TRW & Co · Healthcare
Telemedicine and Digital Health in the UAE: Licensing Telehealth Platforms
A telemedicine licence UAE regulators issue comes from the health authority of the emirate where the service sits: the DHA in Dubai, the DOH in Abu Dhabi or MOHAP in the northern emirates. Telehealth must be delivered by a licensed facility using UAE-licensed clinicians, on approved platforms, with health data generally kept in the UAE. Here is how to launch compliantly.
Key pointMost telehealth launches stall on two structural points rather than paperwork: clinicians must hold UAE licences through a UAE-licensed facility, and patient data must generally stay in the UAE, so overseas doctors and foreign cloud regions need redesigning before any application.
At a glance
Licensed by each emirate
The DHA, DOH and MOHAP each license telehealth in their own jurisdiction, and Dubai Healthcare City operates a separate free zone healthcare regime.
Federal telehealth controls
Cabinet Resolution No. 40 of 2019 added telehealth controls to the medical liability regulations, covering licensing, insurance, technical standards and data protection.
Platforms need approval
The DHA requires telehealth services and platforms to be DHA-licensed, while DOH licences in Abu Dhabi specify each telemedicine service a facility may provide.
Data stays in the UAE
Federal Law No. 2 of 2019 generally prohibits storing or processing health data relating to UAE health services outside the country, subject to exceptions.
Apps may be devices
The 2024 medical products law covers AI-based and wearable medical equipment, so diagnostic or monitoring software may need EDE marketing approval.
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A telemedicine licence UAE regulators grant is not a single national permit. Remote consultations, telediagnosis, remote monitoring and e-prescribing are licensed by the health regulator of the emirate where the service is provided: the Dubai Health Authority (DHA) in Dubai, the Department of Health (DOH) in Abu Dhabi and the Ministry of Health and Prevention (MOHAP) in the northern emirates, with Dubai Healthcare City running its own regime.
This guide explains the federal rules behind telehealth, how each regulator licenses services and platforms, the health data rules that shape the technology, and the steps to launch a compliant digital health service.
Telemedicine licence UAE: the short answer
- A licensed health facility. Telehealth is provided by a facility licensed by the relevant health regulator, either as a dedicated telehealth provider or as a service added to an existing facility licence.
- Licensed clinicians. Doctors and other professionals who treat patients remotely need a professional licence from the UAE regulator concerned, linked to the licensed facility.
- A licensed platform. In Dubai, the DHA requires telehealth services and platforms to be licensed by it. In Abu Dhabi, the DOH licence specifies which telemedicine services are authorised.
- Health data kept in the UAE. Federal law generally prohibits storing or processing health data relating to UAE health services outside the country, unless an exception applies.
Digital health products that diagnose, monitor or treat may also be medical devices, which brings in a separate product approval from the federal medicines regulator.
The legal framework for telehealth
Federal rules
Telehealth is regulated as healthcare delivered by other means. The federal medical liability law, Federal Decree-Law No. 4 of 2016, sets standards of practice and liability for medical errors. Cabinet Resolution No. 40 of 2019 added federal telehealth controls to the executive regulations of that law, requiring telehealth establishments to obtain licences from the competent authorities and to meet technical, staffing, insurance and data protection requirements.
Federal Law No. 2 of 2019 on the use of information and communications technology in health fields applies across the UAE, including free zones. Our guide to health data in the UAE covers it in depth; its key telehealth points are discussed below.
Emirate-level rules
Each health regulator issues its own telehealth standards. The DHA's Telehealth Policy covers teleconsultation, telediagnosis, telemonitoring, mHealth, telerobotics and telepharmacy. The DOH's Standard on Tele-Medicine sets the licensing, prescribing, consent and data requirements in Abu Dhabi. MOHAP regulates the northern emirates.
