Is your case a MOHAP case?
Under the federal profession laws, licences are issued by a "health authority". That term covers the ministry itself and any federal or local body that runs health affairs in its own area, so the answer depends on where you work. MOHAP is the licensing body for federal government facilities and for private practice across the Northern Emirates. Its online service for complaints about private facilities lists Sharjah, Ajman, Umm Al Quwain, Ras Al Khaimah and Fujairah; complaints about care in Dubai or Abu Dhabi are sent on to the DHA or the DOH.
| Where you work | What to expect |
|---|---|
| A private clinic, hospital or pharmacy in Ajman, Umm Al Quwain, Ras Al Khaimah or Fujairah | MOHAP's complaints service and committees |
| A private facility in Sharjah | Either MOHAP or the Sharjah Health Authority, which gained its own framework in 2025; check in writing (see our SHA guide) |
| A federal government hospital or clinic | A MOHAP licence and the federal Medical Liability Law; for disciplinary matters, the liability regulations refer federal government employees to the federal human resources legislation (Cabinet Resolution No. 40 of 2019, Article 18) |
| A pharmacy licensed by the Emirates Drug Establishment | MOHAP licenses its pharmacists (Federal Decree-Law No. 38 of 2024, Article 71) |
If you work for Emirates Health Services, remember that it operates federal hospitals but does not issue licences. A concern raised inside an EHS facility may follow an employer procedure as well as a MOHAP one, so ask HR and the legal team which they are using.
Administrative or medical: the two MOHAP complaint routes
Patients, or a guardian, relative or attorney acting for them, can complain online, through the MOHAP app, at a customer centre or by phone. Complainants must be adults of at least 21. A Health Governance Officer then contacts them to clarify the details. Disputes about money or insurance are sent elsewhere, and MOHAP points out that a committee decision can later be used in court.
| Administrative complaint | Medical complaint | |
|---|---|---|
| Usually about | Behaviour, service, the facility or a breach of regulations, without an alleged clinical error | Harm said to have been caused by a medical error |
| What MOHAP does first | Asks the facility for a written report and reviews its reply | Calls for the patient's medical file |
| How it is examined | An inspection; where it supports the complaint, the inspection report goes to the Health Practices Control Committee | A Medical Liability Committee sets up a technical committee to review the case, then adopts its report and sends it to both sides |
| Your priority | Making sure your account and the facility's tell the same story | Your notes from the time, which carry more weight than anything written later |
The liability regulations (Cabinet Resolution No. 40 of 2019, Article 8) add some formalities: an Arabic text or translation, a clear subject and identification of patient and complainant. Until the report is issued, the complainant may change the complaint, add papers or drop it. Because police, prosecutors and courts must forward medical-error matters to the health authority, a file can also begin with them rather than with the patient.
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.
Treatment or an opposite-sex examination without consent
Article 5 of the Medical Liability Decree-Law rules out both, apart from genuine emergencies.
Alleged medical error after a procedure
The committee tests your care against the four Article 6 grounds. For a gross finding it also needs serious harm and an aggravating feature, such as working beyond your privileges.
Referral commissions or steering patients to a pharmacy
Doctors may not sell medicines, send patients to a particular pharmacy or accept payment for referrals.
Self-promotion and unlicensed health advertising
Doctors may advertise only within the federal rules, and any health advertisement needs a MOHAP licence shown on it.
Working beyond your licensed scope
For doctors this is allowed only to save a life. Nurses and allied professionals have a statutory duty to stay within their licence.
Patient information disclosed or health data misused
Disclosure is allowed only in the exceptions the law lists, and health data is for health purposes unless there is written agreement.
Missing, late or altered entries in the file
Each step of care should be noted with what was done and when. Accurate records are a legal duty for nurses and allied staff as well as doctors.
Refusing or abandoning an emergency patient
Federal law forbids turning away or abandoning an emergency case and sets a minimum fine of AED 10,000.
Complaints about respect, explanations or discrimination
Often linked to rights in the Patient's Charter, such as dignity, equal treatment and full information before consent.
