Who the DOH licenses and how a file is opened
The DOH is the health regulator for Abu Dhabi city, Al Ain and Al Dhafra, set up under Abu Dhabi Law No. 10 of 2018. Professionals apply and renew through the TAMM government platform under the DOH Licensing Procedural Manual (LPM-01), and a licence lasts two years. Cases about individual practice tend to start in one of four ways.
| Starting point | How it works |
|---|---|
| A patient's request | Through the DOH service Investigation Request for Medical Error, the patient, someone with a legal power of attorney, or a first-degree relative if the patient has died, can ask for any licensed facility or professional to be investigated. The request is free and made online, with Emirates ID copies and any medical reports. The DOH warns that investigations can run for months. |
| A court or prosecutor | Medical-error matters that reach the courts or the Public Prosecution have to be sent on to the health authority (Cabinet Resolution No. 40 of 2019, Article 8). |
| An inspection | DOH inspectors hold law-enforcement powers (Law No. 10 of 2018, Article 9), and a number of the DOH's published enforcement cases grew out of routine visits. |
| An incident report | An entry in the facility's incident system, or a sentinel event notified to the DOH, can lead to questions about the people involved. |
Two practical points. DOH circular 63/2021 asks facilities and professionals to keep their mobile numbers and email addresses up to date so that DOH letters reach them; a message sent to an old address can still start a deadline. And the investigation service page carries a separate user guide and FAQs for healthcare professionals, which is worth reading before you write anything.
How the Medical Liability Committee weighs your care
Members are experienced doctors appointed by the head of the health authority. The committee may call on other specialties or set up technical sub-committees, but only members vote. Its remit is broad and exclusive: whether there was an error, how serious it was, who contributed and by how much, what caused the harm, and any percentage of disability. A claim for compensation will not be heard in court until the committee has looked at it.
| The question | What the law says |
|---|---|
| Was there an error? | Federal Decree-Law No. 4 of 2016, Article 6, identifies four grounds: not knowing what a practitioner at your grade and in your specialty should know, departing from accepted professional standards, not taking due care, or carelessness |
| Was it gross? | Cabinet Resolution No. 40 of 2019, Article 5, needs a grave result, such as a death, a mistaken organ removal or the loss of an organ's function, combined with an aggravating feature: for example an unexplained break from standards, working while impaired, flagrant negligence, knowingly going beyond your privileges, or using a technique you were never trained or supervised in. Two-thirds of the members present must agree. |
| Is there no liability? | Article 17 gives the answers: the harm came from something other than an Article 6 ground; the patient's own actions caused it, such as refusing treatment; you chose a different method that is still within accepted practice; or a known or unforeseeable complication occurred without any error |
The committee's rapporteur asks for the original medical file and may call both sides and witnesses. A clear note of the consent discussion, your reasoning and the follow-up is often what makes an Article 17 answer possible. A reasoned report is due 30 days after referral, but the period can be extended. Until it is issued the complainant can change, add to or withdraw the complaint; the DOH's own powers to inspect and penalise carry on regardless.
Medical Liability and Medical Error Under UAE Law
Clinical Documentation and Record Keeping
Clinical Competence and Patient Safety
Match the concern to a course
The concerns that most often lead to complaints and investigations, how they are viewed, and the courses that address each one.
Written consent missing or incomplete
The DOH consent standard lists many interventions that need a signed form. Missing consent records in home care were among the 2024 enforcement findings.
Substitute consent from the wrong relative
In Abu Dhabi the father comes first in the order for substitute consent. Clinicians used to the spouse-first approach in Dubai can get this wrong.
Alleged error in diagnosis or treatment
Your care is tested against the four Article 6 grounds, and the Article 17 answers, including a known complication without error, are considered.
Incident not reported or not disclosed
Incidents should be logged within a day and sentinel events sent to the DOH within two. Facilities also need a process for telling patients and families.
Narcotic, psychotropic or semi-controlled prescribing
Prescriptions are electronic, valid for three days and capped by grade; a general practitioner, for example, can supply only three days of a psychotropic.
