Three things catch marketing teams here. **Promotions and prize draws generally need a permit.** **Cold outreach is regulated** — the Do Not Call rules sit on top of data protection consent. And the **cybercrime framework reaches marketing content**, including images of people published without their consent.
Marketing and Advertising
Claims, promotions, permits and outreach
Three things catch marketing teams here. Promotions and prize draws generally need a permit. Cold outreach is regulated — the Do Not Call rules sit on top of data protection consent. And the cybercrime framework reaches marketing content, including images of people published without their consent.
| Item | Detail |
|---|---|
| Company | [COMPANY NAME], [licence] [NUMBER] |
| Jurisdiction | [Mainland / free zone / DIFC / ADGM] |
| Data protection regime | [Federal PDPL / DIFC / ADGM] |
| Channels used | [Website, email, SMS, calls, social, print, outdoor] |
| Promotions run? | [Y/N — permit position] |
| Consent records held in | [SYSTEM] |
| Suppression list maintained in | [SYSTEM] |
| Approver of marketing content | [NAME] |
| Version and date | [NUMBER], [DATE] |
1. Claims
| Rule | Detail |
|---|---|
| Be accurate | Claims must be truthful and capable of substantiation |
| Hold the evidence before publishing | Not after a challenge |
| Price claims must be honoured | The advertised price is the price charged |
| Prices shown to consumers include VAT | Adding it at checkout is a contravention |
| Discount claims need a real previous price | It must genuinely have been charged |
| Comparisons must be fair and like-for-like | And substantiated |
| Avoid absolute claims you cannot prove | "Best", "cheapest", "number one" |
| Respect the culture and the law | Content offensive to religion or public morals is a serious matter |
| Arabic where required | Labelling and certain consumer-facing content |
| Regulated sectors have their own rules | Health, financial services, education, property |
1.1Keep the substantiation file with the campaign. A claim you could have proved at the time but cannot evidence six months later is, in practice, an unsubstantiated claim.
2. Promotions and Prize Draws
2.1Promotions, competitions, raffles and prize draws generally require a permit from the relevant economic department, with fees and conditions.
5 more pages in the Word file
This is page 1 of the Word document, exactly as it appears when you open it. Fields shown like THIS are placeholders for you to complete.
These notes accompany the template and explain the drafting choices, the compliance points and the mistakes most often made with this document. They appear as a final page in the Word file, intended to be deleted before the document is executed.
Competitions, raffles and prize draws typically require a permit from the relevant economic department, with fees and conditions. Social media giveaways are the version people do not think of as a promotion, and they generally are. Apply before announcing anything.
Telemarketing and SMS are regulated separately from data protection consent, and meeting one does not satisfy the other. Check both before any calling or texting campaign to UAE numbers.
A purchased list carries no demonstrable consent, no reliable suppression history and no way to answer a subject access request. It is the fastest route to a complaint and there is no way to remediate it afterwards.
Photographs of identifiable customers, staff, event attendees or members of the public published without permission engage the cybercrime framework as well as data protection. Event photography is the routine trap — photograph the room, publish it, then be asked to remove someone.
And honour a withdrawal, including from material already published where practicable. An employee who did not feel able to refuse has not really consented, which is the same problem as employee consent generally.
An objection to direct marketing is absolute — no balancing exercise applies. Continuing because the request arrived on a different channel or in the wrong inbox is not a defence, which is why the suppression list must be central.
A single tick box covering both service delivery and marketing is not valid consent. Ask separately, record what wording was shown, and keep the timestamp.
When a complaint arrives, the question is what the person actually agreed to. A flag saying "opted in" with no record of the wording or date answers nothing.
And the advertised price must be honoured. Adding VAT at checkout to a displayed price, or refusing to sell at the advertised price, is a contravention as well as a conversion problem.
A claim you could have proved at the time but cannot evidence six months later is, practically, unsubstantiated. File the evidence with the creative, not in someone’s inbox.
The higher price must actually have been charged, and several emirates regulate promotional pricing directly. Retain the evidence of the earlier price — it is what an inspection asks for.
Engaging an unlicensed influencer for paid promotion creates exposure for the brand as well as the individual. Confirm their licensing position and disclose the partnership.
Where an agency holds your marketing lists or runs campaigns on your behalf, a processing agreement is required, the suppression list must reach them, and the transfer position needs assessing where they sit outside your regime.
Health, financial services, education and property marketing carry sector-specific advertising restrictions and sometimes pre-approval. Check the sector position before the general one.
Reflects UAE law and practice current as of {{DATE OF USE}}. Promotion permit requirements, Do Not Call and telemarketing rules, consumer price display obligations, influencer licensing, cybercrime provisions on content and imagery, and data protection regimes all differ by emirate and change — confirm with the relevant economic department and a UAE adviser before a significant campaign.
This is a ready-to-use template provided for convenience. Laws and requirements change, and every situation is different — please have it reviewed by a qualified professional (a lawyer, corporate secretary, or accountant as relevant) before you rely on it.