How a MOHAP Medical Liability Committee works
The committee's job is to decide whether your care involved a medical error as Article 6 of Federal Decree-Law No. 4 of 2016 defines it: knowledge gaps that someone at your grade and in your specialty should not have, a departure from accepted standards, a failure to take due care, or negligence. Article 17 gives the main answers, including a known complication with no error behind it, or an alternative method that is still within accepted practice. The committee can examine the patient and relies on the original medical file. It should report, with reasons, 30 days after referral, but extensions are common.
- Fair composition. A member who is related to a party, works under a party, treated the patient for the same problem or advised you about the case must not sit (Cabinet Resolution No. 40 of 2019, Article 12). Object in writing as soon as you know.
- A higher bar for gross error. A gross finding needs a two-thirds vote of members present, and the report has to state the ground used (Article 11).
- Watch every channel. Reports can be delivered in person, by post, by fax or by email (Article 15). The grievance period starts when you are notified, so check all the contact details MOHAP holds.
- Grievance. Within 30 days either party may take the report to the Supreme Committee of Medical Liability, a standing federal committee based at MOHAP, which can confirm, change or set aside the first report (Cabinet Resolution No. 14 of 2020).
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.
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.
Two federal penalty scales: which is yours?
The federal system splits the workforce in two, and each half has its own penalty list and appeal path.
| Doctors and dentists | Nurses, midwives and allied health | |
|---|---|---|
| Governing law | Federal Law No. 5 of 2019 (Article 28) | Federal Law No. 6 of 2023 (Article 13) |
| Lightest outcomes | Written notice, then written warning | Written reprimand, then written notice |
| Financial penalty | From AED 1,000 up to AED 1,000,000 | From AED 1,000 up to AED 50,000 |
| Longest temporary suspension | One year | Six months |
| Heaviest outcome | Licence revoked | Licence partly revoked, or revoked and name removed from the register |
| Challenging it | 15 days, to the health authority's complaints committee (Article 29) | 15 days, to the Minister or the head of the authority (Article 14) |
Neither law allows a penalty until you have had the chance to give your side, but neither lets you delay a decision by staying away without a good reason. If you are invited to be heard, go, and go prepared.
For pharmacists, the picture is less tidy. Federal Decree-Law No. 38 of 2024 now governs pharmacy, but the liability regulations still mention the earlier pharmacy law when they deal with discipline. Ask MOHAP, or your lawyer, which article your case uses.
Getting ready to be heard by a MOHAP committee
Both federal profession laws give you the chance to state your side before a penalty, and a decision can go ahead without you if you stay away without good reason. Treat the invitation as your best opportunity and prepare for it as carefully as for a written reply.
- Confirm the arrangements in writing. Which committee, the date and place, the points to be discussed, whether papers can be sent in advance and whether you may bring someone with you.
- Prepare a short bundle. Your written response, the timeline drawn from the record, any guideline you relied on, and your certificates and reflective accounts, each dated and indexed.
- Think about language. The liability regulations expect complaints in Arabic or with a translation, so ask whether your own documents should be translated too.
- Practise three answers. What happened, what you understand now and what you have changed, each in a few sentences you can say without notes.
- Answer the question you are asked. If you do not know, say so and offer to follow up in writing.
- Write it up afterwards. Record who attended, what was asked and anything you undertook to do, and send any follow-up by the agreed date.
If the date clashes with a shift or you are unwell, ask in writing for another date before the hearing and give the reason. Simply not turning up is the worst option.
