Music licensing in the UAE: what the December regime actually requires
From 1 December the collecting bodies begin invoicing. The obligation itself is four years old: what is new is the machinery, and the hardest question is which entity in your structure owes the fee.
From 1 December 2026, businesses across the UAE that use music commercially will need an annual licence. The Ministry of Economy and Tourism announced on 11 August the launch of its Collective Management in Music Guide under Ministerial Resolution No. 136 of 2026, covering restaurants and cafés, shopping malls, fitness centres, hotels and floating hotels, airlines, radio stations, television channels, and concerts and similar events. The Emirates Music Rights Association and Music Nation have been authorised to collect the fees and to distribute payments to creators and rights holders.
The measure is being reported as a new burden on business. It is not, and the distinction matters for anyone assessing exposure for periods already past.
The obligation is older than the machinery
Federal Decree-Law No. 38 of 2021 on Copyright and Neighbouring Rights, with its Executive Regulations under Cabinet Resolution No. 47 of 2022, has supplied the statutory basis for collective management since it took effect. Public performance of protected musical works has required the rights holders’ authorisation throughout. A café playing recorded music to customers in 2024 engaged the economic rights of composers, lyricists, performers and phonogram producers exactly as it will in 2027. The Guide merely adds a mechanism: published tariffs, defined categories, authorised collecting bodies, a commencement date.
The tariffs
The Ministry’s announcement gave no figures. Emirates 24|7 later reported the full matrix and, in summary, Gulf News, and the two accounts agree throughout. The figures below are press-reported rather than taken from the Guide itself.
| Category | Annual fee (AED) |
|---|---|
| Restaurants and cafés | 1–50 seats: 1,500 · 51–100: 2,700 · 101–200: 4,800 · above 200: +20 per seat · maximum 6,000 |
| Venues with DJ services or similar entertainment | 1–50 seats: 2,500 · 51–100: 3,500 · 101–200: 6,500 · above 200: +20 per seat · maximum 8,000 |
| Shops and commercial complexes | to 300 sqm: 1,700 · 301–700: 3,400 · beyond: +60 per 25 sqm · maximum 20,000 |
| Large shopping malls | 625 for the first 100 sqm · +50 per additional 25 sqm · maximum 50,000 |
| Gyms and fitness centres | to 300 sqm: 1,700 · beyond: +5 per sqm · maximum 6,000 |
| Hotels, 1–2 star | 1–50 rooms: 50 per room · 51–100: 5,000 · 101+: 8,000 |
| Hotels, 3 star | 1–50 rooms: 120 per room · 51–100: 12,000 · 101+: 18,000 |
| Hotels, 4–5 star | 1–50 rooms: 150 per room · 51–100: 15,000 · 101–200: 18,000 · 201+: 25,000 · maximum 25,000 |
| Radio | general programming: 1% of annual income · music stations: 3% · minimum 1,700 |
| Television | general programming: 1% of annual income · news: 0.25% · minimum 1,700 |
| Airlines with integrated entertainment | 1–50 seats: 5,000 · 51–300: 10,000 · 301–500: 30,000 · 501+: +75 per seat · maximum 45,000 |
The sector has asked for a delay
Emarat Al Youm reported on 19 August that hotel executives are asking for postponement or phased implementation. Those interviewed accepted the importance of regulating intellectual property rights for authors and musicians, while proposing that the hospitality sector be given more time, or the resolution applied in stages, to help hotels manage operating costs.
The complaint is not about quantum. Walid Al Awa of Tamani Marina said the resolution does not impose large sums and that hotels can bear them, observing that up to AED 15,000 for a mid-range hotel is not, in his view, a high cost. The difficulty is operational: Medhat Barsoum of Capitol Hotel Dubai noted that hotel management frequently does not know which rights holders the music being played belongs to, and asked how hotels are to identify them and through what mechanism dues are paid to the two licensed bodies. Munther Darwish of Palazzo Versace Dubai said the implementation mechanism remains insufficiently clear to him and to his staff. Husni Abdulhadi of Carlton Hotels proposed deferral to next year, noting the precedent of Dubai’s Department of Economy and Tourism deferring room sales fees, food and beverage fees and the Tourism Dirham for hotel establishments under its second package of economic facilitations.
It remains unclear whether the Ministry will accommodate any of this. But most of the questions raised can now be answered.
Does one licence clear everything?
Operators have asked whether paying the annual fee confers the right to play any music, and whether an official database exists identifying which songs and artists may lawfully be played.
The answer follows from the structure. Two authorised bodies exist, and a licence from either covers only the repertoire that body represents. They are differently constituted and differently connected: EMRA, licensed in April 2025, is a non-profit association, while Music Nation, licensed in June 2025, is a commercial entity. Music Nation has partnerships with BMI and SoundExchange; EMRA’s launch was supported by IFPI and CISAC.