Sick leave or records issued without examination
In 2026 the DOH suspended everyone involved in selling sick leave and altering records and referred the case for prosecution.
Insurance claims and billing
Deliberate deception for an insurance benefit is fraud under the DOH payment standard. Earlier cases ended with Thiqa exclusion and limits on licences.
Gifts, sponsorship and conflicts of interest
DOH policy asks you to avoid even the look of a conflict and to declare interests in writing.
Infection control and sterilisation
Sterilisation and infection-control failures at a dental clinic and in home care lay behind closures and doctor referrals in 2024.
Advertising and social media
Under circular 26/2023, a trained facility representative must record advertisements on DOH systems before they are used.
Appealing a report to the Higher Medical Liability Committee
Both sides can use the DOH service Appeal request for medical error complaint. The essentials:
- Time limit: 30 days from receipt of the committee report.
- Cost: AED 5,000, payable through an SMS link that the Ministry of Health and Prevention sends to the number on the request.
- Content: a detailed request that sets out, point by point, what you dispute.
- Decision-maker: the Higher Medical Liability Committee at MOHAP. Federal legislation calls the same body the Supreme Committee of Medical Liability.
- Timing and outcome: there is no fixed time frame, and the decision is emailed to the address you registered.
Miss the window and the first report becomes final under Article 20 of the Decree-Law. The appeal committee, made up of medical consultants, can confirm, change or cancel the report. A change can work against you as well as for you, so take advice from your insurer or lawyer before filing. The legislation describes the appeal decision as final; a UAE lawyer can tell you whether anything further is open in your case.
The appeals that justify the fee answer the committee's reasons directly. Identify the paragraph you disagree with, the guideline or published evidence that supports you, and any material in the record that was overlooked. A report from another expert in the field, arranged through your insurer or lawyer, can strengthen the request. Telling the same story again rarely moves a committee.
Which law a DOH penalty rests on
Administrative action does not wait for the liability process to finish. A penalty on a DOH licensee may be based on Abu Dhabi law or on a federal profession law, and the time you have to challenge it changes with the basis.
| Basis | Range of outcomes | Time to challenge |
|---|---|---|
| Abu Dhabi Law No. 10 of 2018, Article 12 | From a notice or warning, through supervision of the activity and temporary suspension, to suspending or cancelling the licence or closing a facility | 60 days from notification; the DOH has 90 days to decide |
| Abu Dhabi Law No. 10 of 2018, Article 11 | Administrative fines that can reach AED 10 million, with a settlement option at 75% if paid within 60 days | Follow the route in the decision letter |
| Federal Law No. 5 of 2019 (doctors and dentists) | From a written notice to revocation, including fines up to AED 1,000,000 and suspension up to a year | 15 days (Article 29) |
| Federal Law No. 6 of 2023 (nurses, midwives, allied health) | From a written reprimand to revocation and removal from the register, including fines up to AED 50,000 and suspension up to six months | 15 days (Article 14) |
Under both federal laws you must be given a chance to answer before any penalty, though failing to turn up without good reason will not hold up a decision. A 2026 DOH announcement also cited articles of the disciplinary regulations for the Abu Dhabi health sector without naming the instrument in full. If you receive a decision, ask the DOH to confirm the exact provision, and if in doubt act within 15 days.
Suspension, renewal and where criminal protection stops
- Pending a report. Federal Decree-Law No. 4 of 2016, Article 23, lets the health authority suspend a licence in renewable blocks of up to 30 days while a report is awaited or other breaches are examined. It is a safety measure, not a verdict.
- No renewal while suspended. The DOH Licensing Procedural Manual does not allow a suspended professional to apply for renewal. A licence that has been expired or cancelled for more than five years needs a fresh registration.
- Protection for clinical judgement only. Article 24 stops investigation, arrest or detention for a medical error until there is a final report of gross error. Fraud, falsified documents and tampered records are outside that protection.
- Fraud is treated differently. In March 2026 the DOH suspended every staff member involved in selling sick leave without examination and altering records, and referred the matter to the Public Prosecution.