The federal duties most MOHAP complaints turn on
| Source | Duties that often feature | Course |
|---|---|---|
| Federal Law No. 5 of 2019 (doctors and dentists) | Honest and careful practice, fair treatment of every patient and no exploitation (Article 17); advertising only as the rules allow (Article 19); no work outside your licence unless a life is at risk, no selling medicines, no directing patients to a chosen pharmacy and no commissions for referrals (Article 24) | Probity and Honesty in Practice |
| Federal Law No. 6 of 2023 (nurses, midwives, allied health) | Staying within licensed scope, honesty, confidentiality, accurate records, reporting what must be reported and keeping your knowledge current (Article 8) | Ethics and Professional Conduct for Nurses and Midwives |
| Federal Decree-Law No. 4 of 2016 (all professions) | Taking a history before treating, written and signed prescriptions, explaining possible complications in advance (Article 4); consent before treatment and a third person present, with consent, for opposite-sex examinations, emergencies aside (Article 5) | Informed Consent and Chaperones |
| Federal Decree-Law No. 38 of 2024 (pharmacy) | No prescribing or advice for personal gain (Article 42); free samples only to licensed prescribers, marked as not for sale (Article 39) | Ethics and Professional Conduct for Pharmacists |
| Federal Law No. 2 of 2019 (health ICT) | Patient data used for health purposes unless there is written agreement (Article 16) and held inside the UAE except where a health authority allows otherwise (Article 13) | Patient Confidentiality and Health Data |
| Cabinet Resolution No. 7 of 2007 (health advertising) | A MOHAP advertising licence, with its number and expiry date shown; published fines start at AED 4,000 for an unlicensed advertisement | Social Media and Healthcare Advertising Rules |
The 2017 Code of Ethics and the Patient's Charter
The federal benchmark for professional behaviour is still the Code of Ethics and Professional Conduct for Health Professionals adopted in 2017 (Ministerial Resolution No. 1448). Both Dubai's 2025 standards and Abu Dhabi's 2024 bioethics guidelines are presented as building on it. Use the version your facility provides, or request the current text from MOHAP, and quote it precisely if you rely on it in a reflection.
Patients are more likely to know the Patient's Rights and Responsibilities Charter (Ministerial Resolution No. 14 of 2021), which hangs on the walls of clinics and hospitals. It promises dignity, privacy, confidentiality and equal treatment, the right to know who is caring for you, full information before giving consent, the right to say no, access to reports and a cost estimate before surgery. When a complaint is about rudeness, poor explanation or feeling dismissed, the Charter is a good lens for reflecting on what the patient went through.
MOHAP also took part, with the DOH and the Sharjah Health Authority, in the national Healthcare Workforce Bioethics Guidelines released in August 2024.
Healthcare Ethics in UAE Practice
Dignity, Respect and Non-Discrimination in Care
Communicating with Patients and Families
Protections while a MOHAP case is open
- Short, renewable suspension. While a liability report is outstanding, or other breaches are being looked into, the health authority can suspend a licence in blocks of up to 30 days (Federal Decree-Law No. 4 of 2016, Article 23). This protects patients while facts are established; it says nothing about the outcome.
- Advance notice to MOHAP. Another body that wants to investigate you has to write to the licensing authority first, identifying you, your employer and the issue. MOHAP can attend, put documents forward and must be given the result (Article 22; Cabinet Resolution No. 40 of 2019, Article 16).
- A shield against arrest over clinical error. Article 24 rules out investigation, arrest or temporary detention for a medical error unless the health authority has issued a final report finding gross error.
- Separate disciplinary track. Article 38 keeps disciplinary liability apart from criminal liability, so a good result in a criminal matter does not on its own end a disciplinary file.
A deadline calendar for MOHAP cases
| What arrived | Time to act | Who decides | What silence means |
|---|---|---|---|
| A Medical Liability Committee report | 30 days from notification | Supreme Committee of Medical Liability, via the health authority | The report becomes final and binding |
| A penalty on a doctor or dentist | 15 days from notification | The health authority's complaints committee, within 30 days | No answer in 30 days is treated as a refusal |
| A penalty on a nurse, midwife or allied professional | 15 days from notification | The Minister or head of the health authority, within 30 days | No answer is treated as a refusal |
| A refused, revoked or unrenewed non-physician licence | 15 days | Same route, decision within 30 days (Cabinet Resolution No. 176 of 2025, Article 6) | No answer is treated as a refusal |
The clock runs from notification, not from when you read the message. Fifteen days is very little time if you also need your insurer and a lawyer, so contact them the day the decision lands.
Licence, CME and good standing while the case runs
- CME for renewal. MOHAP's service pages list 20 hours for nursing practitioners, 10 for medical and dental technicians, 20 for a pharmacist in charge and 10 for an assistant pharmacist. For doctors the page asks for continuing medical education in the field of the licence but gives no number. None of the pages says whether hours are counted per year or per renewal, so confirm this with MOHAP or your facility.
