Music licensing in the UAE: What businesses should do before 1 December 2026
The UAE’s new framework for the collective management of music rights is moving from policy to implementation.
The Ministry of Economy and Tourism’s Guide to Collective Management in Music applies not only to licensed collective management organisations and rights holders, but also to businesses and establishments that use protected musical works and require licences.
For commercial users of music, the practical question is therefore no longer simply whether music is being played. It is whether the business understands where music is being used, how it is being used, who is responsible for that use and whether the licence obtained actually corresponds with the activity taking place.
The tariff system annexed to the Guide is due to apply from 1 December 2026.
For businesses in hospitality, retail, leisure, entertainment and other music-intensive sectors, the period before implementation should be used to identify gaps rather than waiting for them to emerge through a licensing demand or dispute.
The starting point should be the music, not the business licence
A common mistake is to review music licensing at company level.
The Guide works differently. Different categories are assessed according to different criteria. Restaurants and cafés are generally assessed by seating capacity, shops and fitness centres by area, hotels by room numbers, and radio and television businesses by reference to revenue and content type.
This becomes particularly important for mixed-use properties.
For example, the Guide provides that the hotel tariff relates to the use of musical works within hotel rooms. Restaurants, halls, shops and entertainment facilities within the same hotel are subject to the tariffs applicable to their own categories.
A hotel operator should therefore not assume that one hotel licence automatically resolves every music use within the property.
The same issue can arise in malls, leisure developments and businesses operating multiple outlets.
Six steps businesses should consider taking now
1. Map every place where music is used
Begin with an operational audit rather than a legal one.
Identify where music can be heard by customers, guests or visitors, including:
• guest rooms and common areas
• restaurants, cafés and lounges
• gyms and fitness facilities
• shops and retail areas
• ballrooms and event spaces
• live entertainment areas
• DJ-led venues
• websites, applications or digital platforms where relevant
The Guide expressly recognises a wide range of users and methods of making music available, including background music, live performances, broadcasting and digital services.
The purpose of the exercise is to create a music-use map for the organisation.
2. Identify the correct category for each use
Once the locations have been identified, businesses should test each one against the categories in the Guide.
The charging method can differ materially depending on the activity. Restaurants and cafés with DJs, for example, are treated separately from ordinary restaurants and cafés because of the more intensive use of music.
This means that simply knowing the size of a business or the number of premises may not be enough. The nature and intensity of the musical use also matter.
3. Test existing licences against actual operations
The next question is whether the documentation reflects what actually happens on site.
Businesses should review:
• which company holds the licence
• which premises it covers
• what types of music use are included
• whether different facilities require separate treatment
• whether newly opened or expanded areas have been considered
• whether live music or DJ activity changes the applicable category
The first article in this series identified this as one of the areas most likely to produce disputes: a business may have paid for a licence but still face disagreement over whether the licence corresponds with the way music is actually being used.
4. Review the contracts around the music use
Music is often provided or controlled by someone other than the premises operator.
That may include event organisers, DJs, entertainment providers, tenants, venue hirers, hotel operators, restaurant operators or third-party music suppliers.
Businesses should review contractual provisions dealing with:
• responsibility for obtaining licences
• warranties that required permissions are in place
• indemnities for infringement
• cooperation if a claim is received
• responsibility for maintaining records
• allocation of costs and liability
The contractual position matters because a regulatory or infringement issue with a rights holder may also generate a separate contractual dispute between the businesses involved.
5. Build the evidence before it is needed
Good record-keeping can materially reduce uncertainty when a licensing query arises.
Businesses should consider maintaining a central record containing:
• licences and supporting correspondence
• premises and music-use information
• invoices and payments
• agreements with entertainment and music providers
• information identifying when and where music is played
• documentation showing changes to premises or operations
This is particularly important where an organisation operates a portfolio of venues rather than a single site.
The Guide also links tariffs to actual use and requires transparency in the basis on which tariffs are determined.
6. Create an internal ownership process
Music licensing should not sit somewhere between Operations, Marketing, Events, Procurement and Legal with no clear owner.
For larger organisations, it may be useful to designate one central function responsible for:
• maintaining the music-use register
• coordinating licence applications and renewals
• reviewing new venues and events
• maintaining contracts and supporting documents
• escalating licensing demands or disputes to Legal
That governance step is particularly relevant for hotel groups, restaurant groups, malls and businesses operating several UAE locations.
Some sectors require closer attention
The Guide’s tariff matrix demonstrates why a one-size-fits-all approach is unlikely to work.
Restaurants and cafés are assessed principally by seating capacity, while establishments providing DJ services are placed within a separate tariff structure.
Shops and commercial complexes are assessed primarily according to floor area.
Fitness centres are also assessed by area.
Hotels are assessed by reference to room numbers and hotel classification, although other facilities within the property may require separate consideration.
For activities not specifically classified, including sporting events, theatre performances and cinemas, the Guide states that the tariff will be determined in accordance with the relevant contractual provisions.
That is an area where obtaining clarification before an event may be considerably easier than resolving the position afterwards.
Do not assume an exemption applies
The Guide provides exemptions for educational and academic institutions, government entities, uses connected with national occasions and non-commercial personal celebrations. The Ministry may also exempt other categories by decision.
Commercial businesses should therefore avoid assuming that incidental use of music, or the fact that music is not their core business, automatically takes them outside the framework.
The practical objective is not simply to obtain a licence
The better objective is to be able to answer five questions clearly:
Where do we use music?
How do we use it?
Which entity is responsible for that use?
What licence or permission covers it?
What evidence do we have to demonstrate compliance?
If those answers are clear before 1 December, the organisation will be in a much stronger position to deal with licensing queries, tariff discussions and potential disputes.
The first article in this series examined where disputes may arise under the new framework. The next will look more closely at how the tariff system operates across hospitality, retail, leisure and other affected sectors.
Disclaimer: This article provides general information only and does not constitute legal advice. Businesses should review their own use of musical works, obtain the current applicable licensing information and take advice on their specific circumstances.
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Essa Ziad Galadari Managing Partner – Abu Dhabi, Deputy Head of Litigation, Dubai [email protected] |
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Raka Roy Partner, Head of IP & Data Protection [email protected] |
