UAE music licensing: what hotels, retailers and gyms should prepare before 1 December 2026

Businesses operating hotels, restaurants, shops, malls or fitness venues in the United Arab Emirates should begin preparing well before 1 December 2026. The UAE Ministry of Economy and Tourism has announced that fee collection under its Collective Management in Music Guide is due to start at the beginning of December.

The practical issue is not simply whether a venue plays music. It is whether the organisation can clearly explain how music is used at every site, who controls that use, what contracts already exist and which rights those contracts actually cover.

This is a general operational guide, not legal advice. The applicable position should be reviewed with UAE-qualified legal advisers and against the relevant official materials before any decision is made about licensing, tariffs or exemptions.

The Ministry states that the Guide was issued pursuant to Ministerial Resolution No. 136 of 2026 and sets fees relating to collective management in music. Its announcement names restaurants and cafés, shopping malls, fitness centres, hotels and floating hotels, airlines, radio stations, television channels, concerts and similar events among the relevant categories.

The Ministry also states that Emirates Music Rights Association and Music Nation are authorised to conduct collective management of music rights and to collect the announced fees. That does not mean either organisation automatically administers every recording, composition, performance right or use case. A business receiving a request should establish the authority, mandate and repertoire relevant to that request.

According to Al Tamimi & Company, Ministerial Resolution No. 136 of 2026 was issued on 29 June and took effect on 6 July 2026. Collection under the annexed tariff schedule starts on 1 December 2026. The resolution’s effective date and the start of fee collection are therefore distinct.

A hotel lobby playing background music, a restaurant running a DJ night, a retail shop using a consumer streaming account, and a gym hosting instructor-led classes may all involve music, but they should not be assumed to present the same licensing position.

Start by separating recorded background music, live performances, DJ sets, broadcast radio, television audio, event music and music delivered through digital services. This avoids an all-too-common mistake: treating one supplier agreement as proof that every music use in every venue is covered.

The distinction between a managed in-store programme and an unmanaged playlist is also operationally important. An in-store radio is not simply a playlist: it can involve defined programming, ownership of responsibilities and a clearer audit trail.

List each legal entity, venue, emirate, site type and publicly accessible area. For hotels, separate reception areas, restaurants, bars, event rooms, spas, pools, gyms and lounges. For retail groups, include standalone shops, concessions, pop-ups and mall locations.

For every area, document the source of music, devices used, operating hours, volume control, staff responsible, content provider, use of radio or television, and whether DJs, performers or event agencies are involved. Note seasonal events and one-off activations as well as everyday background music.

Gather agreements with music providers, AV suppliers, event agencies, DJs, performers, franchisees and landlords. Keep invoices, licence documents, terms of service, repertoire statements and any correspondence about rights. The purpose is not to reach a legal conclusion internally; it is to give local advisers a reliable factual record.

Operations may know what is played in practice, procurement may hold supplier contracts, legal may manage risk and marketing may approve branded events. Name a responsible owner for the music-use register and a process for approving changes. This matters especially where different locations have autonomy over content.

The Ministry’s announcement refers to exemptions for educational and academic institutions, government entities, use during national occasions and non-commercial personal celebrations, as well as further exemptions that the Ministry may decide. These categories should not be applied by analogy without local advice.

Nor should businesses assume that a publicly reported tariff figure will apply to their venue. The legal commentary consulted describes a pricing matrix using different factors, including seating capacity, floor area, room count or a percentage of annual revenue depending on the sector. Classification and tariff treatment need to be checked against the applicable text and the facts of the individual operation.

Likewise, a direct licence or a contract with an audio supplier may be relevant, but it does not automatically settle whether any local collective-management requirement applies. Coverage depends on the rights, repertoire, territory, term and permitted uses in the agreement.

For multi-site businesses, this is a governance task as much as a licensing task. A central register can help teams compare venues, spot undocumented music uses and avoid duplicate or inconsistent responses to enquiries.

It can also improve future procurement. A music brief should identify whether a provider is supplying content, equipment, programming, technical delivery or rights clearance, rather than leaving those roles blurred. For a wider overview of the commercial value of structured music planning, see our guide to music for shops.

The announced 1 December 2026 start date is a reason to prepare, not a reason to make assumptions. Map the sites, music uses and contracts now; then obtain UAE legal advice on the relevant category, authorised collecting body, tariff treatment and any available exemption. A documented assessment is more useful than a rushed, one-size-fits-all response.

No. The announced framework refers to different categories and criteria. The applicable outcome may depend on the sector, venue characteristics and nature of music use.

Not necessarily. Its terms need to be checked for repertoire, rights, territory, duration and permitted commercial uses.

A list of venues, seating and event areas, music sources, DJ or live-music activity, supplier agreements and internal contacts responsible for each site.

The Ministry named Emirates Music Rights Association and Music Nation. Their authority and relevant repertoire should still be confirmed for a specific request.

No. It is general information to support internal preparation. Individual licensing and tariff questions require qualified local advice.