Who the DHA licenses and where its powers stop
Health professionals practising in Dubai are licensed by the DHA's Health Regulation Sector. Since 28 August 2024 the rules on practice and discipline have been set by Executive Council Resolution No. 49 of 2024, which replaced the 2012 resolution. They apply to facilities throughout the emirate, free zones and Special Development Zones included; the Resolution gives the Dubai International Financial Centre as an example. Federal government bodies and their facilities are excluded, so people working there fall under the federal system in our MOHAP guide.
| Your situation | Who usually holds the file |
|---|---|
| DHA licence, private hospital, clinic or pharmacy in Dubai | The Health Regulation Sector, with the Medical Practices Committee deciding any penalty |
| DHA licence, clinic in the DIFC | The DHA, under Resolution No. 49 of 2024 |
| Practising in Dubai Healthcare City | Moving to the DHA; confirm in writing (see the next section) |
| Federal government facility in Dubai | MOHAP and your federal employer rather than the Dubai rules |
| An alleged medical error anywhere in Dubai | A Medical Liability Committee under federal law, in addition to any DHA disciplinary step |
You register through Sheryan and your employer activates the licence. That link means your employer will usually hear about a DHA case early and may run its own review at the same time, so be ready to give a consistent account in more than one place.
If you practise in Dubai Healthcare City
DHCC used to regulate its own professionals through DHCR, the regulatory arm of the Dubai Healthcare City Authority, under the DHCC Healthcare Professionals Regulation No. 2 of 2013. Dubai Law No. 16 of 2024, issued on 4 September 2024, points the other way. Its Article 20 says healthcare activity in the DHCC health sector needs DHA licences and permits as well as any DHCA approvals, and Article 30 lets older DHCC regulations survive only where they do not clash with the new law, and only until they are replaced.
How complaints move across in practice has not been fully published. A DHCC case could be handled under the 2013 Regulation or by the DHA under Resolution No. 49 of 2024, so read your first letter carefully for the route and, if it is silent, write to both bodies.
- The 2013 route. A Customer Protection Unit receives patient complaints and the reports that managers and colleagues are obliged to make about poor practice. It sorts each one into Inappropriate Professional Practice, meaning care below the required standard of competence, or Professional Misconduct. You are asked for a written explanation and an expert gives an opinion. The Unit can then close the case, advise you, set a Competence Program or send the matter to the Fitness to Practice Panel. Either party can ask the chair of the Complaints Panel to review that choice within 30 days.
- The Panel. If it finds your fitness impaired, it can cancel or suspend the licence, impose conditions or restrictions, or require a Competence Program, singly or together.
- The DHA route. If the DHA takes the case, the rest of this page is your guide.
- Either way, the federal Medical Liability Law reaches into the free zone, so alleged errors still go to a Medical Liability Committee.
A Competence Program is tailored to you by the regulator. A course you pick for yourself is something different and should never be described as one, though it can usefully cover areas such as record keeping or communication alongside it.
Facing a Licensing Investigation: The Core Remediation Course
Clinical Competence and Patient Safety
Building a Remediation Plan After a Concern
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.
Examination or treatment without consent
Items 27 and 28. For non-emergency examinations of a patient of the opposite gender, the DHA Code expects written consent in advance and another person in the room.
Alleged malpractice or medical error
Item 16. The liability committee applies the federal error test, and its findings then go to the Medical Practices Committee for the disciplinary decision.
Altered, missing or poorly kept records
Item 34 covers editing or deleting file data; losing files and poor file management are listed separately. The Code wants entries dated, signed and readable.
Sick leave certificates and medical reports
Items 59 to 62. These are honesty cases at heart, and the notes usually decide whether an examination really happened.
Controlled or semi-controlled medicines
Items 46 and 47. In Dubai, controlled medicines are prescribed on a unified electronic platform.
Confidentiality or data breach
Item 17. Opening the record of a relative, colleague or well-known person you are not treating breaches the Code.
Social media posts or advertising
Items 43 to 45. DHA social media standards prohibit superlatives and absolute promises, and need written consent for any patient image.
Insurance claims and unnecessary tests
Item 32 deals with unnecessary tests. The Code standard on insurance integrity also rules out duplicate billing, upcoding, improper unbundling and changing records to secure cover.
Boundaries with patients or their families
The Code prohibits personal or romantic relationships with current patients or their close family, and any form of harassment; a breach can be pursued under item 19.
Conflict with colleagues or disparaging remarks
Item 18. Take disagreements to your facility's internal channels rather than airing them publicly; DHA online standards bar criticism of other professionals.
