The UAE Turns Up the Volume on Music Rights

From December 2026, playing music in a UAE restaurant, hotel, mall or fitness center may carry greater legal and commercial significance.

The UAE Ministry of Economy & Tourism has introduced a new Collective Management Guide for Music (Ministerial Resolution No. 136 of 2026), establishing a framework for licensing the commercial use of music, published under Federal Decree-Law No. 38 of 2021 and its 2022 implementing regulations.

The framework potentially affects restaurants, cafés, hotels, shopping malls, fitness centres, airlines, broadcasters, concerts and other commercial users. Licences will generally be issued annually, with fees varying according to factors, including the nature of the music use and the scale of the economic activity.

But this development is about more than another licence for businesses. It could fundamentally change how music rights are monetised in the UAE.

From background music to royalties

A song is rarely protected by a single right.

The composer, lyricist, performer, producer, publisher and record label may each hold different rights in the same recording. When a business plays that recording for customers, it is commercially using protected music.

Collective management organisations (CMOs) solve a practical problem: businesses cannot realistically negotiate licences with every rights holder represented on their playlists.

Instead, CMOs represent repertoires, license users, collect royalties and distribute proceeds to the rights holders they represent.

The UAE Copyright Law already provides the legislative basis for collective management. The new framework takes the market another step forward by creating a more structured mechanism for turning commercial music use into royalty income.

The Ministry authorised two music CMOs in 2025: the EMRA (Emirates Music Rights Association) and MusicNation.

A UAE licence with international reach

Collective management is not limited to UAE artists.

A Dubai hotel might play an Emirati artist followed by a French composer, Turkish songwriter and American recording artist. Each may have rights capable of generating royalties.

International representation and reciprocal arrangements can connect collections in the UAE with rights holders overseas, and potentially allow UAE creators to receive royalties when their works are used abroad.

EMRA, for example, entered into a representation agreement with French collective management society SACEM in February 2026. MusicNation has also announced partnerships with international rights organisations including BMI and SoundExchange.

The significance is clear: the UAE is not simply creating a domestic music licence. It is increasingly connecting its music market to the international royalty ecosystem.

The difficult question: what was actually played?

Collecting licence fees is only half the challenge.

If a mall, hotel or broadcaster uses thousands of tracks during a year, how will the relevant CMO determine which rights holders should receive the money?

Effective collective management depends on reliable usage data, potentially including playlists, broadcaster logs, reporting systems, digital data feeds and automated music-recognition technology.

The system ultimately needs to establish what was played, where, when and how often; which organisation represents the relevant rights; and who is entitled to the resulting royalty.

Transparency will therefore be critical. Businesses need to understand what they are paying for, while rights holders need confidence that royalties are being allocated accurately and fairly.

“But we already pay for Spotify”

This is likely to be a common question.

Paying for access to music is not necessarily the same as obtaining the rights required to perform or communicate that music publicly in a commercial environment.

Consumer streaming subscriptions are generally intended for personal use. Even with commercial music services, the important question is: what rights does the service actually license?

If a provider has secured the necessary rights for commercial use of its repertoire in the UAE, requiring an overlapping licence could raise questions of double licensing. If it merely provides access to recordings, however, the venue may still require additional rights.

Businesses should therefore examine the rights behind their music services, rather than assuming that paying a subscription resolves the copyright issue.

What about direct licensing and music-tech platforms?

An equally interesting question arises for platforms that contract directly with composers, songwriters or independent artists and then license that catalogue to commercial users.

There is an important distinction between:

• Direct licensing: where a platform has sufficient rights in a catalogue to license specified uses; and

• Collective management: where an organisation manages rights for multiple third-party rights holders, collects royalties and distributes them back to those rights holders.

The distinction matters because collective management activities are regulated under UAE copyright law.

As new business models emerge, one of the key questions will therefore be:

When is a company licensing a catalogue it controls, and when is it collectively managing copyright on behalf of others?

The answer could have important implications for music platforms, publishers, labels, music libraries and technology businesses entering, as well as already present in the UAE market.

What should businesses do before December?

Commercial users of music should start by mapping how music is used across their operations.

They should review streaming and music-supply agreements, determine whether subscriptions are personal or commercial, identify which rights are already covered, review arrangements with DJs and entertainment providers, and assess whether different areas of the business require different licensing treatment.

Music platforms and technology businesses face a different set of questions: Who owns or controls the repertoire? What rights can be sublicensed? Is the platform licensing its own catalogue or administering rights for third parties? Could its activities constitute regulated collective management?

The sound of a more mature music market

The UAE's new framework is ultimately about much more than charging businesses for background music.

It represents another step in the development of the country's copyright infrastructure: moving from recognising music rights in law to building mechanisms capable of licensing those rights, tracking their use, collecting their value and paying creators.

The real test will be implementation.