A New Era for Music Licensing in the UAE
The United Arab Emirates is moving from a legislative framework for collective management of music rights to a more operational licensing and tariff regime. The UAE Ministry of Economy and Tourism recently issued Version 1.1 of the Collective Management Guide for Music (the Guide), which is due to be implemented from 1 December 2026. The Guide provides further detail on how the collective management regime is intended to operate, including tariffs applicable to a range of commercial users of music.
Understanding Collective Management Organizations
Copyright and neighboring rights in music can involve multiple categories of rights holders, including songwriters, composers, performers, music publishers, and producers of sound recordings. Obtaining licenses separately from every relevant rights holder may be impractical for commercial users, while individual rights holders may also find it difficult to license and administer every use of their music directly.
Collective management organizations (CMOs) provide a mechanism through which those rights can be administered collectively, including by licensing uses of protected music, collecting remuneration, and distributing it to relevant rights holders. For a business, the practical effect is a more structured route for clearing music rights, with licenses and remuneration administered through the relevant CMO in respect of the rights it represents.
The UAE Framework
Federal Decree-Law No. 38 of 2021 concerning Copyright and Neighboring Rights (the Copyright Law) and Cabinet Resolution No. 47 of 2022 concerning its Executive Regulations already provide the legislative basis for collective management and establish the framework under which entities may be licensed to carry out collective management activities in the UAE.
The UAE collective management framework is now being put into practice, with Emirates Arts and Music Rights Association and Music Nation operating as CMOs in the UAE. This shift from a legislative foundation to active implementation marks a significant development for businesses that use music commercially.
What the Guide Means for Businesses
The Guide identifies a broad range of commercial users, including restaurants and cafés, retail stores and commercial complexes, shopping centers, gyms and health clubs, hotels, certain aviation services, radio stations, and television channels. Using protected music in a business environment—even as part of the customer experience—may be sufficient to bring a business within the licensing framework.
The Ministry's tariff matrix applies different methodologies according to the relevant sector and the nature and scale of the use; there is no single fee for every commercial user. Restaurants and cafés are generally assessed by seating capacity, with different tariffs for establishments with DJ services or similar entertainment. Retail stores, commercial complexes, shopping centers, and fitness facilities are generally assessed by floor area, while hotel tariffs depend on the hotel's classification and number of rooms. The Guide also establishes maximum annual collection limits for several categories.
A key nuance for the hospitality sector: the hotel tariff applies to music used within hotel rooms, but restaurants, halls, commercial stores, and entertainment facilities within a hotel are excluded from that tariff and may fall under their own category-specific tariffs. This means a single hotel property could be subject to multiple tariff calculations, depending on the various services it offers.
Exemptions and Transitional Provisions
The Guide identifies certain exemptions from the collection regime, including educational and academic institutions, government entities, uses connected with national occasions, and personal celebrations or events of a non-commercial nature. The Ministry may also exempt additional uses or categories by decision.
For businesses already holding licenses, the tariff schedule states that existing contracts and obligations arising from them will continue in accordance with their terms, provided that they do not conflict with applicable UAE laws. This transitional provision may provide some comfort to businesses with multi-year agreements, though they should still review their contracts to ensure compliance with the new regime.
Preparing for Implementation
Businesses should start preparing now, even though implementation is more than a year away. Legal experts recommend a systematic approach: map music use across all operations, match each use to the relevant tariff category, review existing licenses and contracts, and confirm coverage and budget for implementation.
The assessment of music use may be relatively straightforward for a single venue, but more complex for hotel groups, mall operators, franchise networks, and mixed-use developments. Such entities may need to undertake a more granular review to identify every instance of music use, from background music in common areas to live performances in food and beverage outlets.
A targeted review ahead of 1 December 2026 can help businesses identify the applicable categories, understand their potential exposure, and avoid compliance gaps and unnecessary duplication of licensing costs. With the right preparation, the transition into the new collective management regime can be managed smoothly, allowing businesses to continue using music to enhance their customer experience without regulatory surprises.