Two tracks that run side by side
One incident in Dubai can lead to two separate processes, each with its own decision-maker and deadline.
| Medical liability | DHA discipline | |
|---|---|---|
| Legal basis | Federal Decree-Law No. 4 of 2016 and its Executive Regulations | Executive Council Resolution No. 49 of 2024 |
| Central question | Did an error happen, how serious was it, and did it cause the harm? | Was a listed violation committed, and what should follow? |
| First decision | Medical Liability Committee | Medical Practices Committee |
| Challenge | Supreme Committee of Medical Liability, 30 days from notification | Medical Grievances Committee, 30 days from notification |
Success on one track does not end the other. Federal law keeps disciplinary liability distinct from criminal liability (Article 38), and Resolution No. 49 lets the DHA impose administrative penalties even where a court acquits you or finds no liability (Article 24). Plan for both from day one and tell the same story in each.
A patient complaint is only one trigger. The DHA also opens files after auditing medical records or inspecting facilities, when courts, prosecutors or government bodies refer a matter, and under its Fitness to Practice Policy where conduct or health puts safe practice in doubt.
A DHA case from first notice to closure
- The case opens. Patients and carers complain through the free online Submit Medical Complaint service. The DHA Health Regulation Sector service catalogue sets a three-year limit from the event, and the DHA quotes one to six months to deal with a complaint.
- Evidence is collected. The Health Regulation Sector obtains the medical file, the facility's reply and your account. If patient safety is at stake, a precautionary suspension can be imposed at this point.
- Alleged errors are referred. A Medical Liability Committee is meant to report with reasons a month after referral, though extensions are allowed and complex cases often take longer.
- The Medical Practices Committee decides. It receives liability findings together with the complaint, decides whether a violation occurred, and sets any penalty and remedial measures.
- Grievance. You can write to the Director General within 30 days of notification. The Medical Grievances Committee has 30 days to decide, and that decision cannot be challenged further within the DHA.
- Closure. Any training, supervision or reassessment is completed by the date set, and the outcome is recorded in Sheryan.
There is no need to wait for step 4 before you act on the concern. Learning and changes to practice that begin shortly after the first letter, and clearly relate to it, show commitment. If they only start once a decision is made, they can look like damage control.
The DHA violation list: Schedules 4 and 5
Resolution No. 49 of 2024 (Article 18) groups prohibited acts into two schedules. Schedule 4 violations are for the Medical Practices Committee. Schedule 5 violations attract set fines, between AED 1,000 and AED 50,000, from the Director General; a second identical Schedule 5 breach inside twelve months doubles the fine and moves the case to the committee.
| Schedule 4 item | Subject | Course that fits |
|---|---|---|
| 16 | Malpractice | Medical Liability and Medical Error Under UAE Law |
| 17 | Revealing a patient's secrets | Patient Confidentiality and Health Data |
| 18 | Damaging a colleague's reputation | Teamwork and Collaboration for Safer Care |
| 19 | Breaching the profession's code of ethics | The ethics course for your profession |
| 27 | Opposite-gender examination with no third person present or no prior consent, outside emergencies | Informed Consent and Chaperones |
| 28 | Treatment given without prior consent, outside emergencies | Informed Consent and Chaperones |
| 32 | Unnecessary investigations | Insurance Billing and Financial Integrity |
| 34 | Editing or deleting medical-file data in breach of instructions | Clinical Documentation and Record Keeping |
| 46 and 47 | Substandard prescribing or dispensing; misuse of narcotic or controlled prescriptions | Safe Prescribing and Controlled Medicines |
| 59 to 62 | Improper sick leave: false, unauthorised, beyond your scope or too long | Probity and Honesty in Practice |
Item 19 deserves a second look. Since a breach of the ethics code is itself a listed violation, the DHA Code of Ethics standards effectively become the test for any conduct the schedules leave out, from accepting gifts to what you post online.
The DHA Code of Ethics and the Fitness to Practice Policy
Every DHA licensee has been bound since 3 September 2025 by the Standards for Code of Ethics and Professional Conduct for Health Professionals (Version 1), circulated under reference CIR-2025-00000127. The DHA presents them as resting on federal law, the 2017 national Code of Ethics and Professional Conduct and the national Patient's Rights and Responsibilities Charter. Following an opening set of general principles, the standards deal with:
- putting the interests of patients, and of the public, first;
- autonomy and informed consent;
- privacy, confidentiality and data protection;
- integrity and accountability;
- working within your scope and keeping competent;
- communicating professionally;
- continuing professional development;
- supervising and delegating safely;
- research ethics;
- honest insurance practice and regulatory compliance.