Different affiliations mean different repertoire. A user should establish what each licence covers before assuming a single arrangement clears its whole operation, and equally before paying twice for works both bodies represent. This is not the single-society model familiar from jurisdictions where one accredited organisation licenses each category of right, including for rights holders who have no contract with it. Here the burden of establishing coverage rests on the user.
Streaming subscriptions and royalty-free music
The most common misconception concerns streaming, and it was the sector’s first question. A personal subscription to a streaming platform does not, by itself, entitle a restaurant, shop, or hotel to play songs publicly for customers: personal listening rights are legally distinct from the right to perform or communicate music publicly in a commercial setting.
A collective management licence resolves the copyright question. It does not resolve the contractual one. Consumer streaming services prohibit commercial use in their terms, and holding a licence from EMRA or Music Nation does not vary a contract with a third-party platform. A business needs a service whose own terms permit commercial playback, as well as the licence.
Nor does “royalty-free” material remove the requirement. The description signals the absence of recurring per-use payments; it says nothing about whether the particular licence extends to public performance in commercial premises. Many such licences cover online content only. The instrument must be read.
The hotel problem
Operators have asked whether, where a restaurant inside the hotel is leased to a separate operator, the hotel can recover the fee from that lessee. This is the commercial heart of the matter, and the answer lies in the parties’ contracts rather than in the Guide.
Hotels illustrate the difficulty better than any other sector, because the operating structure separates the party controlling the use of music from the party paying for it. Under the common management model, the operator supplies the brand and the operating standards and directs how the hotel is run, including what plays in guest rooms and public areas. The staff implementing those standards are often selected by the operator but employed by the owning company, which covers payroll and operating costs. Neither is the obvious licensee: the operator decides but neither owns the premises nor bears the cost, while the owner bears the cost but exercises no practical control over what is played.
Management agreements usually deal with this by treating licensing and intellectual property costs as operating expenses for the owner’s account, or by carving out costs attributable to the operator’s brand and systems. Whether background music in guest rooms falls on one side of that line or the other is rarely stated, and the answer now carries a price.
The position fragments further within a single building. As Morgan Lewis notes, the hotel tariff applies to music used within hotel rooms, while restaurants, halls, commercial stores, and entertainment facilities within a hotel are excluded and may fall under their own category-specific tariffs. A hotel is therefore not one user but several, each potentially operated by a different party under a different contract. Existing contracts and the obligations arising from them continue under their terms, provided they do not conflict with UAE law, so drafting settled years ago, without this schedule in mind, will decide the outcome.
Owners, operators and tenants should establish now who is expected to hold each licence. The collecting bodies deal with the user of the music and are indifferent to how cost has been allocated between the parties; a business that has agreed the expense lies elsewhere still owes the licence, and is left to recover under its contract.
Two questions that remain open
Operators have asked whether the resolution extends to furnished apartment establishments. Serviced apartments are a large part of the Dubai market, and the published categories name hotels and floating hotels without addressing them.
It has also been asked how the regime treats a hotel hosting a well-known performer singing songs belonging to other artists, and whether that requires additional licences. Live performance of third-party repertoire engages the performing right in the underlying composition, which is a different analysis from background recorded music.
Both need the Guide’s own definitions and should be put to the Ministry or the collecting bodies rather than answered by inference.
Exemptions
Educational and academic institutions, government entities, uses occurring on national occasions and non-commercial personal celebrations are exempt, and the Ministry may exempt further categories by resolution.
Ten per cent of collections is allocated to a Cultural Support Fund for Music, supervised by the Ministry and managed by a joint committee drawn from the Ministry of Economy and Tourism and the Ministry of Culture, with collecting bodies required to hold it in a separate account. Gulf News reports that this allocation forms part of the twenty-five per cent share referred to in the executive regulations, which, if right, makes the Fund a carve-out from an existing deduction rather than an addition.
Finally, where regulatory necessity or the public interest requires, the Ministry may amend the terms, controls or obligations attached to a collective management licence during its validity, and the licensed body must implement the amendment immediately on approval. The Ministry will review the tariff matrix periodically in light of the inputs it receives. Budgeting on the assumption that tariffs hold across a licence year would be optimistic.
Before December
Establish where music is used across the business: guest rooms, customer areas, events, broadcast and digital channels. Match each use to its category rather than assuming one licence covers the operation. Check that the delivery method itself permits commercial playback, and read the licence behind any royalty-free material. Review the contracts allocating responsibility for licensing costs between group companies, operators, tenants, franchisees and event counterparties. Then budget, having confirmed the repertoire each licence covers and the ceilings that apply.
This article is provided for general information and does not constitute legal advice. Tariff figures are as reported in the press and should be confirmed against the Guide and with the relevant collecting body before use.