| Location | Regulator | How telehealth is licensed |
|---|---|---|
| Dubai (outside DHCC) | Dubai Health Authority | Telehealth services and platforms must be DHA-licensed, in categories including call centre, telebooth and add-on services |
| Dubai Healthcare City | DHCC's regulatory arm | Free zone healthcare regime with its own facility and professional licensing |
| Abu Dhabi, Al Ain and Al Dhafra | Department of Health | DOH licence required; new licence or service added to an existing licence, specifying each telemedicine service |
| Northern emirates | Ministry of Health and Prevention | Federal licensing under the telehealth controls, with local authorities involved in some emirates |
How telemedicine licensing works in practice
Dubai
The DHA's Telehealth Policy applies to DHA-licensed professionals and facilities providing telehealth. It requires that all telehealth services and platforms be licensed by the DHA, and that providers meet national cyber security standards, telecoms requirements for voice-over-internet channels and Dubai Electronic Security Center requirements. Providers must also follow Dubai Health Insurance Corporation rules on telehealth approvals, e-claims and reimbursement.
Abu Dhabi
The DOH standard states that a DOH licence is required to provide telemedicine. A facility may apply for a new licence or add telemedicine to an existing one, and the licence specifies the services authorised. Some services are limited to certain facility types: tele-interventions, for example, are restricted to hospitals and facilities with surgical services.
Professionals do not need a separate telemedicine licence, but they need a DOH professional licence, must be privileged by their facility and should show appropriate telemedicine training.
Tele-prescribing
Prescribing remotely is the most tightly controlled activity. Under the DOH standard, the prescribing physician must be licensed in the UAE and work for a facility licensed for telehealth, must have real-time audio and video contact with the patient, and must refer the patient for a face-to-face consultation where the treatment plan is uncertain. Emergencies, conditions needing physical examination and invasive procedures are excluded, and controlled medicines follow federal and DOH rules.
Choosing an operating model
Before applying for a telemedicine licence UAE regulators will accept, decide which of three broad models fits the business. Each carries different licensing, liability and investment consequences.
- Add-on service at an existing facility. A licensed hospital or clinic adds telehealth to its licence and uses its own licensed clinicians. This is usually the fastest route, because the facility, governance and insurance already exist; the work lies in platform approval, policies and data hosting.
- Dedicated telehealth provider. A new entity is licensed specifically to deliver remote care, for example through a call centre model. It typically needs suitable premises from which clinicians operate, licensed staff, clinical leadership and full clinical governance, but it owns the patient relationship and the brand.
- Technology platform partnering with licensed providers. A software company supplies the platform while licensed facilities deliver care. This limits clinical liability but requires careful drafting so that the platform does not, in substance, become the provider, and the platform itself may still need regulatory approval.
Investors should also note that the regulator's view of who provides care drives everything else: which entity holds the telemedicine licence UAE authorities issue, who employs the clinicians, who bills insurers and who answers a malpractice claim. Getting this right at the term-sheet stage avoids restructuring later.
The northern emirates and Dubai Healthcare City
In Sharjah, Ajman, Umm Al Quwain, Ras Al Khaimah and Fujairah, MOHAP applies the federal telehealth controls, with local health authorities involved in some emirates. Dubai Healthcare City operates as a healthcare free zone with its own regulatory arm, so a provider licensed there follows DHCC rules rather than DHA rules. In each case the same federal health data law applies.
The biggest structural decision is where the clinicians sit. A foreign doctor without a UAE licence cannot simply consult UAE patients through your app. The workable models are UAE-licensed clinicians working for a UAE-licensed facility, or a UAE facility that keeps responsibility for the patient and uses overseas specialists in a regulated second-opinion or diagnostic role.
Health data, hosting and cyber security
Federal Law No. 2 of 2019 shapes the technology stack. Article 13 prohibits storing, processing, generating or transferring health data outside the UAE where it relates to health services provided in the UAE, except as permitted by decisions of the health authorities. The DHA policy refers to Ministerial Decision No. 51 of 2021 for the exceptions.
The law also requires health data to be retained for at least 25 years from the last health procedure, and sets significant fines for breaching the localisation rule. The DOH standard requires servers and backup servers to be in the UAE and compliance with the Abu Dhabi Healthcare Information and Cyber Security Standard.
The federal Personal Data Protection Law treats health data as sensitive, so consent, transparency and security controls matter even where the sector law is the primary rule. Our guide to cross-border data transfers and localisation explains how the regimes interact.
For a telemedicine licence UAE regulators will look as closely at where your data sits as at who your doctors are.