The parts that most often come up in complaints are concrete. Get consent before you examine or treat, and never pressure anyone into it. Open a patient's record only if you are caring for them or have authority to. Do not change, falsify or destroy notes. Refuse gifts or hospitality that could influence you or look as if they might. Do not start a romantic or personal relationship with a current patient or a close relative of one. Keep patient details and personal clinical advice off social media. Speak up about a colleague who is unfit to practise if patients are at risk.
The DHA Fitness to Practice Policy (version 1.1, in force from 21 March 2025) looks at two things: whether anything gets in the way of you practising safely, and whether your conduct is reliably appropriate. Among the concerns it lists are dishonesty, fraud, substance misuse, breaches of confidentiality and work beyond your scope.
Medical Ethics for Doctors in the UAE
Ethics and Professional Conduct for Nurses and Midwives
Healthcare Ethics in UAE Practice
Professionalism in Practice for UAE Health Professionals
What the Medical Practices Committee can order
| Penalty (Article 19) | Practical effect |
|---|---|
| Written warning | Goes on your record; for the following two years the DHA gives a Current Status Certificate in place of a Good Standing Certificate |
| Downgrading | Your privileges or classification drop to the level stated in the decision |
| Suspension | For a period of up to twelve months |
| Revocation | No new application can be considered for two years from the decision |
| Fine | Between AED 2,000 and AED 100,000 for an individual |
On top of a penalty, Article 19(c) lets the committee order remedial steps: named training within a deadline, up to a year of practice supervised by another professional, and a reassessment whose result shapes what happens next. There is no fixed order, so a serious first offence can lead directly to suspension. And Article 23 treats failure to fix a violation by the DHA's deadline as a fresh violation, which can mean suspension until the problem is put right.
If training is ordered, the decision sets what it covers and when it must be done. The DHA does not publish a list of external remediation providers, so do what the decision says and check with the DHA in writing before you treat any other course as meeting it.
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.
Preventing Recurrence After an Error or Incident
Classify the failure, trace root causes, rank corrective actions by strength, measure whether they hold and build a personal plan that lowers the risk of repetition.
Working through a Medical Practices Committee order
Once a decision sets training, supervision or reassessment, your task changes from persuading the committee to proving that you complied. Because Article 23 makes a failure to correct a violation by the DHA's deadline a new violation, treat each measure as a small project with its own dates.
| Measure | What to set up | What to keep |
|---|---|---|
| Named training by a deadline | Written confirmation from the DHA of which course or provider meets the order, before you enrol | The certificate, the completion date and the DHA's confirmation |
| Supervised practice for up to twelve months | Goals tied to the original concern, agreed with your supervisor at the outset | A dated log, plus written feedback halfway through and at the close |
| Reassessment | Early answers on who assesses you, in what format and when | Your preparation notes and the result letter |
| Written warning | Any move between emirates planned around the two years of Current Status Certificates | The decision and any correspondence about it |
Learning you choose yourself can run beside an order, for example a record keeping course during a period of supervision, as long as you describe it as your own choice. When every measure is complete, ask the DHA to confirm the file is closed and check that Sheryan shows it.
Precautionary suspension and the dates to diarise
You can be stopped from practising before any finding, under either of two powers. Resolution No. 49 of 2024 (Article 22) allows the Director General or the Medical Practices Committee to suspend a professional for up to three months while an investigation is under way, extendable for a further period of the same length with reasons. The DHA licensing manual mentions patient safety risks, problems found in primary source verification and steps taken by another regulator as reasons. Separately, the federal Medical Liability Law (Article 23) allows 30-day suspensions, which can be renewed, while a liability report is pending.
Neither kind of suspension means you have been found at fault. You can ask the Medical Grievances Committee to lift a precautionary suspension while your grievance is considered, and it has three working days to decide.
| Event | Time limit |
|---|---|
| Patient complaint to the DHA | No later than three years after the event |
| Medical Liability Committee report | A month after referral, unless extended |
| Grievance about that report | 30 days from notification; decided by the Supreme Committee of Medical Liability |
| Grievance about a DHA penalty or measure | 30 days from notification; written to the Director General |
| Medical Grievances Committee ruling | Within 30 days of the grievance; no further DHA review |
| Request to lift a precautionary suspension | Decided within three working days |
Keep the two 30-day routes apart: one disputes whether there was an error, the other disputes the penalty, and they go to different committees. While suspended, do not work at all, including locum or second-site shifts. Working without a valid licence is a federal offence in its own right.