If you are suspended, keep your CPD portfolio moving and keep a note of every date, so that you know what renewal will require when the suspension ends.
What the DOH enforcement record shows
The DOH publishes some of its enforcement action. Three announcements show how individual professionals can be drawn in.
| When | Findings | Action |
|---|---|---|
| March 2026 | Sick leave sold without any examination, altered patient records and documents, unlicensed staff, and records kept outside the required systems | Five facilities closed for a period; the licences of everyone involved suspended and the matter sent to the Public Prosecution |
| February 2024 | Breaches of communicable disease rules, home-care visits without consent records and with infection-control failures, and a dental clinic with unlicensed staff, weak sterilisation and poor notes | A fine of AED 1 million on one centre, several doctors referred for investigation, dental work stopped at one group's branches and eight facilities closed |
| December 2017 | Invented details on insurance claims, charges for services never given, inflated dental work and altered clinical information used to justify surgery | Removal from the Thiqa network, fines, recovery of claims, limits on practitioners' licences and referral for legal action |
Read together, these cases suggest that the most serious consequences came from dishonest or careless paperwork rather than from clinical misjudgement on its own. They also show that "the clinic told me to" did not protect the person whose name was on the record or the claim.
Probity and Honesty in Practice
Insurance Billing and Financial Integrity
Clinical Documentation and Record Keeping
The DOH standards your conduct is measured against
Abu Dhabi has no single DOH code of ethics. Professional conduct is judged against federal law, MOHAP's national Code of Ethics and Professional Conduct of 2017, the national Healthcare Workforce Bioethics Guidelines of August 2024 and a group of DOH documents. The ones that most often matter in an individual case:
| DOH document | What it asks of you |
|---|---|
| Patient Consent Standard (in effect from February 2025) | Covers general, implied and informed consent, lists the interventions that need written consent (including surgery, endoscopy, telemedicine, genetic tests, data sharing and research), and sets a substitute consent order headed by the father |
| Policy on Integrity and Benefit Disclosure (2022) | Avoid situations that could even look like a conflict of interest, do not lend your professional title to commercial products, and complete conflict-of-interest declarations |
| ADHICS V2 and Malaffi | Personal log-ins, no work data on your own devices, screens and desks kept clear, suspected breaches reported; emergency access to a Malaffi record must be justified in writing |
| Incident Reporting and Management Standard V2 (December 2024) | Log incidents in the facility system within a day; sentinel events reach the DOH within two days; facilities need a way of telling patients and families what happened |
| Circular 26/2023 on health media and advertising | Advertising and public communications are recorded on DOH systems by a trained facility representative before release |
| Standard on narcotic, psychotropic and semi-controlled medicines (2021) | All such prescriptions are electronic, valid for three days and limited in quantity by the prescriber's grade |
| Standard on recovery of payment (HSFR V2) | Treats deliberate deception to gain a benefit under the health insurance scheme as fraud |
| Child Protection Policy (2026) | Safeguarding duties for staff who see children, with yearly training |
Informed Consent and Chaperones
Patient Confidentiality and Health Data
Open Disclosure: Honest Communication When Care Goes Wrong
Healthcare Ethics in UAE Practice
Checking your own records against DOH standards
Before you write anything, look at your own practice through the documents a DOH reviewer is likely to hold up against it. A private self-audit shows where the gaps are while there is still time to act, and once you act it becomes evidence of change.
| Area | What to check in your own work | DOH reference |
|---|---|---|
| Consent | Whether each intervention that needs written consent has a signed form, and whether any substitute consent followed the order the standard sets | Patient Consent Standard |
| Incidents | Whether events you were part of were logged in the facility system within a day | Incident Reporting and Management Standard V2 |
| Record access | Whether every emergency access you made to a Malaffi record has a written justification | ADHICS V2 and Malaffi |
| Controlled medicines | Whether prescriptions were electronic and within the quantity limits for your grade | DOH narcotics, psychotropic and semi-controlled medicines standard |
| Claims | Whether billed services match what the notes show was done | HSFR V2 |
| Interests | Whether your conflict-of-interest declarations are complete and current | Policy on Integrity and Benefit Disclosure |
Look, note what you find and change what needs changing from now on; never alter past entries. Agree the sample with your adviser, keep the audit apart from the case file, and repeat it a few months later so you can show the change has held.
