The UAE’s new music licensing regime: what every venue must do before 1 December 2026

What actually changed — and what did not

A point of confusion worth clearing first: playing copyright music in a UAE venue without permission has been unlawful for years. Federal Decree-Law No. 38 of 2021 on Copyright and Neighbouring Rights, in force since January 2022, already reserves public performance and communication to the public to the rightsholder. What was missing was the machinery: no licensed body existed to grant permission at scale, so most businesses simply carried an unpriced legal risk and nobody collected.

That machinery now exists. The Ministry of Economy and Tourism has issued collective management licences — the first, in April 2025, to the Emirates Music Rights Association (EMRA), developed in cooperation with CISAC and IFPI, with Music Nation also authorised — and has published a Collective Management Guide for Music together with an approved rate card. Annual fees apply from 1 December 2026. The obligation is not new; the invoice is.

The two-rights problem most businesses miss

A single recording playing in your lobby engages two separate layers of rights: the musical work (the composition and lyrics, owned by writers and publishers) and the sound recording (the specific master, owned by the performer and producer, protected in the UAE as a neighbouring right). Clearing one does not clear the other. This is why collective management exists internationally — a venue cannot realistically negotiate with every writer and label — and why your compliance question is not “do I have a licence” but “do my licences cover both layers of every track I play”. Operators should confirm the scope of repertoire each authorised body represents before assuming a single licence closes the exposure.

Who needs a licence

The regime reaches commercial music use broadly. Publicly identified categories include restaurants and cafés; hotels and floating hotels; shopping malls and retail outlets; fitness centres and gyms; airlines; radio stations and television channels; and concert venues and event organisers. In practice the test is functional rather than sectoral: if copyright music is being communicated to the public in connection with a commercial activity, the regime is engaged. That catches places operators rarely think about — spa and treatment rooms, hotel gyms and pool decks, retail fitting rooms, corporate reception areas, on-hold telephone music, branded events and activations, and music in social-media content produced for the business.

Who is exempt

The published exemptions are narrower than most assume: government entities, educational and academic institutions, music played during national occasions, and personal celebrations or non-commercial events, with further categories addable by Ministry decision. Read them as activity-based, not entity-based: a university is exempt for teaching, but a ticketed commercial concert on its campus is a different question. The same caution applies to charitable and community events with commercial sponsorship or paid admission.

What it will cost

The rate card is approved, and fee brackets vary by the nature of the music use and the size of the economic activity — with live performances and DJ sets attracting higher fees than recorded background music. The Ministry did not publish individual tariff amounts alongside the announcement, so venues should obtain a written quotation from the relevant authorised body against their own floor area, capacity and usage profile rather than budgeting from rumour. Licences run for one year and are renewable, and 10% of collected fees is directed to a Cultural Support Fund for Music overseen by the Ministry of Economy and Tourism with the Ministry of Culture.

The mistake that will catch most venues

Ask a venue manager what licenses their music and the answer is usually a consumer streaming account. It does not. Spotify, Apple Music, YouTube and equivalent consumer services license personal, private listening only — their terms expressly exclude commercial and public use. A venue playing a personal account is not partially covered; it is unlicensed for the public performance entirely, and the account itself is being used in breach of contract. The correct stack is a commercial background-music service (which clears the delivery) plus the public-performance position (which, from December, means the collective management licence). Businesses that budget only for the second and keep using a personal Spotify account have solved half the problem.

The exposure, in actual numbers

This is where the commercial calculus becomes obvious. Under Article 39 of Federal Decree-Law No. 38 of 2021, infringing an author’s or neighbouring rightsholder’s economic or moral rights without written permission carries imprisonment of not less than two months and/or a fine of AED 10,000 to AED 100,000, without prejudice to any more severe penalty under another law. Article 40 attaches materially higher fines to certain aggravated conduct. Rightsholders can pursue civil remedies alongside, and for a multi-site group the risk is not one penalty but the same penalty repeated across the estate — against an annual licence fee that is, for most venues, a rounding error on the F&B line.

What to do before 1 December

1. Audit the estate. Every location where music is audible to the public or to customers, including the places nobody lists: gyms, spas, pool decks, hold music, events, and content your marketing team posts. 2. Separate the categories. Recorded background music, live performance and DJ sets price differently — know your mix before you ask for a quote. 3. Get a written quotation from the authorised body against your actual floor area, capacity and usage. 4. Fix the supply chain. Replace consumer streaming accounts with a commercial service. 5. Paper the responsibility. Event contracts, DJ and band agreements, franchise and management agreements and venue-hire terms should say expressly who obtains and pays for the licence — the assumption that “the DJ has it covered” is not a defence for the venue. 6. Diarise the renewal, because a one-year licence lapses quietly.

For groups with multiple brands or franchised sites, this is a governance exercise as much as a licensing one — and it sits naturally alongside the wider intellectual property and brand protection work most hospitality and retail operators are already doing. Businesses whose model is music or content — venues, promoters, labels, and creators and influencers — should also revisit how rights are cleared in their own productions, and whether their catalogue is registered so they are collecting from this system rather than only paying into it.

Do I need a licence to play music in my restaurant or cafe in the UAE?

From 1 December 2026, yes - if the music is protected by copyright and it is being played as part of a commercial activity. The UAE's new collective management framework requires businesses that publicly perform or play music (including recorded background music, live sets and DJ performances) to hold an annual licence from a Ministry-authorised collective management organisation. Neo Legal advises hospitality, retail and leisure operators on whether their use falls inside the regime and which licences they need.

Does a Spotify, Apple Music or YouTube subscription cover my business?

No - and this is the most common and most expensive misunderstanding. Consumer streaming subscriptions are licensed for personal, private listening only; their terms of service expressly exclude commercial and public use. Playing a personal streaming account in a venue leaves the business unlicensed for the public performance entirely. Businesses need either a commercial background-music service or the appropriate public-performance licence - and in the UAE, from 1 December 2026, the collective management licence sits on top of that.

Who administers music licensing in the UAE?

The Ministry of Economy and Tourism has authorised two collective management organisations to license commercial music use and collect royalties: the Emirates Music Rights Association (EMRA), which received the UAE's first collective management licence in April 2025 under Federal Decree-Law No. 38 of 2021, and Music Nation. Ten per cent of the fees collected is directed to a Cultural Support Fund for Music overseen with the Ministry of Culture.

Which businesses are exempt from the UAE music licensing regime?

The published exemptions cover government entities, educational and academic institutions, music played during national occasions, and personal celebrations or genuinely non-commercial events. Further categories may be added by Ministry decision. Exemption is activity-based rather than entity-based, so a school or government body running a commercial ticketed event should take advice rather than assume the exemption travels with it.

What are the penalties for playing music without a licence in the UAE?

Unlicensed public performance is copyright infringement under Federal Decree-Law No. 38 of 2021. Article 39 provides for imprisonment of not less than two months and/or a fine of between AED 10,000 and AED 100,000 for infringing an author's or neighbouring rightsholder's economic or moral rights without written permission, with aggravated conduct under Article 40 attracting materially higher fines. Rightsholders may also pursue civil remedies, and the practical exposure for a multi-site operator is the same penalty risk repeated per venue.

What should businesses do before 1 December 2026?

Audit where music is actually used across the estate (dining areas, lobbies, gyms, retail floors, hold music, events), identify whether live performances or DJ sets are involved because those attract higher tariffs, approach EMRA to obtain a quotation under the approved rate card, budget the annual fee, and review supplier and event contracts so responsibility for licensing is allocated in writing rather than assumed. Neo Legal runs this as a fixed-scope compliance review for hospitality and retail groups.