Your DHA record, renewal and CPD while a case is open
Sheryan produces the DHA Good Standing Certificate, which takes account of committee and appeal decisions over the previous ten years. While a case or appeal is live, and for two years after a warning, notice letter, suspension or revocation, you receive a Current Status Certificate instead. Because other UAE authorities want a recent certificate when you apply, an open DHA case can delay a move to Abu Dhabi, Sharjah or the Northern Emirates.
- Keep up your CPD. The DHA Manual for Licensing Healthcare Professionals (version 1.2, May 2025) asks for 40 points a year for physicians and dentists, 20 for nurses and pharmacists, and 10 for allied health professionals, multiplied by the years on your licence. Without it there is no renewal.
- Specialty focus. Seventy per cent or more must relate to your specialty, and any surplus is lost at the end of the period.
- Online is allowed. Since the 2025 Manual there is no percentage cap on online learning, as long as it relates to your specialty field.
- Claim only what you did. A false CPD claim is itself a matter for the Medical Practices Committee.
- After revocation. You can apply again two years after the decision, and the licence comes back at the same title, not a higher one.
Your licensing authority decides how any learning counts towards your CPD or a requirement it has set. Each of our certificates shows the title, CPD hours and date of completion, so a reviewer can see exactly what you studied.
The first fortnight after a DHA letter
- Diary every date. Record the day the letter came, what is being asked and the reply date. Grievance periods count from notification, however late you open the message.
- Notify your insurer and your employer. Medical error liability cover is compulsory in the UAE and is bought by the facility owner (Federal Decree-Law No. 4 of 2016, Articles 25 and 26). Ask how claims are reported and whether legal advice is included.
- Do not touch the record. Editing file data against instructions is a Schedule 4 violation in its own right, and the Code forbids changing or destroying notes. Genuine corrections go through your facility's procedure, leaving the original visible with the date and author.
- Write your own timeline now. The committee will work from the original file, so jot down times, who was there, which protocol you used and why, and anything the notes miss, while it is fresh.
- Check the committee's make-up. Under Cabinet Resolution No. 40 of 2019 (Article 12), a member with a family tie to a party, a reporting line to a party, a previous treating role for the same condition, or who advised you about the case, should not sit. Object in writing straight away.
- Have your reply reviewed. Keep the facts, your clinical reasoning and your learning in separate parts, and remember the document may be read later in a civil claim.
Criminal exposure: federal law (Article 24 of Federal Decree-Law No. 4 of 2016) bars investigation, arrest or detention over a medical error unless the health authority has issued a final report confirming gross error, and any investigating body must notify the DHA first (Article 22). This page is general information; for advice on your own case, speak to your insurer or a UAE lawyer.
Responding to a Complaint or Licensing Inquiry
Medical Liability and Medical Error Under UAE Law
Open Disclosure: Honest Communication When Care Goes Wrong
Turning a DHA notice into a written reply
Your reply to the Health Regulation Sector is often the first document the Medical Practices Committee reads about you. A clear structure helps it find what it needs, and stops facts, reasoning and learning from running together.
- Reference and scope. Quote the case reference and the date you were notified, then list the points the DHA has asked you to address.
- Your role. Licence title, facility and your part in the patient's care: treating clinician, on call, or covering for a colleague.
- Chronology from the record. Times and entries taken from the original file, with entry references, kept apart from what you remember.
- Clinical reasoning. What you decided and why, with the guideline or facility policy you relied on at the time.
- Point-by-point answers. One heading per allegation, in the order the DHA raised them, so nothing is left unanswered.
- The patient's experience. A sincere acknowledgement of how the care felt from their side, which is different from accepting fault.
- What you have done since. Learning completed, changes made and who has seen them, with an index of attachments.
Keep the tone factual and courteous and avoid any criticism of colleagues, since damaging a colleague's reputation is itself item 18 of Schedule 4. If the notice touches item 34 or items 59 to 62, say plainly what the record shows instead of explaining it away. Your insurer or lawyer should see the final version before it is sent.
Remediation evidence that tends to help in a DHA case
Behind every decision the committee makes is one question: has the risk that led to the complaint been dealt with? A large bundle of unrelated certificates does not answer that. Learning that fits the problem, and evidence that your practice has actually changed, does.
| Evidence | What makes it persuasive |
|---|---|
| Targeted learning | Picked for the Schedule 4 item or Code standard at issue, with the assessment passed |
| A reflective account | Connects the learning to your case: the event, the standard, your understanding now, the impact on the patient and the change you made |
| Changes in practice | Specific and dated, for example a new consent form, a review of your own notes or a prescribing checklist |
| Feedback over time | From a supervisor or medical director, or repeat audits that show the change has held |
| Compliance | Proof that ordered training, supervision or reassessment was completed on time |
Many DHA licensees start with the core investigation course, add one or two courses on the specific concern and finish with insight or reflective writing. The remediation courses page shows how to assemble this evidence, and the UAE complaints guide sets the DHA process beside the other authorities.