DOH CME, renewal and your good standing certificate
CME in Abu Dhabi is counted over the two-year licence. Physicians and dentists need 80 credits per cycle; nurses, midwives and pharmacists 40; allied health and traditional and complementary medicine professionals 20. The DOH Standard for Continuing Professional Development (2024) requires at least half of each cycle to be formal activity as the Standard defines it, counts one hour as one credit, expects you to keep a portfolio that can be audited, and asks for learning in every year of practice rather than a rush before renewal.
After three months on an active DOH licence you can ask for a good standing certificate. It records any suspension, revocation, investigation or warning, past or current. Other authorities ask for a certificate under six months old, so a DOH case will be visible if you apply in Dubai, Sharjah or the Northern Emirates.
Your licensing authority decides how any learning counts towards your CPD or a requirement it has set. If nothing has been ordered, our courses can sit in your portfolio as self-directed learning with a written reflection, and each certificate shows the title, CPD hours and date of completion.
A response checklist for DOH-licensed professionals
- Start with the dates. Note when the notice arrived. An appeal against a committee report allows 30 days; a grievance against a penalty allows 15 or 60, depending on the law cited.
- Make sure the incident was logged. An event that never reached the facility's incident system is much harder to explain later. The DOH standard on incidents says reporting should lead to disciplinary action only in the most exceptional cases.
- Bring in the insurer and management. The facility owner has to insure its practitioners against medical error claims and pay for the cover (Federal Decree-Law No. 4 of 2016, Article 26). Find out how a claim is notified and whether the policy pays for legal or expert help.
- Leave the notes alone. Use the facility's formal correction process for any change. Electronic systems keep a trail, and the DOH has suspended people for altering records.
- Talk to the patient through the facility. Use the disclosure process your facility has in place rather than calling the patient privately.
- Look at who is on the committee. A member with a family link to a party, a reporting line to a party, a treating role for the same condition or a role advising you must stand aside (Cabinet Resolution No. 40 of 2019, Article 12).
- Write with advice. Lay out the facts, then your reasoning and the guidance you relied on, then what you have changed since.
This is general information drawn from the laws and DOH standards cited here, not legal advice. For your own case, speak to your insurer, your employer's legal team or a UAE lawyer.
Responding to a Complaint or Licensing Inquiry
Open Disclosure: Honest Communication When Care Goes Wrong
Clinical Documentation and Record Keeping
An illustrative example: an unlogged medication incident in Abu Dhabi
The following is an illustrative scenario, not a real case. A nurse on a medical ward in an Abu Dhabi hospital gives a scheduled antibiotic several hours late during a busy shift. The patient deteriorates, then recovers. No incident is logged. Two months later the patient uses the DOH Investigation Request for Medical Error service.
- First moves. She notes the date of the DOH letter, tells her line manager and asks how the hospital's insurer is notified.
- The record. Her notes show when the dose was given but not why it was late. She leaves them untouched and writes a dated, private account of the shift for her adviser.
- The missing incident report. She raises it with the quality team, who decide how it should be recorded now. Nothing is backdated.
- Contact with the patient. It goes through the hospital's disclosure process, not a personal call.
- Learning and change. She completes Open Disclosure and Preventing Recurrence After an Error or Incident, reflects in writing on why the event went unreported, and agrees a handover prompt for time-critical doses with her charge nurse.
- Her reply sets out the timeline from the record, accepts plainly that the event should have been logged, and attaches the certificates, the reflection and the new prompt, each dated.
None of this settles the result. It does give the committee and the DOH a clear view of what happened, what she understands now and what has changed, which is what they need to judge the risk of a repeat.