Digital health products and medical devices
Not every digital health product is a telehealth service. Symptom checkers, remote monitoring devices, diagnostic algorithms and wellness apps may instead, or also, be regulated products.
Federal Decree-Law No. 38 of 2024 on medical products, in force since 2 January 2025, defines medical equipment to include wearable and AI-based products that work without a pharmaceutical effect. Such products need marketing approval from the Emirates Drug Establishment before they are placed on the market. Our guide to medical devices regulation explains that process.
Promoting telehealth services and health apps also engages healthcare advertising rules; see our guide to healthcare advertising in the UAE.
Launching a telehealth service: step by step
- Define the service model. Decide which services you will offer (teleconsultation, telediagnosis, remote monitoring, e-prescribing, telepharmacy) and whether any software is a medical device.
- Choose the emirate and regulator. Pick where the licensed facility will sit, which determines the regulator, the standards and the patient population you can serve.
- Set up the legal entity. Establish the onshore or free zone company and obtain the commercial licence that supports a health activity. See our guide to healthcare licensing in the UAE.
- License the facility or add the service. Apply for a telehealth facility licence or add telehealth to an existing facility licence, and license the platform where required.
- License clinicians. Obtain professional licences for every clinician, linked to the facility, and document privileging and telehealth training.
- Build compliant infrastructure. Host data in the UAE, meet cyber security standards, connect to the health information exchange where required and document data flows.
- Prepare policies and contracts. Put in place consent, clinical governance, referral, records, complaints and insurer arrangements, and contracts with technology vendors.
- Go live and monitor. Track performance reporting, incidents and complaints, and renew licences and insurance on time.
An illustrative scenario
This scenario is illustrative only and does not describe a real matter.
A digital health start-up wants to offer video consultations to UAE residents using doctors in several countries and a cloud platform hosted in Europe. It also plans an AI symptom checker that suggests whether users need urgent care.
To obtain a telemedicine licence UAE regulators will accept, the start-up would need to rethink three things. First, consultations must be delivered by a UAE-licensed facility using clinicians licensed in the relevant emirate. Second, patient data would need to be hosted in the UAE unless an exception applies. Third, the symptom checker may be a medical device requiring separate EDE approval. A common route is to partner with an existing licensed facility while building its own licensing case.
Risks and common mistakes
Launching on a commercial licence alone
A trade licence for IT or consultancy activity does not authorise healthcare. Without a health facility licence, the business is providing unlicensed medical services, and clinicians acting through it risk their own licences. Platforms that only connect patients with independently licensed facilities sit closer to the line, but their contracts and user journeys must make clear who provides care. Regulators look at substance: who employs the clinicians, who sets prices and who holds the patient relationship.
Hosting patient data overseas
Global platforms often default to cloud regions in Europe or the United States. For health data relating to services in the UAE, that conflicts with the federal localisation rule unless an exception applies, and the DOH standard expressly requires UAE-based servers. Backups, analytics tools, support desks and AI vendors can all move data abroad without anyone noticing. Map every data flow before launch and use UAE regions and processors where needed.
Using unlicensed or foreign-licensed clinicians
Patient demand for overseas specialists is real, but treating UAE patients requires a UAE professional licence. Second-opinion and diagnostic partnerships can be structured, with the UAE facility retaining responsibility for the patient and the foreign partner meeting its home regulator's rules and insurance requirements. What does not work is a foreign doctor consulting and prescribing directly for UAE patients through an app.
Treating software as outside regulation
Founders often assume an app is "just software". If it is intended to diagnose, monitor or guide treatment, it may be a medical device under the 2024 medical products law, which expressly covers AI-based products. Marketing it without EDE approval is a breach separate from any telehealth licensing issue. Classify each product early, and keep the intended-use statements in your marketing consistent with the regulatory position.
Ignoring insurance and liability
The federal medical liability framework applies to remote care as it does to in-person care, and telehealth establishments must meet insurance requirements. Professional indemnity cover should expressly include telehealth, and contracts with technology vendors should address outages, data incidents and allocation of liability. Insurer approval and e-claims rules also determine whether patients can be reimbursed.