Insight: Understanding and Showing It After a Concern
Reflective Practice and Written Reflections
Rebuilding Trust After a Complaint
A core course set for DHA-licensed professionals
For most DHA cases, these five courses cover the process, the liability rules, the reflection committees expect and a structured plan. Add the ethics course that matches your licence: doctors, nurses and midwives, dentists, pharmacists or allied health professionals. Doctors whose concern is about standards of practice rather than ethics can add Professional Standards for Physicians in the UAE.
Each course runs online at your own pace, uses UAE case studies, ends with a 20-question scenario-based assessment (30 questions in the 4-hour core investigation course) needing 80% to pass, and includes a structured reflective account for your portfolio.
Facing a Licensing Investigation: The Core Remediation Course
Responding to a Complaint or Licensing Inquiry
Insight: Understanding and Showing It After a Concern
Building a Remediation Plan After a Concern
Medical Liability and Medical Error Under UAE Law
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.
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.
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.
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.
Clinical Documentation and Record Keeping
Records that hold up when someone else reads them: what to write, consent and refusal, labelled late entries, template pitfalls, reports, sick notes, retention and keeping the file intact.
Questions
Is a DHA complaint the same as a medical malpractice claim?
No. A malpractice question, whether an error caused harm, goes to a Medical Liability Committee under federal law. A DHA disciplinary case asks whether you broke the rules in Resolution No. 49 of 2024 and is decided by the Medical Practices Committee. A single incident can produce both.
I have been suspended as a precaution. What can I do?
Lodge a grievance with the Director General within 30 days and ask the Medical Grievances Committee to lift the suspension meanwhile; it must answer that request within three working days. A precautionary suspension lasts up to three months and can be extended for the same period with reasons. It is not a finding.
What is the deadline for challenging a Medical Practices Committee penalty?
Thirty days from notification, in writing to the Director General. The Medical Grievances Committee rules within 30 days and there is no further DHA review. Disputing a liability report is a separate grievance to the Supreme Committee, also within 30 days.
The court found no liability. Can the DHA still penalise me?
Yes. Resolution No. 49 of 2024 allows administrative penalties even after an acquittal or a finding of no liability, because the disciplinary question is a different one.
Does the DHA process apply to me in Dubai Healthcare City?
Possibly. Dubai Law No. 16 of 2024 requires DHA licences for healthcare activity in DHCC, while the older DHCC rules remain until replaced where they do not conflict. Your notice should show which route is being used; if not, ask both bodies. Federal liability law applies in either case.
Can the committee make me work under supervision?
Yes. Alongside or instead of a penalty, it can require named training by a deadline, up to a year of supervised practice and a reassessment. Follow the decision exactly and ask the DHA before substituting other learning.
Will a DHA case stop me moving to Abu Dhabi or Sharjah?
It may slow things down. During a case, and for two years after a warning, suspension or revocation, the DHA issues a Current Status Certificate rather than a Good Standing Certificate. Tell the new authority about the case at the outset.
Is there a time limit on a patient complaining to the DHA?
Yes. According to the DHA Health Regulation Sector service catalogue, a complaint cannot be lodged once three years have passed since the event.
If I complete courses, will the DHA close my case?
No course can determine the result. Learning aimed at the concern, a specific reflection and proof that your practice has changed can help you show the committee the risk has been addressed. 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.
- Executive Council Resolution No. 49 of 2024 Regulating the Practice of Health Professions in the Emirate of Dubai
- Dubai Law No. 16 of 2024 Concerning the Dubai Healthcare City
- DHA service: Submit Medical Complaint
- DHA Health Regulation Sector Service Catalogue
- DHA Manual for Licensing Healthcare Professionals, version 1.2 (May 2025)
- DHA Standards for Code of Ethics and Professional Conduct for Health Professionals, Version 1
- DHA circular CIR-2025-00000127 (Code of Ethics)
- DHA Fitness to Practice Policy (2025)
- DHA Standards for Medical Advertisement Content on Social Media
- DHCC Healthcare Professionals Regulation No. 2 of 2013
- 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
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.