Electronic Transactions Penalties

Lists the violations and administrative fines for trust service providers and other persons breaching the electronic transactions law and its executive regulations, such as operating without a licence, failing security or audit obligations, or misusing certificates, and sets the escalation for repeat violations.

Official title
Cabinet Resolution No. 52 of 2024 Concerning the Administrative Penalties for Violating the Provisions of Federal Decree-Law No. 46 of 2021 Concerning Electronic Transactions and Trust Services and its Executive Regulations
Instrument
Cabinet Resolution No. 52 of 2024
Issued by
UAE Cabinet
Jurisdiction
UAE Federal
Dates
issued 15 May 2024 · in force 1 June 2024
Status
in force
Topics
Electronic transactions
Official source
uaelegislation.gov.ae · official text (PDF)
Verified
25 October 2026

Summary

Cabinet Resolution No. 52 of 2024 is the fine schedule for the electronic transactions regime. Issued on 15 May 2024 and in force from the day after Official Gazette publication (1 June 2024), it lists 22 violations of Federal Decree-Law No. 46 of 2021 and its executive regulations (Cabinet Resolution No. 28 of 2023) and the administrative fine for each, and it repealed Ministry of Economy Resolution No. 1 of 2008 on certification service providers (Article 7).

Article 2 lets the Telecommunications and Digital Government Regulatory Authority (TDRA) fine anyone who breaches the decree-law or its regulations according to the attached table, double the fine for a repeat violation within one year or where the violator fails to correct its position within the deadline set, and preserves harsher penalties under other laws. Article 3 lets the Cabinet amend the table, Article 4 gives any interested party a reasoned written appeal to the TDRA Director General within 14 days of notice, Article 5 has fines collected by Ministry of Finance methods and Article 6 leaves implementing resolutions to the TDRA Chairman.

The table is aimed at licensed and unlicensed trust service providers. Operating after a licence expires costs AED 500 per day for up to 90 days, after which suspension is available; starting to operate without completing renewal within 30 days of expiry costs AED 300 per day up to AED 9,000. Advertising services without a licence or after expiry, ignoring a suspension or cancellation order, failing to follow controls on relying on specialised expertise, failing to run safe and reliable systems and failing to follow termination procedures each cost AED 50,000. Violating an order to stop activities, transferring the licence or changing ownership without approval, publishing information that conflicts with TDRA records, failing technical standards, acting unfairly in operations or marketing, breaching pre-suspension contracts and using an authorised person's capacity without a covering licence each cost AED 20,000. Failing general obligations under the law, regulations or directives costs AED 15,000. Withholding records from the TDRA, obstructing an inspection, misusing the accredited trust mark, failing to tell relying parties the assurance level of a digital identity, lacking complaint and account suspension mechanisms, and failing to help transfer clients to another provider each cost AED 10,000.

Status: in force; no amendment recorded. There is no criminal penalty in this resolution; the fines sit alongside whatever the decree-law and the Penal Code provide.

Who it applies to

Trust service providers and qualified trust service providers licensed by the TDRA, former licensees whose licence has expired or been suspended or cancelled, persons advertising or providing electronic signature, seal, time stamp or digital identity services without a licence, and accredited providers using the trust mark. The TDRA imposes the fines and hears appeals.

Key provisions

Article 2The TDRA fines violators of the decree-law or its executive regulations per the attached table; fines double for a repeat violation within one year or for failing to correct within the deadline; harsher penalties under other laws are preserved.
Article 3The Cabinet may add to, remove or change the fines on the TDRA's proposal.
Article 4Any interested party may file a reasoned written appeal with supporting documents to the TDRA Director General within 14 days of being notified of the fine.
Article 5Fines are collected by the methods set by the Ministry of Finance.
Article 7Repeals Ministry of Economy Resolution No. 1 of 2008 on the regulation of certification service providers and any conflicting provision.
Article 8Published in the Official Gazette and in force from the day following publication.
Table22 violations with fixed fines: AED 300 or AED 500 per day for late renewal or expired operation; AED 10,000, AED 15,000, AED 20,000 or AED 50,000 for the remaining violations, from withholding records up to unlicensed advertising and ignoring suspension orders.

Penalties

AED 300 per day (maximum AED 9,000) for resuming services without completing renewal within 30 days of expiry; AED 500 per day for up to 90 days for operating after expiry, then suspension; AED 10,000 for withholding records, obstructing inspection, misusing the trust mark, not disclosing identity assurance levels, lacking complaints mechanisms or not helping clients transfer; AED 15,000 for breaching general obligations; AED 20,000 for ignoring stop orders, unapproved licence transfers or ownership changes, conflicting publications, technical failures, unfair conduct, breaching pre-suspension contracts or acting outside the licence; AED 50,000 for unlicensed advertising, ignoring suspension or cancellation orders, expertise controls, unsafe systems or termination failures. All double for repetition within one year.

In practice — how Polaris handles it

This schedule matters to two kinds of client. The first is the handful who want to operate signature, identity or certificate services in the UAE: the AED 50,000 fine for advertising before the TDRA licence issues means the marketing site waits until the licence exists, and we structure the entity so the licence holder, its ownership and its authorised signatories match the TDRA file, because an unapproved ownership change or transfer is a separate AED 20,000 line. The second is every client who signs through an online platform: the fines fall on the provider, not the signer, but a provider operating on an expired or suspended licence is exactly the one whose signatures a registrar may refuse, so we check the UAE Trust List before accepting platform-signed corporate documents for filing, and we recommend qualified providers for anything a bank or court will scrutinise.

Related instruments

Related Polaris services

Source and verification. This page was written from the official text published at uaelegislation.gov.ae, read on 25 October 2026. Quoted from that text: “Provide Trust Services or Accredited Trust Services after the Licence expires.”
This summary is published for general information by Polaris Corporate Services FZ-LLC, a licensed Trust and Corporate Service Provider. It is not legal advice and does not replace the official text, which prevails in case of difference. Arabic is the authoritative language of UAE federal and emirate legislation; English translations are provided by the issuing authorities. Instruments change: check the status and the official source before relying on this page.

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