Cross-border telehealth
Overseas hospitals and telehealth companies, including from the UK, India, Singapore and Bangladesh, often want to serve UAE patients. The regulatory answer is usually a UAE footprint: a licensed facility, UAE-licensed clinicians and UAE-hosted data. International specialists can then contribute through structured referral or second-opinion arrangements.
The reverse also applies. A UAE provider offering consultations to patients abroad must check the rules of the patient's country, which may require local licensing or prohibit cross-border prescribing. Contracts should allocate regulatory responsibility clearly on both sides.
Checklist: what to do next
- List every service you will offer and confirm which regulator licenses each one.
- Decide whether any software or device is a medical device needing EDE approval.
- Choose the emirate, entity type and facility licence route for your telemedicine licence UAE application.
- Confirm every clinician will hold a UAE professional licence linked to the facility.
- Map data flows and host health data in the UAE unless an exception applies.
- Prepare consent, prescribing, referral, records and complaints policies.
- Confirm professional indemnity and other insurance expressly cover telehealth.
- Review marketing against healthcare advertising rules before launch.
TRW & Co supports telehealth providers, digital health companies and investors with structuring, licensing strategy, technology contracts and data compliance, as part of our healthcare regulation practice. Where a dispute or claim arises, see our guide to medical malpractice in the UAE. To discuss your plans, contact us at info@trw.co or +971 58 942 1012.
Frequently asked questions
01Do I need a separate licence for telemedicine in the UAE?
Telehealth must be provided by a health facility licensed by the relevant regulator. In Abu Dhabi, the DOH requires a licence for telemedicine, either as a new facility licence or as a service added to an existing one. In Dubai, the DHA requires telehealth services and platforms to be DHA-licensed. Clinicians generally do not need a separate telemedicine licence but must hold a professional licence from the regulator concerned, linked to the facility.
02Can a doctor outside the UAE consult UAE patients online?
Not directly as the treating clinician. UAE patients must be treated by clinicians licensed in the UAE through a UAE-licensed facility, and the DOH standard requires prescribers to be UAE-licensed. Overseas specialists can contribute through structured second-opinion, diagnostic or referral arrangements in which the UAE facility keeps responsibility for the patient and the foreign partner complies with its home regulator's rules and insurance requirements.
03Can telehealth doctors prescribe medicines in the UAE?
Yes, within limits. In Abu Dhabi, the DOH standard requires the prescriber to be UAE-licensed and working for a facility licensed for telehealth, to have real-time audio and video contact with the patient, and to refer for a face-to-face visit where the plan is uncertain. Emergencies and conditions needing physical examination are excluded, and controlled medicines follow federal and DOH rules. Dubai and MOHAP apply their own requirements.
04Can a UAE telehealth platform host data in a foreign cloud?
Generally not for health data relating to health services provided in the UAE. Article 13 of Federal Law No. 2 of 2019 prohibits storing, processing or transferring such data outside the UAE except as permitted by health authority decisions, and the DOH standard requires servers and backups to be in the UAE. Breaching the localisation rule can lead to substantial fines, so platforms usually use UAE cloud regions and processors.
05Is a health app a medical device in the UAE?
It can be. Federal Decree-Law No. 38 of 2024 defines medical equipment to include wearable and AI-based products that act without a pharmaceutical effect. If an app or algorithm is intended to diagnose, monitor or guide treatment, it may need marketing approval from the Emirates Drug Establishment before it is placed on the market. General wellness apps may fall outside, but intended-use wording and marketing claims matter.
Sources and official materials
- DHA Telehealth Policy — Licensing of telehealth services and platforms in Dubai
- DOH Standard on Tele-Medicine — Telemedicine licensing, prescribing and data rules in Abu Dhabi
- ICT in the health sector (u.ae) — Federal Law No. 2 of 2019 on ICT in health fields
- Dubai Health Authority — Health regulator for Dubai
- Emirates Drug Establishment — Federal regulator of medical products, including medical devices
- Dubai Healthcare City — Healthcare free zone with its own regulatory arm
General information only, current as at 27 October 2026. It is not legal advice and does not create a lawyer–client relationship. UAE law differs between the onshore jurisdiction, the DIFC, ADGM and the free zones, and changes frequently; check current official sources and take advice on the facts of your matter.