After the outcome: conditions, re-licensing and evidence
There is no published DOH scheme for outside remediation courses. If a decision imposes conditions, meet them exactly and keep evidence of each one. Federal regulations give a sense of what a route back can involve. Nurses, midwives and allied professionals whose licence is reissued after revocation may be required to complete training on what went wrong, be reassessed, accept a narrower scope or work under supervision for a time (Cabinet Resolution No. 176 of 2025, Article 11). Physicians coming back from a suspension of three to twelve months can have their competence re-evaluated or their privileges limited (Cabinet Resolution No. 67 of 2020, Article 7.2).
When nothing has been ordered, well-chosen learning still helps your response and your return. The elements that carry weight:
- a course that fits the concern, completed and certificated;
- a reflection that connects the learning to the event and to how you work now;
- proof of change, such as an audit of your own consent records or prescribing, or a new template;
- comments from a supervisor or medical director gathered over several months.
Our remediation courses page sets out how to assemble this into a single file.
Building a Remediation Plan After a Concern
Insight: Understanding and Showing It After a Concern
Reflective Practice and Written Reflections
Preventing Recurrence After an Error or Incident
A starting set for a DOH investigation
DOH cases tend to turn on three things: the liability test, the quality of the record and how openly the event was handled afterwards. This set covers all three, together with the process and the reflection committees look for. Add the ethics course for your profession, for example Medical Ethics for Doctors in the UAE or Ethics and Professional Conduct for Dentists, and one topic course from the concerns table.
All courses are online and self-paced, with UAE case studies and knowledge checks, a 20-question scenario-based final assessment (30 questions in the 4-hour core investigation course) with an 80% pass mark and a reflective account to keep in your portfolio. To see how Abu Dhabi compares with Dubai and the federal system, read the UAE complaints guide.
Facing a Licensing Investigation: The Core Remediation Course
Medical Liability and Medical Error Under UAE Law
Responding to a Complaint or Licensing Inquiry
Open Disclosure: Honest Communication When Care Goes Wrong
Insight: Understanding and Showing It After a Concern
Recommended courses
All coursesFacing a Licensing Investigation: The Core Remediation Course
Both UAE tracks, each authority's process and deadlines, licence status, written responses and hearings, insight, remediation evidence and returning to practice.
Medical Liability and Medical Error Under UAE Law
How UAE medical liability works for clinicians: duties and prohibited acts, error and gross error, committees, the 30-day grievance, suspension, insurance, discipline and responding well.
Responding to a Complaint or Licensing Inquiry
Complaint routes in each emirate, the committee process, deadlines, the first 72 hours, building a chronology and writing an honest, structured response.
Open Disclosure: Honest Communication When Care Goes Wrong
What to say, and when, after a patient is harmed: candour duties, sentinel event rules, apology wording, interpreters, families, records and follow-up in UAE practice.
Insight: Understanding and Showing It After a Concern
A five-step method for understanding your part in a concern and showing that understanding in statements, interviews and reassessments before UAE committees and licensing authorities.
Building a Remediation Plan After a Concern
Defining the concern, finding its cause, testable objectives, supervision and audit, building an evidence portfolio and returning after suspension, revocation or a gap.
Questions
A relative of my patient has asked the DOH to investigate me. Can they do that?
Yes, in some cases. A first-degree relative can file if the patient has died, and anyone holding a legal power of attorney can file for the patient. Otherwise the patient files personally. Courts, prosecutors and DOH inspections can also open a case without any patient request.
How much is a DOH medical error appeal and where does it go?
The fee is AED 5,000, paid through an SMS link from MOHAP. You have 30 days from receiving the report, and the Higher Medical Liability Committee at MOHAP decides. There is no fixed timetable, and the result is emailed to you.
The committee found no gross error, but the DOH has fined me. How?
They are separate decisions. The committee answers the clinical question of error and severity. A fine, warning or suspension is an administrative step under Abu Dhabi law or a federal profession law, and it has its own route to challenge.
Do I have 15 days or 60 to challenge a DOH penalty?
That depends on the law the decision uses: 60 days under Abu Dhabi Law No. 10 of 2018, 15 days under the federal laws for doctors and for nurses, midwives and allied professionals. If the letter does not make this clear, ask, and work to 15 days in the meantime.