- Do not let it lapse. Apply at least 30 days before expiry and do not practise on an expired licence. For nurses, midwives and allied professionals, six months without a renewal application, or six months in a row of unexplained inactivity, leads to revocation (Cabinet Resolution No. 176 of 2025, Article 10); doctors have an equivalent six-month rule (Cabinet Resolution No. 67 of 2020, Article 6).
- Good standing. MOHAP will issue a good standing certificate once you have held its licence for three months, and it is valid for six months, but not to anyone with a sentence for a medical offence. The national qualification rules expect good standing to mean no outstanding or past disciplinary orders, so an open file can hold up a licence application in Dubai, Abu Dhabi or overseas. Disclose it.
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.
Getting back to practice after suspension or revocation
The federal regulations build the route back around retraining, reassessment and supervision, with different wording for each part of the workforce.
| Profession | What the regulations allow |
|---|---|
| Doctors and dentists | After a suspension of between three and twelve months the authority can reassess competence, narrow clinical privileges or limit practice (Cabinet Resolution No. 67 of 2020, Article 7.2). After revocation, a new licence is possible once the reasons for it have gone (Article 8). |
| Nurses, midwives and allied health | A fresh application is possible once the reasons for revocation have ended. The authority can attach conditions such as training aimed at those reasons, a new competence assessment, a narrower scope, or a period of direct supervision. A conviction involving honour or trust also requires proof of rehabilitation (Cabinet Resolution No. 176 of 2025, Article 11). |
Start a dated log on the day the case opens: what you studied, what you changed, who saw the change. When you reapply, that log is your evidence.
Building a Remediation Plan After a Concern
Preventing Recurrence After an Error or Incident
Rebuilding Trust After a Complaint
Preparing your reply to MOHAP
- Identify the route and the date. Is this administrative or medical, which committee is involved, and when must you reply or attend?
- Protect the record. The regulations expect every step of care to be recorded with what was done and when (Cabinet Resolution No. 40 of 2019, Article 2). If something must be added, add it as an obvious, dated late entry. Changing an older entry after a complaint can become a new allegation.
- Speak to your insurer. Cover against medical error claims is compulsory, comes from a UAE-licensed insurer and is paid for by the facility owner (Federal Decree-Law No. 4 of 2016, Articles 25 and 26). The policy and the facility's procedure tell you how to notify; the insurer can help with wording.
- Align with your facility. In an administrative complaint MOHAP hears from the facility first, so talk to your medical director or quality lead before you write.
- Build a timeline. Times, people present, what was said and what was noted, keeping what you remember separate from what the file shows.
- Answer the person, not only the allegation. Acknowledge how the patient experienced the care, and say what you have changed.
Responding to a Complaint or Licensing Inquiry
Communicating with Patients and Families
Open Disclosure: Honest Communication When Care Goes Wrong
An illustrative example: late notes at an Ajman clinic
An illustrative scenario only; it describes no real case. A physiotherapist at a private clinic in Ajman receives an administrative complaint through MOHAP. The patient says a treatment caused pain, the risks were never explained and the session notes were written days afterwards.
- The route. The letter alleges no error causing harm, so it reads as an administrative complaint. MOHAP has asked the clinic for a written report first, so he speaks to the clinic manager before either of them writes.
- The law. He is an allied health professional, so his penalty list, and the 15 days he would have to challenge a penalty, come from Federal Law No. 6 of 2023.
- The record. The notes were indeed completed late. He leaves them as they are, says so in his reply and explains that week honestly, without excuses.
- The duties. Federal law expects possible complications to be explained before treatment, and Article 8 of the 2023 law makes accurate records a duty for allied professionals.
- Learning and change. He completes Clinical Documentation and Record Keeping and the ethics course for allied health professionals, reflects in writing on the patient's experience, and now finishes his notes before the next patient comes in.
- His reply accepts the gap in the record, describes the consent discussion as he remembers it, clearly labelled as recollection, and attaches dated evidence of the new habit.
The outcome is still for MOHAP to decide. What it now has is an honest account that matches the clinic's, and something concrete to weigh.
