions No. 41 and No. 42 of 2025 on media content monitoring and standards, effective 29 May 2025.
Why it was withheld. Rests on a single unofficial secondary source. The decision numbers and the effective date were not confirmed by an official source.
Status. Single source. Report the content standards, which are separately verified, without citing these two decision numbers.
Qatar. Law No. 9 of 2026 has a stated effective date.
Why it was withheld. The Qatar News Agency reported the law’s issue on 25 June 2026, but no official source states a gazette date or an effective date. The substance of the amendments is separately confirmed.
Status. Dates unverified. Publish the substance without dates and flag that commencement is unconfirmed.
Qatar. Global minimum tax registration deadline of 30 November 2026.
Why it was withheld. Traces to a secondary publication whose own text computes 2 November and then tabulates 30 November. The General Tax Authority published no calendar date, only a three month window from portal activation on 2 August 2026, which ends on 1 or 2 November depending on how the months are counted.
Status. Debunked. Publish 31 October 2026 as the protective date and disclose the disagreement rather than asserting a single deadline.
Egypt. The personal data protection licensing regime becomes fully enforceable on 1 November 2026, with licence decisions taking ninety working days and fees tiered by data volume.
Why it was withheld. The executive regulations to Law No. 151 of 2020 are listed in commercial databases as Ministerial Decision No. 816 of 2025, published in the Official Gazette in November 2025, but the gazette text itself could not be retrieved from an official source in this pass, and no top tier media report confirming the enforcement date, the decision period or the fee tiers was located.
Status. Held pending the official text. Highest priority verification item for the next cycle: retrieve the Official Gazette text or the Personal Data Protection Centre publication and republish with the confirmed date.
Egypt. Direct electronic marketing requires its own licence, priced at ten per cent of the controller licence fee, or twenty five per cent when marketing for third parties.
Why it was withheld. The separate direct marketing licence and the fee percentages appear only in advisory commentary. No official source or top tier media report was located.
Status. Held pending the official text. Confirm the licence and the fee levels against the gazetted executive regulations.
Kuwait. Corporate governance amendments under Capital Markets Authority Decision No. 56 of 2026 must be fully complied with by 31 December 2026.
Why it was withheld. The decision’s issue and publication dates are listed in commercial databases, but the Capital Markets Authority circular and the 31 December 2026 compliance date could not be retrieved from an official source, and no top tier media report was located.
Status. Held pending the authority’s circular. Retrieve it from the Capital Markets Authority and republish with the confirmed dates.
Bahrain. Domestic minimum top up tax quarterly advance payments are running, with the first annual return statutorily due 31 March 2027 and shown on the portal as 30 June 2027.
Why it was withheld. The National Bureau for Revenue site refused automated retrieval, and no official source or top tier media report confirming the advance payment rules or either return date was located.
Status. Held pending the National Bureau for Revenue guides. Confirm directly with the Bureau before advising on dates.
Bahrain. First domestic minimum top up tax return due 30 June 2027 under an eighteen month transition.
Why it was withheld. The eighteen month timeline is not in the legislation. It appears only on the National Bureau for Revenue portal. The statutory fifteen month rule gives 31 March 2027, and no official source reconciles the two dates.
Status. Administrative practice, not law. Publish the statutory date with the portal position disclosed. Advise clients not to rely on the extension without written confirmation.
Oman. Decision number for the Financial Services Authority securities executive regulations.
Why it was withheld. The number was not printed by any official source read. The substance and dates are separately confirmed. The personal income tax decree, Royal Decree No. 56/2025, is now confirmed by the Oman Tax Authority and is cited above.
Status. Number unverified. Publish the substance without the instrument number.
Saudi Arabia. Specific minimum local content percentages per product under the mandatory list.
Why it was withheld. The existence, the product count and both phase dates are primary verified. The individual percentage figures sit on the authority’s own site which refused automated requests, so they are not independently confirmed.
Status. Figures unverified. Publish the regime and direct clients to the authority for the product specific percentage before bidding.
Regional. Influencer licensing regimes equivalent to the United Arab Emirates and Saudi models exist in Qatar, Kuwait, Bahrain, Oman, Egypt and Jordan.
Why it was withheld. No equivalent paid influencer permit was confirmed in any of these markets. Influencer advertising appears to be caught by general media licensing, consumer protection and data protection consent rules instead.
Status. Unverified negative. Do not represent the absence of a licence as a positive finding. Commission a dedicated pass before this reaches a client deliverable.
Compiled by LexDesk360. Contact us for bespoke legal consultancy.
About this brief
This briefing is an intelligence product produced by the LegalEyes desk. It is not legal advice, it does not create a lawyer and client relationship, and it should not be relied upon in place of advice on your own facts. The English text is authoritative. Arabic and French renderings are provided for convenience only and the English governs. Sources are stated so that every statement can be traced to the instrument that supports it. Items that could not be verified to that standard are recorded in the section headed what we did not publish and were withheld.
How this bulletin was made. Items are gathered from official gazettes, regulator publications and public consultation platforms across ten markets, then put through an adversarial verification gate whose default verdict is to reject. Publication requires an official government source, being a gazette, legislation portal, ministry, regulator or state news agency, or, where no official text is yet published, a report in top tier news media. LegalEyes does not cite law firms, accounting firms or other advisory commentary. Every item carries the source that supports it and is archived under an immutable run identifier, so any statement made here can be traced back to the instrument behind it. Everything that failed that test is listed in the section headed what we did not publish.