The patient has dropped the complaint. Is it over?
Not necessarily. A complaint can be withdrawn until the committee reports, but the DOH can still use its own inspection and penalty powers, so keep preparing until you are told in writing that the matter is closed.
Could the police get involved in an Abu Dhabi medical error case?
Not over the clinical error alone unless the health authority has issued a final report confirming gross error. Allegations of fraud, forged documents or altered records are treated differently and can go straight to the Public Prosecution.
My DOH licence is suspended and due for renewal. What happens?
Under the Licensing Procedural Manual you cannot apply to renew while suspended. Keep your CPD portfolio current and ask the DOH what renewal will need once the suspension has ended.
Will another emirate see that I was investigated by the DOH?
Yes. The DOH good standing certificate lists past and current investigations, warnings, suspensions and revocations, and other authorities ask for a recent certificate when you apply.
Is there a DOH code of ethics I should quote in my reply?
There is no single DOH code. You can refer to the national 2017 Code of Ethics and Professional Conduct, the 2024 bioethics guidelines and the specific DOH standard involved, such as the Patient Consent Standard or the integrity policy.
Will completing courses change the DOH outcome?
No course can decide an outcome. Learning matched to the concern, a specific reflection and evidence of changed practice can help you show insight and a lower risk of repetition. Your licensing authority decides how any learning counts towards your CPD or a requirement it has set.
Official sources
Checked October 2026. Rules and processes change, so confirm the current position with the official source. This page is general information, not legal advice.
- DOH service: Investigation Request for Medical Error
- DOH service: Appeal request for medical error complaint
- DOH Encyclopedia of Health Legislation, Book 1 (includes Abu Dhabi Law No. 10 of 2018)
- DOH Licensing Procedural Manual (LPM-01, 2024)
- DOH Standard for Continuing Professional Development for Healthcare Workforce (2024)
- DOH Incident Reporting and Management Standard, version 2
- DOH Patient Consent Standard
- DOH Policy on Integrity and Benefit Disclosure
- Abu Dhabi Healthcare Information and Cyber Security Standard (ADHICS) V2
- DOH Standard for Management of Narcotics, Psychotropic and Semi-Controlled Medicinal Products
- DOH Standard for the Recovery of Payment for Healthcare Services under the Health Insurance Scheme
- DOH Circular 26/2023, Health Media and Advertising
- DOH Child Protection Policy (2026)
- DOH: Healthcare Workforce Bioethics Guidelines (August 2024)
- DOH news: five facilities closed and staff suspended pending referral to the Public Prosecution (27 March 2026)
- DOH news: AED 1 million fine, doctors referred for investigation, eight facilities closed (4 February 2024)
- DOH news: facilities disciplined over health insurance violations (25 December 2017)
- Federal Decree-Law No. 4 of 2016 Concerning Medical Liability
- Cabinet Resolution No. 40 of 2019, Executive Regulations of the Medical Liability Decree-Law
- Cabinet Resolution No. 14 of 2020 Concerning the Supreme Committee of Medical Liability
- Federal Law No. 5 of 2019 Regulating the Practice of the Human Medicine Profession
- Cabinet Resolution No. 67 of 2020, Executive Regulations of Federal Law No. 5 of 2019
- Federal Law No. 6 of 2023 on the Practice of Some Medical Professions by Persons Other Than Physicians and Pharmacists
- Cabinet Resolution No. 176 of 2025, Executive Regulations of Federal Law No. 6 of 2023
How this guide is researched
Official sources only
Every legal and regulatory point comes from primary sources: UAE federal health laws, the licensing authorities' codes, standards and policies, and official government guidance. Anything we cannot confirm is left out.
Original, edition by edition
Lessons, scenarios and assessment questions are written by us for each edition separately, then checked for accuracy, teaching quality and fair assessment before publication.
Reviewed when rules change
When a code, standard or law changes, the affected courses are reviewed and updated. Reported errors in legal or regulatory facts are corrected first.