A learning plan a MOHAP committee can follow
MOHAP does not publish a list of remediation courses, and no federal law names one. If training is ordered, for instance as a condition of getting your licence back, do exactly what the order says and check in writing before you substitute anything. If nothing is ordered, a short plan with a clear purpose is more persuasive than a large number of unrelated certificates.
- Start with the process: Facing a Licensing Investigation: The Core Remediation Course, or Responding to a Complaint or Licensing Inquiry if the case has only just begun.
- Address the subject: one or two courses from the concerns table above, plus the ethics course for your licence, whether for nurses and midwives, pharmacists, allied health professionals or doctors.
- Show your thinking: Insight: Understanding and Showing It After a Concern or Reflective Practice and Written Reflections.
Check with your insurer or lawyer before you send anything in as evidence.
Facing a Licensing Investigation: The Core Remediation Course
Responding to a Complaint or Licensing Inquiry
Insight: Understanding and Showing It After a Concern
Reflective Practice and Written Reflections
Ethics and Professional Conduct for Nurses and Midwives
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.
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.
Ethics and Professional Conduct for Nurses and Midwives
Statutory duties under Federal Law No. 6 of 2023, consent, scope and delegation, medicines, advocacy, safeguarding and midwifery law, with UAE case studies.
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.
Questions
I work at a private clinic in Fujairah. Is it MOHAP that will handle the complaint?
Yes. Private facilities in Fujairah, Ajman, Umm Al Quwain and Ras Al Khaimah fall under MOHAP's complaints service. An alleged error goes to a Medical Liability Committee; other complaints begin with a report from your facility and, if needed, an inspection.
How quickly does MOHAP deal with complaints?
MOHAP quotes 45 days, with longer for complex matters. The liability committee is meant to report a month after referral but can be given more time, and any grievance adds to the total.
What is the deadline to challenge a penalty from MOHAP?
Fifteen days from the date you are notified, under both federal profession laws. Doctors and dentists go to the health authority's complaints committee; nurses, midwives and allied professionals go to the Minister or the head of the authority. If there is no reply within 30 days, treat the grievance as refused.
Which law decides my penalty?
For doctors and dentists, Federal Law No. 5 of 2019. For nurses, midwives and allied health professionals, Federal Law No. 6 of 2023, which has lower maximum fines and a shorter maximum suspension. Pharmacists should ask MOHAP which provision applies to them.
Is a complaint inside an Emirates Health Services hospital handled the same way?
Not necessarily. The MOHAP complaints service is aimed at private facilities. In a federal facility the liability law still applies, but disciplinary matters for government employees may follow federal HR rules, so ask your employer which procedure it is using.
Could my licence be suspended before the committee reports?
It could. The health authority may suspend a licence for periods of up to 30 days, which can be renewed, while a liability report is outstanding. It is a protective step and does not mean the committee has decided against you.
My nursing licence was revoked. Is there a way back?
There can be. Once the reasons for revocation no longer exist you may reapply, and MOHAP can set conditions such as targeted training, a fresh competence assessment, a narrower scope or supervised practice.
Will a MOHAP case follow me if I move to Dubai or Abu Dhabi?
Very likely. A new authority will want a recent good standing certificate, and the national rules treat open or past disciplinary orders as relevant. Tell the receiving authority about the case at the start.
Does MOHAP recommend particular remediation courses?
MOHAP does not publish a course list. Ordered training is set case by case. Learning you choose yourself can support your reflection but does not replace ordered training. 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.
- MOHAP service: Complaints about private health facilities and their medical staff
- MOHAP: e-complaint system for healthcare malpractice in private facilities (October 2021)
- MOHAP: Renewal of a License to Practice as a Doctor
- MOHAP: Renewal of Licenses for Nursing and Medical Professionals
- MOHAP Services Guide (English)
- MOHAP: Issue a Good Standing Certificate for a Health Professional
- MOHAP: Monitoring of Health Advertisements
- Ministerial Resolution No. 14 of 2021, Patient's Rights and Responsibilities Charter
- 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
- Federal Decree-Law No. 38 of 2024 Governing Medical Products, Pharmacists and Pharmaceutical Establishments
- Federal Law No. 2 of 2019 on the Use of ICT in Health Fields
- Unified Healthcare Professional Qualification Requirements (PQR), 3rd version
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.